SDS Updates Every Three Years?
Written By: Atanu Das on Sunday, January 20, 2019
Many manufacturers continue to express confusion on how often SDSs need to be updated. Let's take a look at how Canada and the US requirements compare.
Canada
Implemented by Health Canada, the original WHMIS 1988 rules required manufacturers to review and update safety data sheets every three years. Since then, WHMIS 2015 has superseded and implements new GHS rules. Health Canada explains what's changed as follows:
Under WHMIS 2015, the supplier of a hazardous product is responsible for ensuring that the label and SDS are accurate, up-to-date and compliant with the HPR at the time of every sale or importation of the hazardous product.
This obligation also existed under WHMIS 1988; however, there was also a provision that required suppliers to review and update SDSs every three years. Although this provision has not been retained under the Hazardous Products Regulations (HPR), the level of protection offered to workers is maintained because suppliers have an ongoing responsibility to ensure that the SDS is accurate, up-to-date and compliant with the HPR at the time of every sale or importation of the hazardous product.
In addition to supplier WHMIS requirements, which are set out under the Hazardous Products Act and the HPR, there are employer WHMIS requirements under provincial, territorial and federal occupational safety and health laws and regulations. Employers are required to ensure that hazardous products in the workplace are properly labelled, SDSs are made available to workers, and workers receive education and training to ensure the safe storage, handling, disposal and use of hazardous products in the workplace. Under WHMIS 2015, some provincial, territorial or federal jurisdictions may continue to require that, if possible, employers ensure that SDSs for hazardous products in the workplace are not more than three years old.
It is also important to note that there are requirements in section 5.12 of the HPR with regard to the updating of SDSs and labels by suppliers when "significant new data" (data that change the classification of a hazardous product or change the ways to protect against the hazard(s) presented by the hazardous product) become available.
When significant new data become available, the SDS and label are exempt from the requirement to reflect the significant new data for a period of 90 and 180 days, respectively, from the date upon which the information became available, provided that, upon sale or importation during that period, the new information and date upon which it became available is transmitted in written form to the purchaser (in the case of sale) or is obtained or prepared by the importer (in the case of importation). The supplier must update their SDS and label to reflect the significant new data within 90 and 180 days, respectively.
United States
As mandated under the OSHA Hazard Communication Standard (HCS) 2012 update, chemical manufacturers, distributors, importers, and employers must update their SDSs within 3 months from the time they are aware of significant new hazard information or ways to protect against the hazards. Chemical labels must be updated in 6 months. If the chemical is not currently being produced or imported, the chemical manufacturer or importer must add the information to the SDS before the chemical is introduced into the workplace again.
OSHA does not define what constitutes "significant new hazard information" but it is good practice to include any change of hazard classification, new hazards, new occupational exposure limits, and new risk management measures in revised SDSs.
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