whmis (after ghs) - current status and resources · 2020-04-22 · education and training...
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Canadian Centre for Occupational Health and Safety
www.ccohs.ca
WHMIS (after GHS) -
Current Status and Resources
January 2015
Christopher Liddy, MSc Occupational Health & Safety Specialist
Who is ?
2 www.ccohs.ca
Canadian Centre for Occupational Health and Safety (CCOHS)
Established in 1978 by an Act of Parliament
Governed by a tripartite council
Promotes the total well-being – physical, psychosocial and mental health – of working Canadians
January 2015
Disclaimers
3
Amendments to Hazardous Products Act (HPA) received Royal Assent in June 2014
________
This presentation is accurate as to the August 9th, 2014 Canada Gazette Part I version of the proposed Hazardous Products Regulations (HPR) (Federal)
Changes may occur before final regulation is published
www.ccohs.ca January 2015
Timeline and Next Legal Steps
Hazardous Products Regulations
– Canada Gazette Part I occurred August 9, 2014
Public comment period – 30 days ending Sept. 8, 2014
Remaining steps:
• Health Canada to review comments
• Publish final regulation in Canada Gazette Part II
Goal: Amended regulations in force on or before June 1, 2015
www.ccohs.ca 4 January 2015
Changes
HPR repeals and replaces the Controlled Products Regulations (CPR)
Ingredient Disclosure List also repealed
Implements the GHS hazard classification criteria and hazard communication elements as per the 5th edition of the “Purple Book”
Aligns, as much as possible, with the OSHA Hazard Communication Standard (HCS 2012)
www.ccohs.ca 5 January 2015
Other Legislative Changes
Provinces, territories and federal occupational health and safety regulators must each adopt their own legislative changes
Will use a model OSH concept
Dates of enactment may vary
www.ccohs.ca 6 January 2015
Benefits of Aligning with GHS
Hazard classification criteria is more comprehensive
- improves ability to indicate severity of hazards
New hazards classes identified
Physical hazard criteria are consistent with TDG
Standardized language (hazard and precautionary statements)
Standardized SDS format and more comprehensive requirements
www.ccohs.ca 7 January 2015
A Quick Overview
8 Date
How Will WHMIS Change?
Once “WHMIS After GHS” has been implemented, there
will be:
new classification rules and hazard classes
new label requirements
new standardized format for Safety Data Sheets
www.ccohs.ca 9 January 2015
Hazard Classification
GHS Hazard Groups and Classes
www.ccohs.ca
Physical hazards – 16 classes
Health hazards – 10 classes
Environmental hazards – 2 classes*
*Not proposed for
implementation in WHMIS
10 January 2015
Hazard Classification
11
GHS PHYSICAL HAZARD CLASSES
Explosives* Pyrophoric liquids
Flammable gases Pyrophoric solids
Flammable aerosols Self-heating substances and mixtures
Oxidizing gases Substances and mixtures which, in
contact with water, emit flammable
gases
Gases under pressure Oxidizing liquids
Flammable liquids Oxidizing solids
Flammable solids Organic peroxides
Self-reactive substances and
mixtures
Corrosive to metals
www.ccohs.ca
Hazard Classification
GHS HEALTH HAZARD CLASSES
Acute toxicity Carcinogenicity
Skin corrosion/irritation Reproductive toxicity
Serious eye damage/eye irritation Specific target organ toxicity
– single exposure
Respiratory or skin sensitization Specific target organ toxicity
– repeated exposure
Germ cell mutagenicity Aspiration hazard
www.ccohs.ca 12
Hazard Classification
Plus, as proposed in HPR:
Combustible dusts
Simple asphyxiants
Pyrophoric gases
Physical hazards not otherwise classified (PHNOCs)
Biohazardous Infectious Materials
Health hazards not otherwise classified (HHNOCs)
www.ccohs.ca 13 January 2015
Hazard Classification
www.ccohs.ca 14
Each hazard class has at least one defined
hazard category
Identifies the degree of hazard within a hazard class
Category 1 is ALWAYS the highest level hazard within a
class
January 2015
Supplier Labels
Once a product is classified, GHS uses standardized
items
Pictograms
Signal words
Hazard statements
Precautionary statements
www.ccohs.ca 15 January 2015
Supplier Label Elements
www.ccohs.ca 16 January 2015
Pictograms
www.ccohs.ca 17 January 2015
18 January 2015 www.ccohs.ca
Signal Words
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Only one will be used
Danger
Warning
… (or none)
www.ccohs.ca January 2015
Hazard Statements
Examples:
Extremely flammable gas
Contains gas under pressure; may explode if heated
Fatal / Toxic / Harmful if inhaled
May cause cancer / Suspected of causing cancer
Tip! Wording of the hazard statement helps describe the degree of the hazard
www.ccohs.ca 20 January 2015
www.ccohs.ca 21 January 2015
Precautionary Statements
Advice on how to minimize or control hazards (storage, use, first aid, PPE, emergency)
Keep container tightly closed
Wear protective gloves/protective clothing/eye protection/face protection
Fight fire remotely due to the risk of explosion
Tip! May not identify all of the necessary control measures. Check the SDS for more information.
