How will Workplace Hazardous Materials Information System Moving To The Globally Harmonized System affect you?
Roles and Responsibilities
Overall, the current roles and responsibilities for suppliers, employers and workers likely will not change in WHMIS after GHS.
Suppliers, Importers and Producers duties will continue to include:
- classifying hazardous products
- preparing labels and SDSs (safety data sheets)
- providing these elements to customers
Employers must continue to:
- Educate and train workers on the hazards and safe use of products.
- Ensure that hazardous materials are properly labelled.
- Prepare workplace labels and SDSs as necessary.
- Provide access for workers to up-to-date SDSs.
- Ensure appropriate control measures are in place to protect the health and safety of workers.
Workers will still:
- Participate in WHMIS and chemical safety training programs.
- Take necessary steps to protect themselves and their coworkers.
- Participate in identifying and controlling hazards.
How chemicals are classified will be affected. It is likely (but not confirmed) that WHMIS legislation will:
- Adopt all of the major GHS health and physical hazard classes including aspiration hazard and specific target organ toxicity-single exposure. Some sub-categories in GHS may not be adopted. It is unlikely that the environmental hazard classes will be adopted under WHMIS (but this does not exclude that it may be adopted by another government department).
- Continue to include some hazards that are currently not in the GHS system, but are present in the current WHMIS system – such as biohazardous materials.
- Have more specific names for its hazard classes.
- Combine two WHMIS classes (teratogenicity/embryotoxicity and reproductive toxicity) into one new GHS hazard class called reproductive toxicity
Labels requirements will also change, and will probably have a few new requirements. Labels will use new pictograms, as well as a signal word – Warning or Danger.
Under the GHS system, once a chemical is classified, specific signal words, hazard statements and symbols/pictograms are required (prescribed) for each hazard class and category. These elements must appear on the label.
All of the required elements for labels are not yet determined. It is still not clear, for example, if the names of hazardous ingredients will be included on the label, or if the WHMIS hatched border will still be required.
Safety Data Sheets (SDSs)
SDSs will use a 16-section format. There will be standardized information requirements for each section. The 9-section WHMIS format for MSDSs will no longer be acceptable. Another important change to note is that the product classification and some of the label information will probably be required on the SDS. The SDS updating requirements (every 3 years) will likely be required.
How can suppliers prepare now?
Under WHMIS after GHS, suppliers will continue to classify products, create labels and create SDSs (formerly MSDSs) but they will follow the “WHMIS after GHS” requirements.
To prepare to classify a product, suppliers could:
- Obtain a copy of the GHS criteria.
- Identify the relevant hazard data for their ingredients and products.
- Review the data in light of the classification criteria to determine the appropriate hazard classes and categories. Note that there is specific guidance for classifying the health and environmental hazards of mixtures.
- Document the rationale and information for future reference.
Once changes to WHMIS legislation have been published, confirm product classifications.
Suppliers must use a “weight of evidence” approach to classify products. The validity of research reports and other information must be evaluated as a whole. In some cases a single, well-conducted study will be sufficient.
How can employers prepare now?
After GHS implementation, SDSs and labels for products originating within and outside of Canada will share common elements. This standardization should simplify education and training after the initial transition period is over. However employees will need training on both systems until the transition is complete.
During the transition period, employers will be faced with more than their normal number of SDSs — in addition to the WHMIS-compliant MSDSs for existing stock, new SDSs compliant with WHMIS after GHS requirements may be provided for new shipments of the same products. Keeping up-to-date inventories of all controlled products and the status of the MSDS/SDS will be essential.
Where can I get more information?
The Canadian Centre for Occupational Health and Safety (CCOHS), in partnership with Health Canada’s National Office of WHMIS (NOW) developed and released two free on-line training courses to help workplaces prepare for “WHMIS After GHS”.
These free courses provide an introduction to the expected changes to WHMIS after GHS. Participants will learn about the expected impacts of these changes for workers, employers, and chemical suppliers.
WHMIS After GHS: An Introduction (30 minutes)
WHMIS After GHS: How Suppliers Can Prepare (60 minutes)
Both courses are offered in English and French, and are free of charge but registration is required in order to keep users aware of changes to the courses.
Health Canada also offers an email news service to announce information about WHMIS.
