Complying With WHMIS 2015

Employees in the automotive aftermarket industry work with chemicals and materials that can affect their health and safety. Hazardous materials can be found in a range of common products in the workplace, such as paints, cleaners, solvents, hardeners, sealants, adhesives, batteries, antifreeze, refrigerants, and waste products from these materials. Employees may be exposed while painting, cleaning parts and equipment, while servicing and repairing vehicles, or when cleaning up spills. The effects on workers exposed to these chemicals can range from feeling ill or getting headaches, to nervous system, kidney, or lung damage, burns, rashes, and even cancer. Some of these materials can cause fires and explosions.
For everyone in the automotive aftermarket, it is important to understand that WHMIS 2015 regulations are distinct from other laws such as the Transportation of Dangerous Goods regulations (TDG), or the Consumer Chemical and Container Regulations (CCCR). If you’ve taken steps to comply with TDG or CCCR, that’s great news, but you still have to comply with WHMIS 2015 regulations as well.
While WHMIS 2015 includes new harmonized criteria for hazard classification and requirements for labels and safety data sheets, the roles and responsibilities for suppliers, employers, and workers have not changed.
Suppliers, defined as persons who, in the course of business, sell or import a hazardous product, will continue to:
• identify whether their products are hazardous products;
• prepare labels and safety data sheets, and provide these to purchasers of hazardous products intended for use in a workplace.
Employers will continue to:
• educate and train workers on the hazards and safe use of hazardous products in the workplace;
• ensure that hazardous products are properly labelled;
• prepare workplace labels and safety data sheets (as necessary);
• ensure appropriate control measures are in place to protect the health and safety of workers.
Workers will continue to:
• participate in WHMIS and chemical safety training programs;
• take necessary steps to protect themselves and their co-workers;
• participate in identifying and controlling hazards.
To provide Canadian suppliers, employers, and workers time to adjust to WHMIS 2015, there is a transition period. During this period, suppliers are allowed to either continue to comply with the old HPA and the repealed CPR and Ingredient Disclosure List, or they must comply with the new HPA and the new HPR. However, the supplier must fully comply with either the old HPA/repealed CPR/Ingredient Disclosure List or the new HPA and HPR for a specific controlled or hazardous product. The classification, label and (material) safety data sheet must comply fully with the specific legislation and regulation chosen by the supplier, and not a combination of the two.
A label or SDS that is compliant with the United States Hazard Communication Standard (2012) may not be sufficient for compliance in Canada. The supplier must be compliant with the Canadian requirements, whether the CPR or the HPR.
The recently introduced Globally Harmonized System of Classification and Labelling of Chemicals (GHS) is an internationally consistent approach to classifying chemicals and communicating hazard information through labels and safety data sheets.
The key objectives of the GHS are:
• to increase worker protections through the adoption of an improved, globally recognized standard for communicating the hazards associated with workplace hazardous chemicals.
• to facilitate trade through common labelling and other hazard communication requirements;
• to lower costs for businesses and consumers by reducing the need for retesting and reclassifying workplace hazardous chemicals from, or for, different markets.
The Workplace Hazardous Materials Information System (WHMIS) 2015 requirements are laid out in the amended Hazardous Product Act (HPA) and the new Hazardous Products Regulations (HPR).
This section provides information on some of the key regulatory changes to WHMIS 1988 as a result of the coming into force of the modifications to the HPA and the coming into force of the new HPR. Additional technical guidance is expected to be added throughout 2015.
Hazard Classes: The Globally Harmonized System of Classification and Labelling of Chemicals (GHS) includes three types of hazard classes: physical hazard classes, which represent hazards relating to physical and chemical properties, such as flammability or compressed gases; health hazard classes, which represent hazards to health arising from exposure to a substance or mixture, such as acute toxicity or skin sensitization; and environmental hazard classes (hazardous to the aquatic environment and hazardous to the ozone layer). Further information on how each type of hazard class is addressed in the HPR is listed below.
Physical Hazards: The GHS physical hazard classes subdivide physical hazards in a manner that differs from the Controlled Products Regulations (CPR); however, nearly all of the physical hazards that are covered in the CPR are addressed by the GHS physical hazard classes. All GHS physical hazard classes except the Explosives hazard class have been adopted in Canada by the HPR. In addition, the following new physical hazard classes have been introduced in the HPR to enhance protections for workers: Combustible Dusts, Simple Asphyxiants, Pyrophoric Gases, and Physical Hazards Not Otherwise Classified.
Health Hazards: The GHS health hazard classes subdivide health hazards in a manner that differs from the CPR; however, these classes address nearly all of the health hazards that are currently covered in the CPR and introduce some additional types of hazards that are not currently covered but would enhance protections for workers (for example, aspiration hazard). All GHS health hazard classes have been adopted in Canada by the HPR. The Biohazardous Infectious Materials hazard class (which is not a GHS health hazard class) has been retained in the HPR in order to maintain worker protection, and a new Health Hazards Not Otherwise Classified class has also been introduced.
Environmental Hazards: The GHS environmental hazard classes have not been adopted in the HPR.
Safety Data Sheets and Labels: The general concept of communicating the hazards of a product on a label and safety data sheet (SDS) through pictures and statements that convey messages about hazards, precautions, and first aid measures remains the same under the new HPR. However, different pictograms and statements are required under the HPR than were required under the CPR.
Through the implementation of GHS, it is now possible to meet both Canadian and U.S. requirements using a single label and SDS for each hazardous product.
For more detailed information on WHMIS 2015, go to Heath Canada’s website, http://www.hc-sc.gc.ca/.