www.ccohs.ca 22 January 2015
Some Items of Note...
23 Date
Current Classes vs. New Classes
WHMIS Poisonous and Infectious Materials (Class D) is now divided into several distinct classes:
Acute toxicity
Specific Target Organ Toxicity – Repeated Exposure
Reproductive Toxicity (will include Teratogenicity/ Embryotoxicity)
Carcinogenicity
Respiratory or skin sensitization
Germ cell mutagenicity
Serious eye damage/eye irritation
Skin irritation
Biohazardous infectious materials
January 2015 www.ccohs.ca 24
Current WHMIS Classes
Substances and mixtures that react vigorously with water to release a toxic gas
Currently classified as Dangerously Reactive Material
Proposed to be classified in Acute toxicity
Specific labelling requirements set in proposed HPR
Biohazardous Infectious Materials
Proposed to be included in WHMIS (after GHS)
www.ccohs.ca 25 January 2015
New Hazard Classes
Aspiration Hazards
Chemical pneumonia, injury, or death due to entry of a liquid or solid directly through nose or mouth, or indirectly from vomiting, into the trachea and lower respiratory system
www.ccohs.ca 26 January 2015
New Hazard Classes
Single Target Organ Toxicity – Single Exposure (STOT – single)
Organ toxicity – specific, non-lethal toxic effects
Narcotic effects – central nervous system depression (drowsiness, narcosis, reduced alertness, loss of reflexes, etc.)
Respiratory tract irritation
www.ccohs.ca 27 January 2015
New Hazard Classes
Simply Asphyxiants
Means any gas that is liable to cause asphyxiation by the displacement of air (unconsciousness or death by suffocation)
(no pictogram)
www.ccohs.ca 28 January 2015
New Hazard Classes
Physical Hazards Not Otherwise Classified (PHNOC)
Health Hazards Not Otherwise Classified (HHNOC)
A way to capture hazards that are not included in the criteria for other classes
Note that HCS 2012 uses Hazards Not Otherwise Classified (HNOC)
(pictogram chosen as
applicable to the hazard)
www.ccohs.ca 29 January 2015
New Hazard Classes
Combustible Dusts
Mixture or substance that is in the form of a powder that, upon
ignition, is liable to catch fire or explode when dispersed in air or
an other oxidizing medium (proposed HPR definition)
Proposed HPR does not regulate products that are shipped in a
non-dust form which when processed would present a hazard*
*NOTE: HCS 2012 requires these products to be accompanied by a
label and SDS. WHMIS (after GHS) does not, but voluntarily providing
a label/SDS would not be viewed as non-compliant
www.ccohs.ca 30 January 2015
New - Ingredient Disclosure Rules
For a hazardous product that is a:
Material or substance: Chemical name, CAS number and other identifying information
Mixture: Chemical name (and CAS number, etc) and concentration (or concentration range) of all ingredients that classify for a health hazard and are present above the designated concentration limit for the category or subcategory
www.ccohs.ca 31 January 2015
Labels
Must be available in both official languages
- Can be two labels or a bilingual label
Pictogram, signal word and hazard statement(s) must be grouped together
• Must be clearly displayed
www.ccohs.ca 32 January 2015
Labels
Standardized information
Pictogram, signal word, hazard statement, precautionary statements are set out in Section 3 of Annex 3 of the GHS 5th edition purple book.
