What Manufacturers & Suppliers Need to Know About WHMIS GHS Revision 7 Updates

The Origin of WHMIS

Canada’s Occupational Health and Safety Act ensures workers’ right to know about health and safety hazards in the workplace. Because of this requirement, Canada developed a national hazard communication standard known as the Workplace Hazardous Materials Information System (WHMIS), which allows all Canadian workers to access information about the hazardous substances and mixtures they encounter in the workplace. WHMIS was implemented in October 1988 through a set of provincial, territorial, and federal legislation.

Many of the requirements of this hazard communication system were incorporated into the federal Hazardous Products Act and the Hazardous Products Regulations (HPR). WHMIS 1988 incorporated elements of hazard communication including product classification and labeling, the provision of Material Safety Data Sheets (MSDSs), and training for workers. It also required suppliers of so-called “controlled products” to properly label them and provide MSDSs to customers.

In February 2015, the HPR was updated to align WHMIS with the 5^th Revision of the Globally Harmonized System of Classification and Labelling of Chemicals (GHS). Aligning WHMIS with GHS created more consistency in hazard classification, standardized product labeling requirements and SDS format, and more closely linked physical hazards with the Transportation of Dangerous Goods Regulations. Under the updated legislation, any hazardous products used in a workplace – not just “controlled products” – are subject to the requirements of WHMIS 2015, with exceptions for certain products covered under other legislation. As much as possible, Canada tried to align its implementation of the GHS with that of the United States, which had revised its hazard communication standard in 2012 to align with the 3^rd Revision of the GHS.

How the GHS Sets a Baseline

The GHS, an internationally accepted system of hazard communication, is intended to provide common and consistent criteria to define and classify physical, health, and environmental hazards of chemical substances and mixtures. The system then conveys this information through a set of standardized hazard communication elements. It uses a harmonized format for SDSs and has specific criteria for labeling.

The 1^st Revision of the GHS was introduced in 2003, and the document has been updated by the UN Committee of Experts every 2 years since then. As of 2023, the current edition is the 9^th Revision, with another revision expected to be published this year.

While the UN GHS itself is not legally binding, over 70 countries worldwide have adopted some or all of the parts, or “building blocks”, into their systems of hazard communication. These building blocks correspond to different hazard classes and categories. This allows different countries to choose what to implement in their local legislation, which can lead to regional variations. Many of Canada’s major trading partners, including the United States, Australia, New Zealand, and the European Union, have already adopted or are working on aligning with the 7^th Revision of the GHS.

Read more at OSHA’s Proposed HazCom Implementation of GHS Revision 7.

Health Canada's Official HPR Amendment 

In December 2020, Health Canada recommended amending the HPR to bring it into alignment with the 7^th Revision of the GHS. While the update has some variances, it largely mirrors the changes suggested by the United States in its parallel effort to update the OSHA Hazard Communication Standard (HCS; Docket No. OSHA-2019-0001). The initial public comment period for Canada’s proposed amendment to the HPR ended in February 2021, the same month the United States published a proposed rulemaking to update the HCS to align with the 7^th Revision of the GHS. Canada’s public comment period was extended till May 2021, which coincided with the deadline for submitting comments on the United States’ proposed rulemaking, as well. Health Canada’s final rule to align the HPR with the 7^th Revision of the GHS, SOR/2022-272, was registered into law in the Canada Gazette on December 15, 2022 and published January 4, 2023.

How WHMIS Implements GHS Revision 7

The regulation changes do not alter the fundamental structure of WHMIS; rather, the incorporation of the elements of the 7th revision of the GHS improve the effectiveness of this hazard communication system and enhance workplace safety. Through the ongoing work of the U.S.–Canadian Regulatory Cooperation Council (RCC), the changes also align WHMIS with the upcoming OSHA Hazard Communication Standard update. The WHMIS update from the 5th Revision of the GHS to the 7th Revision includes some administrative updates and clarification of some hazard communication elements, including modification to the wording of some precautionary statements, addition of supplemental label elements, and amendment of definitions. It also introduces a new hazard class, hazard subcategories, alterations to Section 9 of the SDS, and several other changes.

Specific updates include:

• Adoption of a new hazard category for Non-flammable Aerosols (Category 3) 
• Introduction of the Chemicals Under Pressure physical hazard class, which is an element of the 8th Revision of the GHS
• Division of Category 1 Flammable Gases into two subcategories:
  
  • Subcategory 1A for Pyrophoric Gases and Chemically Unstable Gases
  • Subcategory 1B for flammable gases that are not pyrophoric or chemically unstable, but still have a flammability hazard
• Expansion of text methodology for Oxidizing Solids
• Addition of a second option for the hazard statement for Combustible Dusts
• Changes to the specific information requirements for physical/chemical properties in Section 9, including the removal of the “appearance” element and the addition of particle characteristics

When Manufacturers & Suppliers Need to Comply with WHMIS Revision 7 Updates

The hazardous products regulations came into force on December 15, 2022, the day they were registered in the Canada Gazette. Canada has implemented a 3-year phase-in period for chemical manufacturers and suppliers to bring their SDSs into compliance with this new revision. SDSs aligned with either the 5th or the 7th Revision of the GHS are considered compliant under the HPR until December 14, 2025.

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