WHMIS 2015: Current Status and Resources

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1 WHMIS 2015: Current Status and Resources Jennifer Dipper, Technical Specialist Canadian Centre for Occupational Health and Safety

2 Who is? Canadian Centre for Occupational Health and Safety (CCOHS) Established in 1978 by an Act of Parliament Governed by a tripartite council Promotes the total well-being physical, psychosocial and mental health of working Canadians 2

3 Current Status

4 Legislative Changes Amendments to Hazardous Products Act (HPA) received Royal Assent in June 2014 The final Hazardous Products Regulations (HPR) (Federal) were published in the Canada Gazette Part II February 11 th, The amended HPA and new HPR are in force. 4

5 Implementation Overview HPR repeals and replaces the Controlled Products Regulations (CPR) Ingredient Disclosure List also repealed Implements the GHS hazard classification criteria and hazard communication elements as per the 5 th edition of the Purple Book Aligns, as much as possible, with the OSHA Hazard Communication Standard (HCS 2012) 5

6 Federal vs. Jurisdictional OH&S 6

7 OH&S Legislative Changes Provinces, territories and federal occupational health and safety regulators must now each adopt their own legislative changes Will use a model occupational health and safety concept Dates of enactment may vary BC WHMIS 2015 legislation went into effect Aug 4,

8 WHMIS 2015 WHMIS 1988 WHMIS

9 How Has WHMIS Changed? WHMIS 2015 introduces: new classification rules and hazard classes new label requirements new standardized format for Safety Data Sheets 9

10 Hazard Classification

11 Hazard Classification WHMIS 2015 Hazard Groups and Classes Physical hazards 19 classes Health hazards 12 classes 11

12 Hazard Classification WHMIS 2015 Physical Hazard Classes Combustible dusts Oxidizing solids Corrosive to metals Pyrophoric gases Flammable gases Pyrophoric liquids Flammable aerosols Pyrophoric solids Flammable liquids Flammable solids Gases under pressure Organic peroxides Oxidizing gases Oxidizing liquids Self-heating substances and mixtures Self-reactive substances and mixtures Simple asphyxiants Substances and mixtures, which in contact with water, emit flammable gases Physical Hazards Not Otherwise Classified 12

13 Hazard Classification WHMIS 2015 Health Hazard Classes Acute toxicity Reproductive toxicity Skin corrosion/irritation Specific target organ toxicity single exposure Serious eye damage/eye irritation Specific target organ toxicity repeated exposure Respiratory or skin sensitization Aspiration hazard Germ cell mutagenicity Carcinogenicity Biohazardous infectious materials Health hazards not otherwise classified 13

14 Hazard Classification Each hazard class has at least one defined hazard category Identifies the degree of hazard within a hazard class Category 1 is ALWAYS the highest level hazard within a class 14

15 New Health Hazard Classes Aspiration Hazards Severe acute effects, such as chemical pneumonia, varying degrees of pulmonary injury or death, following the entry of a liquid or solid through the oral or nasal cavity, or indirectly from vomiting, into the trachea and lower respiratory system (HPR) Specific Target Organ Toxicity Single Exposure (STOT single) Organ toxicity specific, non-lethal toxic effects Narcotic effects e.g. drowsiness, and dizziness Respiratory tract irritation 15

16 New Physical Hazard Classes Simple Asphyxiants Any gas that is liable to cause asphyxiation by the displacement of air (HPR) (unconsciousness or death by suffocation) Pyrophoric Gases Gas that is liable to ignite spontaneously in air at a temperature of 54 deg C or less (HPR) Combustible Dusts A mixture or substance that is in the form of finely divided solid particles that, upon ignition, is liable to catch fire or explode when dispersed in air (HPR) (Note: The HPR does not regulate products that are shipped in a nondust form which, when processed, would present a hazard) 16

17 New Hazard Classes Physical Hazards Not Otherwise Classified (PHNOC) Health Hazards Not Otherwise Classified (HHNOC) A way to capture hazards that are not included in the criteria for other classes Note: US HCS 2012 uses Hazards Not Otherwise Classified (HNOC) 17

18 Exclusions Explosive Cosmetic, device, drug or food Pest control product Consumer product Wood or product made of wood Nuclear substances Hazardous wastes Tobacco and tobacco products Manufactured article No longer exempt Flavours and fragrances 18

19 Supplier Labels

20 Supplier Labels Once a product is classified, WHMIS 2015 uses standardized items: Pictograms Signal words Hazard statements Precautionary statements 20

21 Supplier Label Elements WHMIS 1988 WHMIS 2015 Product Identifier Product Identifier Supplier Identifier (name only) Hazard symbol Risk phrases Precautionary measures First aid instructions Supplier Identifier (name, address and telephone number) Hazard pictogram Hazard statements (supplier must use standardized wording) Precautionary statements (response, prevention, storage and disposal) Precautionary statements (response) Reference to MSDS Signal word (Danger or Warning) 21

22 Pictograms 22

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24 Signal Words Only one will be used Danger Warning (or none) 24