Where not available via GHS, the proposed HPR sets the requirements
www.ccohs.ca 33 January 2015
Labels (and SDSs)
Initial supplier identifier
In most cases, it is the contact information for the Canadian manufacturer or importer
- If the product is imported and used in the importers’ workplace only, the foreign supplier information may remain
www.ccohs.ca 34 January 2015
Big and Small Packaging
Bulk shipments
A labelling exemption exists for products sold without packaging
100 mL or less
Exempt only from requirement to have precautionary or hazard statements on the label
3 mL or less
Where label will interfere with normal use of product, product would be required to have a label that is durable and legible for transport and storage, not during use
www.ccohs.ca 35 January 2015
Workplace Labels
Requirements are not set in HPA/HPR
Provincial/territorial/federal OSH decision because this requirement affects the workplace
Likely:
Product name (matching the SDS product name)
Safe handling precautions, may include pictograms or other supplier label information
A reference to the SDS (if available)
www.ccohs.ca 36 January 2015
Safety Data Sheets
1. Identification (product and supplier)
2. Hazard(s) identification
3. Composition/information on ingredients
4. First-aid measures
5. Fire-fighting measures
6. Accidental release measures
7. Handling and storage
8. Exposure controls/ personal protection
www.ccohs.ca 37
9. Physical and chemical properties
10.Stability and reactivity
11.Toxicological information
12.Ecological information*
13.Disposal considerations*
14.Transport information*
15.Regulatory information*
16.Other information
January 2015
SDS: New Requirements
Product classification and label elements (listed in Section 2)
Information about any hazardous reaction produced by the product as a result of having followed instructions for use provided
Not new
Both official languages - two SDSs or a bilingual SDS
www.ccohs.ca 38 January 2015
Updates to Labels and SDSs
Must be accurate at the time of each sale or importation of the product
Update required when “significant new data” is available
- change in a category or subcategory of a hazard class
OR
- changes the ways to protect against the hazard
New
No requirement to update the SDS every three years in the absence of new information
www.ccohs.ca 39 January 2015
Updating Requirements
SDSs updated within 90 days
Labels updated within 180 days
If sale is within this window, supplier must ensure the SDS is otherwise up to date, and that the new information and the date it became available is transmitted, in writing.
www.ccohs.ca 40 January 2015
Exemptions
Explosive*
Cosmetic, device, drug
or food*
Pest control product*
Consumer product*
Wood or product made
of wood*
Nuclear substances
Hazardous wastes
Tobacco and tobacco
products
Manufactured article
No longer exempt
Flavours and fragrances
www.ccohs.ca 41 January 2015
But For Now...
SDS
Currently, GHS formatted SDSs are acceptable in Canada (via an Administrative Policy)
Labels
Labels must comply with current WHMIS requirements.
Addition of a GHS-style label is acceptable if...
- There is also a WHMIS compliant label
- The information on the GHS-style label does not conflict with the WHMIS compliant label
www.ccohs.ca 42 January 2015
Training Requirements
43 Date
Education and Training Requirements
Reminder:
WHMIS education, training and program requirements are outlined by provinces, territories and federal OSH agencies – timing of new laws may vary
___
SDS are already in transition
Labels - some GHS-style labels may already be in the workplace (okay as long as the WHMIS-compliant label is also present)
Transition to the new WHMIS requirements (HPA, HPR) will occur on June 1, 2015 (or before)
www.ccohs.ca 44 January 2015
Worker Education and Training
New hazard pictograms
New hazard classes
New labels and their required elements
The meaning of signal words and hazard statements found on labels and SDSs
The new SDS format and how to locate information needed to work safely with a product
Worksite-specific training on measures to work safety with hazardous products
www.ccohs.ca 45 January 2015
Resources
Hazardous Product Act – Amendments
47
www.ccohs.ca January 2015
Hazardous Products Regulations (HPR)
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Canada Gazette, Part I - Proposed Hazardous Products Regulations available at Canada Gazette website:
www.ccohs.ca January 2015
Health Canada Web Site
49
www.ccohs.ca January 2015
United Nations Economic Commission for Europe
50
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Examples from UNECE
Updated: WHMIS Awareness e-Courses
52
Non-certificate
30 minutes and 1 hour in length
Online courses
Developed by Health Canada and CCOHS
Available at ccohs.ca
www.ccohs.ca January 2015
53 www.ccohs.ca
Developed by Health Canada and CCOHS
Available at ccohs.ca
Updated: WHMIS Awareness Fact Sheets
WHMIS (after GHS) for Workers
54
This educational CCOHS e-course has been developed with the support and input of Health Canada. It has also been reviewed by regulators, labour, suppliers and employers.
