It is the duty of every Employer to follow all WHMIS regulations, at both the Federal and Provincial level. WHMIS regulations apply to all substances that are classified as “controlled products,” and covers various safety requirements such as proper product labelling, identifying hazardous contents in piping systems/vessels, provision of critical safety information via Material Safety Data Sheets (“MSDS”) etc. This blog post touches on the most important aspects of WHMIS that Employers need to know.
Where controlled products are used, handled, stored, transported or disposed of at an Employer’s workplace, the Employer has three main WHMIS responsibilities:
- Ensuring controlled products are properly identified and labelled;
- Ensuring that MSDS are provided and present for each controlled product used;
- Properly educating and training all employees who may use or handle controlled products.
WHMIS Labelling (Supplier and Workplace Labels)
Every container of a controlled product must have a supplier label affixed in a conspicuous place on that container. These labels have very specific criteria including the requirement for a border, symbols representing the hazardous materials, and specific wording. Unless a container is emptied the label cannot be removed, damaged, or destroyed. If a supplier label is not provided by the manufacturer, or is not appropriate, the Employer’s workers cannot use the product until the proper label is obtained or is created and affixed to that container. If a supplier label was not provided with the specific container, but the Employer has extra supplier labels on hand from previous interactions with the supplier (or manufacturer), workers can apply these labels to the container, provided that the labels are specific for that product.
A workplace label has fewer requirements but must contain the name of the product, how to safely handle the product, and a notice that a MSDS is available. Some products do not require a MSDS (does not contain hazardous ingredients that have been classified as such) and more information on these specific materials can be found in the ‘Partial Exemptions’ section of the regulation.
Material Safety Data Sheets
Material Safety Data Sheets (“MSDS”) are required by law, and must be provided for each and every controlled product used or handled in the workplace. It is a technical bulletin that outlines specific hazard information, safe use/handling information, emergency procedures etc. Each MSDS, under Canadian Federal regulations must contain at least nine information categories in total; these include:
- Product Information: The product identity, contact information of the company or person who prepared the MSDS, emergency phone numbers, and the intended product use.
- Hazardous Ingredients: A list of all hazardous ingredients (by name, percent amount, associated chemical abstracts services number etc.) that make up the product.
- Physical Data: Details regarding the physical form/state, odour and appearance, and other physical attributes of the chemicals (e.g. vapour density, boiling point etc.).
- Fire & Explosion Data: Information regarding flammability/explosion conditions and risks, flammable limits, auto-ignition temperature, flash point, hazardous products of combustion, and fire control measures.
- Reactivity Data: Details outlining Instability and/or reactivity conditions, a of incompatible substances (to prevent dangerous reactions), and hazardous decomposition products.
- Toxicological Properties: Information regarding exposure routes, acute and chronic health effects, other health hazards, and exposure limits.
- Preventative Measures: Details of all required safety precautions regarding use, handling, storage, transportation, disposal, spill response and cleanup, as well as required personal protective equipment (“PPE”) controls.
- First Aid Measures: All required first aid and exposure treatment requirements.
- Preparation Information: Details regarding who prepared the MSDS (name(s), department, contact information), MSDS preparation date, revision date(s) etc.
It is important to note that by law, MSDS must be up-to-date and current to within three (3) years of the most recent date. The primary reason for this requirement is to ensure the most current health and safety information is provided to workers who need to use and handle the product.
WHMIS Training and Education
A crucial part of understanding and following WHMIS requirements is the education and training of your workers. While there are several online courses available, nothing takes the place of a customized, in person class. In a classroom setting, participants not only tend to learn more (and better), instructors can also review the Employer’s actual products, labels and specific MSDS with the very workers tasked to use those chemicals.
In summary, workers can safely use and handle chemical, controlled products provided that a proper WHMIS system has been established by their Employer, and all regulatory requirements have been followed, of which the last component is the education and training of workers in all safety protocols. Workers should never personally take their safety for granted when it comes to using hazardous controlled products.
About Craig Yee – Occupational Health and Safety Consultant in Vancouver
Craig Yee is an Industrial Hygienist and Principal of OHS Global Risk Solutions. He earned his Masters Degree in Occupational and Environmental Hygiene at the University of British Columbia. He has over 12 years of direct experience in the hygiene, health and safety industry in both public and private sectors. You can connect with him on Google+.