25 Hazard Statements Flammable gas Extremely flammable gas (Category 1) Flammable Gas (Category 2) Wording of the hazard statement helps describe the degree of the hazard Gas under pressure Contains gas under pressure; may explode if heated Fatal if inhaled (Category 1 and Category 2) Acute Toxicity Toxic if inhaled (Category 3) Harmful if inhaled (Category 4) Carcinogen May cause cancer (Category 1) Suspected of causing cancer (Category 2) 25

26 Precautionary Statements Advice on how to minimize or control hazards (prevention, response, storage, disposal), e.g. Keep container tightly closed Wear protective gloves/protective clothing/eye protection/face protection Fight fire remotely due to the risk of explosion Tip! May not identify all of the necessary control measures. Check the SDS for more information. 26

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28 Supplier Labels Must be available in both official languages o Can be two labels or a bilingual label Pictogram(s), signal word and hazard statement(s) must be grouped together Clearly and prominently displayed Easily legible 28 Sept. 25, 2015

29 Standardized Information Pictogram, signal word, hazard statement, precautionary statements are set out in Section 3 of Annex 3 of the GHS 5 th edition purple book Where not available via GHS, the HPR sets the requirements in Schedule 5, for example: 29

30 Initial Supplier Identifier Appears on the supplier label and safety data sheet In most cases, it is the contact information for the Canadian manufacturer, importer or distributor o If the product is imported and used in the importers workplace only, the foreign supplier information may remain 30

31 Workplace Labels (BC) Product identifier WHMIS 1988 WHMIS 2015 Information for the safe handling of the controlled product Reference to MSDS (if supplied or available) Product Identifier identical to that found on the SDS of the corresponding hazardous product Information for the safe handling of the hazardous product that is conveyed in a manner appropriate to the workplace Reference to SDS (if supplied or available) 31

32 Safety Data Sheets

33 Safety Data Sheets Standardized 16-section SDS Advantage: Information will be easier to find for SDS users, since all SDS s will have the same layout 33

34 Safety Data Sheets 1. Identification (product and supplier) 2. Hazard identification 3. Composition/information on ingredients 4. First-aid measures 5. Fire-fighting measures 6. Accidental release measures 7. Handling and storage 8. Exposure controls/ personal protection 9. Physical and chemical properties 10.Stability and reactivity 11.Toxicological information 12.Ecological information* 13.Disposal considerations* 14.Transport information* 15.Regulatory information* 16.Other information * Heading required but section content is optional 34

35 SDS: New Requirements Product classification and label elements (listed in Section 2) Information about any hazardous reaction produced by the product as a result of having followed instructions for use provided Not new Both official languages - two SDSs or a bilingual SDS 35

36 Ingredient Disclosure For a hazardous product that is a: Material or substance: Chemical name, CAS number and other identifying information Mixture: Chemical name, CAS number, other identifying information and the concentration (or concentration range) of all ingredients that classify for a health hazard and are present above the designated concentration limit for the category or subcategory in which it is classified 36

37 HPR - SCHEDULE 2 Information elements on SDS - Biohazardous infectious materials Item Column 1 Column 2 Heading 1 Section I Infectious Agent 2 Section II Hazard Identification 3 Section III Dissemination Specific Information Elements (a) name; (b) synonym or cross-reference; and (a) pathogenicity/toxicity; (b) epidemiology; (c) host range; (d) infectious dose; (a) reservoir; (b) zoonosis; and (c) characteristics (e) mode of transmission; (f) incubation period; and (g) communicability (c) vectors 4 Section IV Stability and Viability 5 Section V First Aid/Medical 6 Section VI Laboratory Hazard 7 Section VII Exposure Controls/ Personal Protection 8 Section VIII Handling and Storage 9 Section IX Regulatory and Other Information (a) drug susceptibility/resistance; (b) susceptibility to disinfectants; (a) surveillance; (b) first aid/treatment; (a) laboratory-acquired infections; (b) sources/specimens; (a) risk group classification; (b) containment requirements; (a) spills; (b) disposal; and (a) regulatory information; (b) last file update (date); and (c) physical inactivation; and (d) survival outside host (c) immunization; and (d) prophylaxis (c) primary hazards; and (d) special hazards (c) protective clothing; and (d) other precautions (c) storage (c) prepared by (name of author) 37

38 Laboratory Samples Special Considerations

39 Laboratory Samples Definition: Sample of a hazardous product that: is packaged in a container that contains < 10 kg of the hazardous product, and is intended solely to be tested in a laboratory, but does not include a sample that is to be used by the laboratory for testing other products or for educational or demonstration purposes Examples: Industrial hygiene samples Product samples for research and development Quality control samples 39

40 Bailment Definition The transfer of possession without transferring ownership (referred to in definition of sell in the HPA) Example Product A (from Company A) is being sent to Company B to do testing on Company A s behalf. The results are sent back to Company A. Lab samples are commonly bailed. Note: Bailment cannot occur for cross-border shipments 40

