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Act First Safety FAQ – Frequently Asked Questions

Workplace Hazardous Materials Information System (WHMIS)
Frequently Asked Questions

1. What is WHMIS?
The Workplace Hazardous Materials Information System (WHMIS) is a Canada-wide system designed to give employers and workers information about hazardous materials used in the workplace. Under WHMIS, there are three ways in which information on hazardous materials is provided:
• labels on the containers of hazardous materials;
• Material Safety Data Sheets (MSDS) or Safety Data Sheets (SDS) to supplement the label with detailed hazard and precautionary information; and
• worker education programs.
The manufacturer, supplier or distributor of the hazardous material provides the labels and Safety Data Sheets to the employer. The employer passes the information on to the worker and provides education programs.

2. There are currently two WHMIS systems – WHMIS 1988 and WHMIS 2015 (under GHS). What is the difference between these systems?

WHMIS, the original Workplace Hazardous Materials Information System, was implemented in 1988. It was established to give all working Canadians consistent and accurate information about hazardous materials they may be exposed to in the workplace. WHMIS 1988 incorporates safety labelling on containers, Material Safety Data Sheets (MSDS) and worker education programs.

WHMIS 2015 builds on WHMIS 1988 by incorporating elements from the internationally
recognized Global Harmonized System (GHS), and establishes new rules for classifying
and labelling of hazardous workplace materials, and new information for Safety Data
Sheets (formerly Material Safety Data Sheets). This new WHMIS system aligns Canada’s
occupational hazard classification and communication requirements with those used by
the United States and other major trading partners.

Under WHMIS 2015|GHS, “controlled products” are called “hazardous products” and there are:
• new rules for classifying hazardous workplace chemicals;
• two main hazard classes – physical hazards and health hazards;
• new label requirements, including pictograms instead of symbols (WHMIS 1988) that correspond to hazard classes; and,
• an expanded 16-section standard format for Safety Data Sheets (changed from Material Safety Data Sheets under WHMIS 1988).
While WHMIS 2015|GHS provides an internationally consistent approach, the key responsibilities of suppliers, employers and workers are the same under WHMIS 2015.

3. What is GHS?

The Global Harmonized System (GHS) for Classification and Labelling of Chemicals (GHS) is an international system to standardize chemical hazard classification and communication globally.

With a growing global economy, Canadian workers are increasingly exposed to hazardous chemicals in products produced in other countries. The GHS system will enhance workplace safety by ensuring labelling and safety information is consistent throughout the world.

GHS is being implemented in Canada in three phases with the transition being completed December 1, 2018. GHS is not replacing WHMIS. It is being incorporated into Canada’s WHMIS 2015 system. This is resulting in new standardized:
• Classification criteria
• Label requirements
• Safety Data Sheet (SDS) requirements (formerly Material Safety Data Sheet – MSDS)

4. Is there a process and time frame to transition from WHMIS 1988 to WHMIS 2015|GHS?

The transition period to move from WHMIS 1988 to WHMIS 2015 (with GHS) is from Feb, 2015 to Dec 1, 2018. As time gets closer to the 2018 deadline, employers will see an increasing number of the new GHS labels and Safety Data Sheets (SDS) entering their workplaces.

During the transition period (to Dec 1, 2018), employers may continue to have WHMIS 1988 labels and Material Safety Data Sheets (MSDS) in their workplace. If so, they must also continue to educate workers about WHMIS 1988.

5. Have employer’s duties and responsibilities changed under WHMIS 2015 and GHS?

Under WHMIS 2015|GHS, employers must continue to:
• Educate and train their workers on the hazards and safe use of products
• Ensure that hazardous products are properly labelled
• Prepare workplace labels and Safety Data Sheets (SDS) as necessary
• Provide access for workers to up-to-date SDS
• Review the education and training provided to workers annually or whenever work conditions or hazard information changes.

