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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

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Page 1: WHMIS (after GHS) - Current Status and Resources · 2020-04-22 · Education and Training Requirements Reminder: WHMIS education, training and program requirements are outlined by

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

Page 2: WHMIS (after GHS) - Current Status and Resources · 2020-04-22 · Education and Training Requirements Reminder: WHMIS education, training and program requirements are outlined by

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

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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

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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

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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Ingredient Disclosure List also repealed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

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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

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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

Page 8: WHMIS (after GHS) - Current Status and Resources · 2020-04-22 · Education and Training Requirements Reminder: WHMIS education, training and program requirements are outlined by

A Quick Overview

8 Date

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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

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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

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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

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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

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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

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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

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Supplier Labels

Once a product is classified, GHS uses standardized

items

Pictograms

Signal words

Hazard statements

Precautionary statements

www.ccohs.ca 15 January 2015

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Supplier Label Elements

www.ccohs.ca 16 January 2015

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Pictograms

www.ccohs.ca 17 January 2015

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18 January 2015 www.ccohs.ca

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Signal Words

19

Only one will be used

Danger

Warning

… (or none)

www.ccohs.ca January 2015

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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

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www.ccohs.ca 21 January 2015

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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

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Some Items of Note...

23 Date

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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Training Requirements

43 Date

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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

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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

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Resources

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Hazardous Product Act – Amendments

47

www.ccohs.ca January 2015

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Hazardous Products Regulations (HPR)

48

Canada Gazette, Part I - Proposed Hazardous Products Regulations available at Canada Gazette website:

www.ccohs.ca January 2015

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Health Canada Web Site

49

www.ccohs.ca January 2015

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United Nations Economic Commission for Europe

50

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51

Examples from UNECE

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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

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53 www.ccohs.ca

Developed by Health Canada and CCOHS

Available at ccohs.ca

Updated: WHMIS Awareness Fact Sheets

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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

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CCOHS – OSH Answers (Fact Sheets)

55

www.ccohs.ca

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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

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CCOHS – Key Topic Page

57

www.ccohs.ca

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CANWrite™ – SDS Authoring Software

58

www.ccohs.ca 27/01/2015

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Posters and Publications

59

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CANLabel™ – Free Basic Web Version

60

www.ccohs.ca January 2015

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Getting Ready – National Initiatives

61

www.ccohs.ca January 2015

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WHMIS.org

62

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

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OSHA – United States

63

www.ccohs.ca January 2015

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OSHA

64

www.ccohs.ca

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Links

65

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

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Workplace

Impact –

Transition

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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

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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

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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

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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

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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

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Questions?

CCOHS has a free,

bilingual Inquiries Service

to support you!

72 October 31, 2014

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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

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Canadian Centre for Occupational Health and Safety

For further information:

Inquiries Service

1-800-668-4284

905-570-8094

Thank You

www.ccohs.ca