What is the Globally Harmonized System (GHS)?
GHS stands for the “Globally Harmonized System of Classification and Labelling of Chemicals”. GHS is a system that defines and classifies the hazards of chemical products, and communicates heath and safety information on labels and material safety data sheets (called Safety Data Sheets, or SDSs, in GHS). The goal is that the same set of rules for classifying hazards, and the same format and content for labels and safety data sheets (SDS) will be adopted and used around the world. An international team of hazard communication experts developed GHS.
Why is global harmonization necessary?
Currently many different countries have different systems for classification and labelling of chemical products. In addition, several different systems can exist even within the same country. This situation has been expensive for governments to regulate and enforce, costly for companies who have to comply with many different systems, and confusing for workers who need to understand the hazards of a chemical in order to work safely.
GHS promises to deliver several distinct benefits. Among them are:
- promoting regulatory efficiency
- facilitating trade
- easing compliance
- reducing costs
- providing improved, consistent hazard information
- encouraging the safe transport, handling and use of chemicals
- promoting better emergency response to chemical incidents, and
- reducing the need for animal testing
What is the scope of GHS?
The GHS system covers all hazardous chemicals and may be adopted to cover chemicals in the workplace, transport, consumer products, pesticides and pharmaceuticals. The target audiences for GHS include workers, transport workers, emergency responders and consumers.
What are the two major elements in GHS?
The two major elements of GHS are:
1. Classification of the hazards of chemicals according to the GHS rules:
GHS provides guidance on classifying pure chemicals and mixtures according to its criteria or rules.
2. Communication of the hazards and precautionary information using Safety Data Sheets and labels:
Labels – With the GHS system, certain information will appear on the label. For example, the chemical identity may be required. Standardized hazard statements, signal words and symbols will appear on the label according to the classification of that chemical or mixture. Precautionary statements may also be required, if adopted by your regulatory authority.
Safety Data Sheets (SDS) – The GHS SDS has 16 sections in a set order, and information requirements are prescribed.
What are some key terms in the GHS Vocabulary?
- SDS – Safety Data Sheet. SDS is the term used by GHS for Material Safety Data Sheet (MSDS).
- Hazard group – While not given a formal definition, GHS divides hazards into three major groups – health, physical and environmental.
- Class – Class is the term used to describe the different hazards. For example, “Gases under Pressure” is an example of a class in the physical hazards group.
- Category – Category is the name used to describe the sub-sections of classes. For example, Self-Reactive Chemicals have 7 categories. Each category has rules or criteria to determine what chemicals are assigned to that category.
- Hazard Statement – For each category of a class, a standardized statement is used to describe the hazard. For example, the hazard statement for chemicals which meet the criteria for the class Self-heating substances and mixtures, Category 1 is “Self-heating; may catch fire”. This hazard statement would appear both on the label and on the SDS.
- Signal word - There are two signal words in the GHS system – Danger and Warning. These signal words are used to communicate the level of hazard on both the label and the SDS. The appropriate signal word to use is set out by the classification system. For example, the signal word for Self-heating substances and mixtures, Category 1 is “Danger” while “Warning” is used for the less serious Category 2. There are categories where no signal word is used.
- Pictogram – Pictogram refers to the GHS symbol on the label and SDS. Not all categories have a symbol associated with them.
What is meant by the GHS hazard groupings and “building block” concept?
Within the GHS classification system, there are three major hazard groups:
- Physical hazards
- Health hazards
- Environmental hazards
Within each of these hazard groups there are “classes” and “categories”. Each of these parts is called a “building block”. Each country can determine which building blocks of the GHS system it will use in their different sectors (workplace, transportation, consumers). Once the building blocks are chosen, the corresponding GHS rules for classification and labels must be used.
What are the classes within the Health hazard group?
Criteria for classifying chemicals have been developed for the following health hazard classes:
- acute toxicity
- skin corrosion/irritation
- serious eye damage/eye irritation
- respiratory or skin sensitization
- germ cell mutagenicity
- reproductive toxicity
- specific target organ toxicity – single exposure
- specific target organ toxicity – repeated exposure
- aspiration hazard
What are the classes within the Physical hazard group?
