by Tammy J. Murphy
Under the Hazardous Products Act (HPA) and Hazardous Products Regulations (HPR), an SDS and label is required for any and all hazardous products that are imported or sold for use in a workplace and for any hazardous product that may be created in the workplace.
Health Canada has published a limited number of “hazardous substance assessments” which may assist suppliers with producing a safety data sheet (SDS). These assessments are documents which give information in regards to classifying chemicals per the hazard classes detailed in the HPA and/or HPR. They are considered to be “educational and information resources” and are NOT mandated classifications.
Per WHMIS 2015, the supplier is responsible for providing a current, accurate and comprehensive SDS and label as mandated by the requirements in the HPA and HPR. It should be noted that although suppliers may have access to not only publicly available information but also proprietary information, the hazardous substance assessments only use publicly available information and may not contain the most current information.
Health Canada has noted that these assessments “are not used to determine whether an SDS is compliant under the HPA.” Compliance determination is on a case by case basis and takes into account the supporting documentation of a substance(s)’ classification that the supplier provides.
Recommended Action Items:
- Review the five hazardous substance assessments posted to determine whether any of these substances are in your product line as a component in your formulation
- If so, review your product classification to determine whether it will be impacted by this information
- Monitor the hazardous substance assessment website to be alert to newly posted substance information
Government of Canada, Health Canada, Environmental and Workplace Health, Occupational Health and Safety, Workplace Hazardous Materials Information System (WHMIS) website: https://www.canada.ca/en/health-canada/services/environmental-workplace-health/occupational-health-safety/workplace-hazardous-materials-information-system/hazardous-substance-assessments.html
Hazardous Substance Assessments
Hazardous Products Act (HPA)
Hazardous Products Regulations (HPR)
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