Canada WHMIS 2015 Transition - What's the Status Now?

Written By: Atanu Das on Monday, April 30, 2018

In a recent update by Health Canada, the WHMIS 2015 transition period was discussed. The main points mentioned were that the deadline for distributors, manufacturers and employers is still on track for December 1, 2018, both Canadian and US hazard communication requirements can be met using a single label and SDS, and Health Canada uses a graduated approach to non-compliance.

Some good practices for Distributors to prepare for the transition from WHMIS 1988 to the new standard include: 

• Meet with suppliers to develop a transition plan with milestones and responsibilities

• Establish and maintain an accurate list of all hazardous products in stock and whether they are WHMIS 1988 or WHMIS 2015 compliant.

• Plan to sell through WHMIS 1988 stock before September 1, 2018 

• Communicate with your customers to help ensure new labels and SDSs meet their needs for WHMIS 2015

For Employers, the following practices were recommended:

• Understand how the hazard classification in the two WHMIS criteria differ. This means that some products may have different and in some cases, new hazards not previously classified.

• Review your training processes and materials to make sure they are 2015 ready. As long as you have both older and new products in the workplace, you will need to educate your employees on both requirements.

• Communicate with your supplier to make sure new shipments contain 2015 SDSs and labels and provide them as soon as they are available.

• Plan to use up or safely dispose of 1988 stock or relabel them with 2015 compliant labels, prior to the deadline.

As part of its compliance and enforcement efforts, Health Canada performed a Safety Data Sheet Audit Project and reviewed 188 publicly available SDSs to determine HPA and HPR compliance. While not yet finalized, the preliminary findings determined that these sections of the SDS had the following prevalence of non-compliance:

These high numbers suggest that better training should be performed when complying with the new WHMIS standard. If you are exporting to or from Canada, let us assist you with your compliance needs.

**Portions of this blog post are excerpted from the Health Canada presentation given at the April 24, 2018 Society for Chemical Hazard Communication plenary session.