Criteria for classifying chemicals have been developed for the following physical hazard classes:
- flammable gases
- flammable aerosols
- oxidizing gases
- gases under pressure
- flammable liquids
- flammable solids
- self-reactive substances and mixtures
- pyrophoric liquids
- pyrophoric solids
- self-heating substances and mixtures
- substances and mixtures which, in contact with water, emit flammable gases
- oxidizing liquids
- oxidizing solids
- organic peroxides
- corrosive to metals
What are the classes within the Environmental hazard group?
Criteria for classifying chemicals have been developed for the following environmental hazard class:
- hazardous to the aquatic environment (acute and chronic)
- hazardous to the ozone layer
Where can I get information on the GHS criteria for the different hazard classes?
The most current information on GHS classification, labels and SDS as well as other criteria is available in the 4th revised edition of the Globally Harmonized System of Classification and Labelling of Chemicals (GHS)from the United Nations Economic Commission for Europe (UNECE).
GHS is a dynamic system. The international GHS committee meets twice a year to work on developing potential new hazard classes as well as resolving specific issues, and updating the latest GHS publication. Check the above link for more information.
What is the target date for implementation of GHS?
Countries and sectors (consumer, environmental, workplace, transportation) within a country will implement GHS at varying times depending on their local circumstances.
While WHMIS regulators continue to meet to consult about changes to WHMIS, a clear deadline has not been identified for full implementation. Proposed changes to the legislation are expected in 2011.
Next steps include:
- Consultations with stakeholders are being finalized.
- Economic analysis is underway.
- Legislation will be revised.
- Proposed legislative changes (e.g., to the Hazardous Products Act and Controlled Products Regulation) will be published in Canada Gazette I – expected in 2011.
- Final legislation will be published in the Canada Gazette II.
Note that the legislative process usually takes two years.
An implementation date will be known when the Canada Gazette II is published. This will be followed by a transition period (the US has proposed 2 years).
GHS has been adopted into the new EU Classification, Labelling and Packaging (CLP) regulations (in force as of January 20, 2009). These regulations must be used for new products which are:
- Pure substances by December 1, 2010
- Mixtures by June 1, 2015
There is a two-year transition period for existing products labelled and packaged according to EU Directives (67/548/EEC and 1999/45/EC, both as amended).
Proposed amendments to the OSHA Hazard Communication Standard regulations were published on September 30, 2009. US OSHA is accepting comments and may have another proposed regulation posted before finalizing and publishing a “Final Rule”. A two-year transition period is proposed for training and a three-year period for full implementation.
To find out more about the status of GHS implementation in other countries and their sectors please see the article produced by the UNECE.
Will GHS affect other laws in Canada?
It is very likely. GHS is expected to be implemented by other regulatory agencies, including by Transport Canada for the Transport of Dangerous Goods, and by Health Canada for Consumer Chemical Products and Pest Control Products. Discussions are occurring but the consultations are not complete.
For the latest report (June 2006) on Canadian activities regarding implementation see the page Implementation of GHS – Canadian Activity on the Health Canada web site.
For more information see the page Globally Harmonized System of Classification and Labelling of Chemicals (GHS) on the Health Canada web site.
First Response’s Comments:
Many of my clients require Workplace Hazardous Materials Information System training; many of them have been asking me for the last 3 – 5 years about the ‘changes’ to the Globally Harmonized System. As of this post, nothing has come into force just yet, so ‘training as usual’ is the general theme. If you interpret the rules of the Occupational Health & Safety Act correctly, ‘any employee who is likely to come in contact with hazardous materials MUST have WHMIS training’ . So, could an office environment be required to train all its employees? Well, that depends; if they have any WHMIS controlled products in the office (i.e. in the kitchen, mail room, storage area, janitors closet etc) then potentially, YES. This makes it very challenging for many companies as the logistics of training all their employees is very disruptive to the day to day flow of doing business, not to mention the cost factor. One of the ways First Resopnse is helping companies deal with this dilemma is with our virtual university and extensive on line training library, of which there is an excellent WHMIS course that can be completed at the comfort of your own work station. Your Employees just enter in a credit card number (or an access code set up with us) and proceed to do the training in their own time. Upon completion, they print off their certificate and give it to their department manger for their employee file. How simple is that? Stay tuned for more posts and updated to the move to the GHS system. In the meantime, I would love to hear your take on the whole issue… put them in the comment box below…