WHMIS changes on the horizon

Canada’s Workplace Hazardous Materials Information System (WHMIS) is going to change — after remaining essentially unchanged for more than two decades. WHMIS is a comprehensive program for providing information on the hazards and safe use of hazardous materials in Canadian workplaces.

WHMIS will be implementing the key elements of the Globally Harmonized System of Classification and Labelling of Chemicals (GHS). GHS was created several years ago to help standardize chemical hazard classification and communication worldwide. Once implemented, hazard information prepared in other countries will be easier to use in Canadian workplaces, as they will generally use the same hazard classification, labelling and data sheet rules. Currently, the WHMIS classification rules, label and MSDS requirements are unique to Canada.

While GHS will be implemented in Canada, it will not actually replace WHMIS. Instead, WHMIS will be modifi ed to incorporate GHS elements. There will be a new set of classification rules, label requirements, and Safety Data Sheet (SDS) requirements (the MSDS will be called an SDS). In Europe, GHS is already being implemented, and in the United States, the Occupational Safety & Health Administration (OSHA) recently announced proposed regulations.

How GHS will change WHMIS

Classification will be the first area of change. WHMIS will likely:

• adopt all of the GHS health and physical hazard classes, including some hazards new to Canada — aspiration (toxicity due to inhaling a substance into the lung), and specific target organ toxicity — single exposure hazards. However, not all categories (smaller parts) of every GHS class will be adopted.

• continue to include some hazards that are currently not in the GHS system, such as biohazardous materials.

• have more specific names for its hazard classes.

• combine two WHMIS classes (teratogenicity/ embryotoxicity and reproductive toxicity) into one new GHS hazard class — reproductive toxicity.

Supplier labels will also change, and will probably have a few new requirements. The most noticeable change will be new pictograms, as well as the use of a signal word — for example: Warning or Danger.

Depending on the hazard class and category, a specific signal word, hazard statement and symbol/pictogram will be required or prescribed, and must appear on the label.

It is still not clear, however, if the names of hazardous ingredients will be included on the label, or if the WHMIS hatched border will still be required.

SDSs will use a 16-section format. There will be standardized information requirements for each section. The nine-section WHMIS format for MSDSs will no longer be acceptable. Another important change to note is that the product classifi cation and some of the label information will probably be required on the SDS. The SDS updating requirements (every three years) may continue to be required.

Little change expected in Canada

The current roles and responsibilities for suppliers, employers and workers are not likely to change in any significant way because of GHS. Suppliers will still have to classify hazardous products and prepare SDSs and labels for their customers. What will change is that suppliers will now use the new classification rules, as well as prepare SDSs and labels according to the GHS requirements.

Employers will continue to make sure that their products are labelled and that SDSs are available to workers. Training and education will also continue to be vital to Canada’s WHMIS system, as employers must ensure staff are educated and trained properly about the new WHMIS and working safely with products. Workers will still have to learn about WHMIS but will learn about WHMIS and changes due to the adoption of GHS requirements, including new labels, pictograms and SDSs. They will continue to participate in training programs so that they know how to protect themselves and their co-workers in the workplace.

When will GHS be adopted in WHMIS?

A clear deadline has not been identified for full implementation but since Canadian regulations often take a year or two to move from initial draft to full implementation, the Canadian Centre for Occupational Heath & Safety (CCOHS), based in Hamilton, ON, expects that it may take Canada until after 2010 or 2011 to see the revised regulations come into force. Canada is likely to use a transition period to implement the new requirements and will likely try to harmonize implementation timing with its major trading partners.

In the United States, proposed regulations were published on September 30, 2009. It is not a final rule (the US is accepting comments) but a three-year transition period is proposed for full implementation. The European Union (EU) has published its GHS revised hazard communication rules, which will allow for implementation from 2010 to 2015 plus a two-year transition period.

CCOHS offers free resources to help you learn more about GHS and WHMIS after GHS. Read the OSH Answer fact sheet on the Globally Harmonized System (GHS) at www.ccohs.ca/oshanswers/chemicals/ghs.html.Also, you can take one or two free e-courses– WHMIS After GHS: An Introduction, at www.ccohs.ca/products/courses/whmis_ghs_intro/;and WHMIS After GHS: How Suppliers Can Prepare, at www.ccohs.ca/products/courses/whmis_ghs_suppliers/.