41 Bailment and Biohazardous Infectious Materials Exemption A laboratory sample classified only in the Biohazardous and Infectious Materials hazard class that is bailed is exempt from ALL label and SDS requirements Example A sample of mucosa that is couriered to be tested at another location is not required to have an SDS or a label. 41

42 Other Exemptions Two other exemptions: 1. Bailed laboratory sample that is not biohazardous and not available to sell; or unknown chemical identity and/or concentration 2. Laboratory samples classified only as Biohazardous are sold or imported 42

43 Other Exemptions (cont d) These samples are exempt from: all SDS requirements, and the requirement for pictogram, signal word, hazard statement and precautionary statement(s) on the label Label must include: chemical name or generic chemical name of hazardous ingredient, if known, and Hazardous Laboratory Sample. For hazard information or in an emergency, call statement + emergency phone number 43

44 Updating SDS s and Labels

45 Updates to Labels and SDSs Must be accurate at the time of each sale or importation of the product Update required when significant new data is available New o change in a category or subcategory of a hazard class OR o changes the ways to protect against the hazard No requirement to update the SDS every three years in the absence of new information 45

46 Supplier Updating Requirements SDSs updated within 90 days Labels updated within 180 days If sale is within this window, supplier must ensure the SDS is otherwise up to date, and that the new information and the date it became available is transmitted, in writing 46

47 Employer SDS Updating Different jurisdictions are adopting different requirements In BC Employers are required to obtain from the supplier an up-to-date supplier SDS once a hazardous product is 3 years old, unless: (a) the employer has written confirmation from the supplier that the SDS has not changed, or the up-todate supplier SDS does not apply to the hazardous product, or (b) it is not practicable for the employer to obtain the up-to-date SDS or written confirmation under (a). If the employer cannot obtain updated SDS, they must add any significant new data or hazard information 47

48 Education and Training Requirements

49 Education Education teaches workers the principles of WHMIS, and the meaning of the information on labels and SDSs. BC legislation stipulates worker education must include: Elements of the WHMIS program Major hazards of the hazardous products used in the workplace Rights and responsibilities of employers & workers Content required on labels & SDSs and the significance of this information Use, storage and handling information of hazardous products used in the workplace 49

50 Training Workplace-specific training teaches workers how to work safely with hazardous products. BC WHMIS training requirements include: Content required on a supplier vs workplace label; purpose and significance of the information on labels; Content required on an SDS and the purpose and significance of the information contained on the SDS; Procedures for the safe use, handling and disposal of hazardous products (specific to the workplace and cover the safe work procedures and emergency response procedures to be used in the workplace) 50

51 Education and Training Requirements Reminder: Timing of new laws will vary by jurisdiction For BC: If no WHMIS 2015 products in the workplace, employer continues to comply with WHMIS 1988 If employer receives a WHMIS 2015 product (SDS and label), employer must follow new requirements. Must revise education and training to include WHMIS

52 WHMIS Transition

53 What Will Stay the Same? Suppliers will: Ensure the appropriate classification of their hazardous products Provide labels for hazardous products Provide SDSs for hazardous products 53

54 What Will Stay the Same? Employers will: Make sure all hazardous products are properly labelled Make up-to-date SDSs readily available to workers Provide worker education and training Make sure appropriate control measures are in place to protect the health and safety of workers 54

55 What Will Stay the Same? Workers will: Participate in education and training programs Take the necessary steps to protect themselves and their coworkers Participate in identifying and eliminating hazards 55

56 Multi-Year Transition Phase Timing Phase 1 From Feb 11, 2015 to May 31, 2017 Phase 2 From June 1, 2017 to May 31, 2018 Phase 3 From June 1, 2018 to November 30, 2018 Completion December 1, 2018 Manufacturers and Importers WHMIS 1988 or WHMIS 2015 WHMIS 2015 Suppliers Distributors WHMIS 1988 or WHMIS 2015 WHMIS 1988 or WHMIS 2015 Employers* Consult F/P/T regulator WHMIS 1988 or WHMIS 2015 WHMIS 2015 WHMIS 2015 WHMIS 1988 or WHMIS 2015 WHMIS 2015 WHMIS 2015 WHMIS 2015 *Requirements may vary consult your local jurisdiction for their WHMIS requirements and transition timing. 56

57 Resources

58 Health Canada Web Site 58

59 United Nations Economic Commission for Europe 59

60 National Initiatives 60

61 WHMIS.org This national WHMIS web portal provides: Status and timing of regulatory changes for every jurisdiction Links to regulations, consultation documents, etc. Information and resources for different audiences (employers, suppliers, workers, trainers, etc.) New/updated resources will be developed over time and shared through this portal 61

62 BC page on WHMIS.org 62

63 WHMIS 2015 for Workers Educational e-course developed by CCOHS with the support and input of Health Canada. Reviewed by regulators, labour, suppliers, and employers. Provides education on key WHMIS 2015 requirements Based on the amended HPA and final HPR Produces an online certificate Does not replace workplace-specific training Available now! Free for individual Canadians