Safety in Transition

After many years of discussion, Canada will now be aligning Workplace Hazardous Materials Information System (WHMIS) with the new Globally Harmonized System (GHS). Health Canada’s goal was to have updated the federal WHMIS laws in force by no later than June 2015. Earlier this year, on February 11, 2015 the law was enacted, and will be in effect as of June 1, 2015.

Phase 1 of the mandatory transition from WHMIS to GHS will begin following the publication of the final Hazardous Products Regulations in Canada Gazette, Part ll.

Harmonization not Standardization

With the increase in international trade, there is a need to harmonize chemical hazards classifications and communication worldwide.
GHS implementation will:

  • Reduce confusion
  • Ensure compliance
  • Maintain the health & safety of workers both here and abroad

GHS has already been implemented in the US. Worker training there was to be completed by December of 2013 and all Material Safety Data Sheets (MSDSs) needed to be converted to Safety Data Sheets (SDSs) by June 2015. With cross-border trade, your workers are likely seeing the different labels and SDSs in the workplace.

How to Prepare

  • Continue with WHMIS compliance
  • Start education and training about WHMIS to GHS changes
  • Alberta workplaces may already be receiving new GHS-compliant labels and Safety Data Sheets (SDSs)
  • Review your chemical inventories and minimize any unnecessary chemicals in your workplaces

GHS – What to Know

GHS has three main elements:

  1. Classification of Chemicals Pictograms
  2. Safety Data Sheets
  3. Labels

Pictograms

There are nine GHS classification pictograms that depict the following specific hazards:

  • Health Hazard Man – carcinogen, mutagenicity, reproductive/organ toxicity)
  • Skull & Crossbones – acute toxicity, fatal or toxic
  • Exclamation Mark – irritant, skin sensitizer, hazardous ozone layer, narcotics
  • Flame – flammables, pyrophorics, self heating, emits gas, organic peroxides)
  • Flame Over Circle – oxidizers
  • Corrosion – skin corrosion, burns, eye damage, corrosive to metals
  • Gas Cylinder – gases under pressure
  • Exploding Bomb – explosives, self reactives, organic peroxides
  • Environment – aquatic toxicity

Safety Data Sheets (SDSs)

  • SDS has 16 sections
  • Very structured order
  • Hazard statements
  • Hazard symbols
  • Signal words
  • Building block approach
    • Physical hazards
    • Health hazards
    • Environmental hazards

Labels

  • Product identifier, ie: Cleenz Gr8
  • Hazardous ingredients, ie: Contains glycol ether (new)
  • Hazard symbols/pictograms, ie: skull & crossbones
  • Signal words, ie: Danger (new)
  • Hazard statements, ie: Highly flammable liquid/vapour
  • Precautionary statements, ie: Keep away from heat sources
  • SDS reference, ie: See SDS for more information
  • Supplier identifier, ie: ABC Chemical Company

GHS Checklist

  • Accessible MSDSs and SDSs through transition
  • GHS-compliant labelling
  • Training resources and implementation plan for your organization
  • Continued updating of SDSs every three years
  • Classified documents according to new standard and hazards

Proposed Transition Timelines

Phase 1

Introduction, initial education and training, planning:

  • WHMIS to GHS in effect June 1, 2015
  • Introduction of new labels, SDSs to market and workplaces
  • Preparing workers for GHS changes with training 2015–18
  • Clearing old labels and MSDSs from the market and workplaces
  • Continue worker training as may be required to ensure overall compliance

Phase 2

December 1, 2018:

  • Employer compliance with the new regulations
  • Worker training has been completed, with proper records and documentation
  • End of sales with old labels or MSDSs
  • Products with old requirements must be used up by May 31, 2019

Phase 3

Transition complete June 1, 2019:

  • All products must comply
  • End of allowances for previous requirements in Canada

Education vs. Training

Note to Neil: Flexbox here?

Education
Training

General Information
Work Specific Information

How GHS/WHMIS works
How to store products at your worksites

Hazards of the products
The procedures required for safe use, handling, and disposal of hazardous products

Understanding the new symbols
Training in emergency procedures in the event of an accident or spill

The information found on an SDS and what that information means
Procedures for unusual situations, ie: procedures to follow if the hazardous product is present in the air, workers may be exposed

The information on both the suppliers label and workplace label, and what that information means
Established procedures required when the hazardous product is in a pipe, piping system, vessel, tank car, etc.

Who Needs Training?

Examples of job roles that would require the updated education and training will include any workers who:

  • May be exposed to a hazardous product(s) due to their routine work activities including normal use, or maintenance related activities, or emergencies
  • Use, store, handle, or will dispose of any hazardous products
  • Supervise or manage workers who may be exposed, or use, handle or will dispose of any hazardous products
  • Are involved in emergency response activities
  • Essentially, all workers including those in offices require this updated WHMIS training

What Happens to WHMIS?

Keep training on old WHMIS style labels and current MSDSs and gradually include the newer and updated training information until your overall transition is complete in 2018.

Responsibility of the Employer

After GHS

  • Develop, implement, and maintain a WHMIS/GHS education and training program
  • Review annually, or when work conditions or hazard information changes in conjunction with your established hazard assessment processes and procedures

Frequency of Education & Training

Employers are required to provide refresher education and training:

  • As needed to protect the worker’s health & safety
  • If conditions of the workplace have changed
  • If new products are introduced into the workplace
  • If existing products have changed and now have different hazards
  • When new hazard information becomes available, or is updated with regards to safe use, handling, storage, and disposal

Responsibility of the Worker

  • Active participation in all education and training, maintain all certifications
  • Follow all established safe work procedures and company specific training

Successful Training & Education

Workers should be able to work safely and answer these questions for every hazardous product they work with:

  1. What is this product?
  2. What are the hazards of this product?
  3. How to work safely with the product and co-workers?
  4. What to do in the event of an emergency
  5. Where can more product information be found if needed?

Who Can Provide Training?

  • Training can be provided by the employer or any qualified person or agency*
  • Employers remain legally responsible to ensure the protection of their workers

*We are currently developing a course curriculum and plan to have WHMIS 2015 transition training available to members in the near future.

If you have any questions or need to discuss further, please Contact Us.