Based on the amended HPA and proposed HPR
Will produce an online certificate
Provides education on key WHMIS requirements
Does not replace workplace-specific training
Available now! Free for individual Canadians
www.ccohs.ca January 2015
CCOHS – OSH Answers (Fact Sheets)
55
www.ccohs.ca
CCOHS – OSH Answers (Fact Sheets)
56
Current WHMIS topics will be updated to reflect changes.
Classification
Labels
SDSs
Education and Training
Glossary of Terms
Plus a number of OSH Answers on hazards and how to work safety with them.
www.ccohs.ca January 2015
CCOHS – Key Topic Page
57
www.ccohs.ca
CANWrite™ – SDS Authoring Software
58
www.ccohs.ca 27/01/2015
Posters and Publications
59
CANLabel™ – Free Basic Web Version
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www.ccohs.ca January 2015
Getting Ready – National Initiatives
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www.ccohs.ca January 2015
WHMIS.org
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This national WHMIS web portal will be available Dec. 2014, and will provide:
Status and timing of regulatory changes for every jurisdiction
Links to regulations, consultation documents, etc.
Information and resources for different audiences (employers, suppliers, workers, trainers, etc.)
New/updated resources will be developed over time and shared through this portal.
www.ccohs.ca January 2015
OSHA – United States
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www.ccohs.ca January 2015
OSHA
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www.ccohs.ca
Links
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Justice Laws Website: http://laws-lois.justice.gc.ca/eng/acts/H-3/nifnev.html
Gazette I: http://gazette.gc.ca/rp-pr/p1/2014/2014-08-09/html/reg1-eng.php
Health Canada: http://www.hc-sc.gc.ca/ewh-semt/occup-travail/whmis-simdut/ghs-sgh/index-eng.php
UNECE: http://www.unece.org/trans/danger/publi/ghs/ghs_welcome_e.html
CCOHS: http://www.ccohs.ca
OSHA: http://www.osha.gov/dsg/hazcom/index.html
www.ccohs.ca January 2015
Workplace
Impact –
Transition
What Will Stay the Same?
Suppliers will:
Classify their products
Prepare labels and SDSs for products
Provide labels and SDSs to their customers
www.ccohs.ca 67 January 2015
What Will Stay the Same?
Employers will:
Make sure all hazardous products are properly labelled
Make up-to-date SDSs readily available to workers
Provide worker education and training
Make sure appropriate control measures are in place to
protect the health and safety of workers
www.ccohs.ca 68 January 2015
What Will Stay the Same?
Workers will:
Participate in education and training programs
Take the necessary steps to protect themselves and
their coworkers
Participate in identifying and eliminating hazards
www.ccohs.ca 69 January 2015
Workplace Impact - Transition
Anticipated transition period of 2-3 years with
both current/new WHMIS until products clear supply
chain
Education and Training
Educate on WHMIS after GHS (label, pictograms,
SDS) for all workers PLUS current WHMIS for new
workers?
Workplace specific training on safe work practices
www.ccohs.ca 70 January 2015
Workplace Impact - Transition
Accurate inventory is critical
Review MSDS / SDS
Manage MSDS and SDS until all old products cleared?
Watch as products arrive and adjust program as necessary
Re-label old products with new labels if still on shelves
Choose safer products to simplify training, improve safety
www.ccohs.ca 71 January 2015
Questions?
CCOHS has a free,
bilingual Inquiries Service
to support you!
72 October 31, 2014
Frequently Asked Questions
1. When will the new WHMIS be starting?
2. When and what do I educate and train workers on?
3. Have a GHS SDS for my product – is that okay?
4. Have a GHS label on my product – is that okay?
5. With the new WHMIS, does the new rule mean I don’t
need to worry about updating SDSs?
www.ccohs.ca 73 January 2015
Canadian Centre for Occupational Health and Safety
For further information:
Inquiries Service
1-800-668-4284
905-570-8094
Thank You
www.ccohs.ca