6. During the transition period (to Dec 1, 2018) are workers required to be trained in both WHMIS 1988 and WHMIS 2015?

Response provided by Ontario Ministry of Labour for businesses operating in Ontario
Yes. During the transition, employers must ensure that workers are trained on:
• controlled products with WHMIS 1998 labels and Material Safety Data Sheets for as long as they are still used in the workplace; and,
• hazardous products with WHMIS 2015|GHS labels and Safety Data Sheets, as soon as practicable after these products enter the workplace and, in some cases, before they are used.
The type and amount of training will depend on whether a product is new to the workplace and/or newly classified as a hazardous product.
• If the product is a controlled product under WHMIS 1988 and is already used in the workplace, workers should already be trained to work with it safely.
• If the same product enters the workplace with WHMIS 2015|GHS labels and safety data sheets, and workers know how to work with it safely, workers may continue to use the product but must be trained as soon as practicable on the content and format of the new supplier labels and Safety Data Sheets.
• If a hazardous product enters the workplace with WHMIS 2015|GHS labels and Safety Data Sheets, and it was not previously used at the workplace, the product may be stored but not used until workers are trained on the new supplier labels and Safety Data Sheets as well as procedures for the safe use, storage, handling and disposal of the product, including in an emergency. The same applies if a product is a hazardous product under the new system but was not classified as a controlled product under the old system.

7. What can employers do during the transition period (up to Dec 1, 2018) to ensure their workers are safe from hazardous materials that may be labelled under either of the WHMIS 1988 or WHMIS 2015 (under GHS) systems?

• Review your current WHMIS practices and policies to identify if the correct labels, Material Safety Data Sheets (MSDS) and safety precautions are in place for products labelled under the WHMIS 1988 regulations.

• Assess if products labelled under the Global Harmonized System (GHS) are already in your workplace, or are anticipated to arrive in the near future; if so, you must implement new workplace procedures and policies that comply with the WHMIS 2015|GHS regulations.

• Consider implementing a blended MSDS/SDS Management System to ensure your employees have up-to-date training and accurate information about hazardous materials labelled under either system.

• Once a year, or when workplace conditions change (i.e. new types of hazardous materials or GHS labelling enter your workplace), review your WHMIS training program and update your workplace procedures and policies if necessary to ensure workers are safe when handling, storing, transporting or disposing products that contain dangerous materials.

• Stay informed about WHMIS 2015|GHS and new information about hazardous materials.

8. What WHMIS training options are available?

Act First Safety provides flexible WHMIS training that covers both the original WHMIS 1988 and WHMIS 2015|GHS. This training can be taken online at Act First Safety’s website or through instructor-led training session at your workplace. Call for more information or to book your training.

9. Who should receive WHMIS education and training?

In Canada, if a workplace uses hazardous products, there must be a WHMIS program in place. Workers must be educated and trained so they understand the hazards, and know how to work safely with hazardous products.
All workers who work with a hazardous product, or who may be exposed to a hazardous product as part of their work activities must learn about the hazard information for these products. The hazard information should include the information received from the supplier, as well as any other information that the employer is aware of about the safe use, storage, handling and disposal of each product.
As an example, this education and training will include all workers who:
• May be exposed to a hazardous product due to their work activities (including normal use, maintenance activities, or emergencies).
• Use, store, handle or dispose of a hazardous product.
• Supervise or manage workers who may be exposed, or use, store, handle or dispose of a hazardous product.
• Are involved in emergency response.

10. What legislation covers the Workplace Hazardous Materials Information System (WHMIS) in Canada and Ontario?

WHMIS legislation was originally implemented in 1988. WHMIS 2015|GHS, includes the amended Hazardous Products Act (HPA) and Hazardous Products Regulations (HPR). Both the HPA and HPR are currently in force.

The Workplace Hazardous Materials Information System (WHMIS) is implemented by a combination of federal and provincial legislation. The main purpose of the federal WHMIS legislation is to require the suppliers of hazardous materials used in the workplace to provide health and safety information about their products as a condition of sale.

The main purpose of the provincial WHMIS legislation is to require employers to obtain health and safety information about hazardous materials in the workplace and to pass this information on to workers.

Ontario’s WHMIS Legislation
There are two pieces of provincial legislation that implement WHMIS in Ontario:
1. The Occupational Health and Safety Act, which places duties on employers in charge of workplaces where hazardous materials are used, to obtain labels and material safety data sheets from their suppliers and to provide worker education programs.
2. The WHMIS Regulation, Ontario Regulation 644/88 (now R.R.O. 1990, Regulation 860), which came into effect on October 31, 1988. This regulation sets out in detail the employer duties respecting labels, material safety data sheets and worker education.

11. How is WHMIS enforced in Ontario?

WHMIS is enforced by each provincial government. In Ontario, WHMIS is enforced by the Ontario Ministry of Labour.