|
|
Home /
MSDS Violations /
MSDS Violations
The WHMIS trade secret exemption mechanism administered by the Hazardous Materials Information
Review Commission requires that the MSDS accompanying a claim be reviewed against the
requirements of the Hazardous Products Act and Controlled Products Regulations. The statistical
information shown below outlines the Commission’s findings of MSDS non-compliance for the fiscal
years 2003–2004 and 2004–2005.
While the MSDSs reviewed by the Commission cannot be said to represent a random sample of all such
documents in use in Canada (estimated to be in the order of some 750,000), there seems little reason to
conclude that our findings should not be considered as broadly indicative of the state of MSDS
compliance in general.
The term “violation occurrence” is used in the quantification of the Commission’s MSDS review
findings. For example, a missing acute lethality value for a hazardous ingredient counts as one violation
occurrence. Similarly, if two such values associated with the same ingredient are undisclosed, or if a
value has not been disclosed for two hazardous ingredients, there would be two violation occurrences
counted in each case.
In general, it is important to note that the amount of information “available” for disclosure on a MSDS
can vary substantially. For example, a LD50(oral) value is more likely, compared to an LC50(inhalation)
value, to have been determined for a given hazardous ingredient.
Aggregate multi-year MSDS violation statistics have been published for several years in the
Commission’s Annual Report.
Violation Category |
Number of Violation Occurrences |
2004–2005 |
2003–2004 |
Hazardous ingredients (See Note 1) |
|
|
Chemical identity not disclosed |
50 |
51 |
Chemical identity incorrectly disclosed |
4 |
24 |
CAS registry number not disclosed |
30 |
27 |
Concentration not disclosed |
53 |
64 |
Concentration incorrectly disclosed |
25 |
33 |
Concentration ratios missing or incorrect |
92 |
14 |
LD50 (oral) not disclosed |
112 |
123 |
LD50 (dermal) not disclosed |
28 |
26 |
LC50 (inhalation) not disclosed |
52 |
40 |
Generic chemical identity |
|
|
(For the claimed trade secret ingredient) |
12 |
27 |
Preparation information |
|
|
(Preparer’s name, telephone number, date of preparation—at least one missing) |
147 |
132 |
Product information |
|
|
Manufacturer—supplier identity, etc. |
11 |
8 |
Product use |
17 |
8 |
Physical data |
|
|
Odour & appearance |
70 |
– |
Other |
9 |
91 |
Fire or explosion hazard |
|
|
Flash points |
10 |
9 |
Hazardous combustion products not disclosed |
48 |
103 |
Reactivity data |
|
|
Stability |
– |
1 |
Incompatibility |
101 |
29 |
Hazardous decomposition products not disclosed |
6 |
17 |
Toxicological properties (See Note 2) |
|
|
Route of entry |
15 |
8 |
Effects of acute exposure |
119 |
90 |
Effects of chronic exposure |
127 |
143 |
Exposure limits |
85 |
117 |
Irritancy |
16 |
39 |
Corrosivity |
21 |
2 |
Sensitization (dermal) |
10 |
4 |
Sensitization (respiratory) |
2 |
20 |
Carcinogenicity |
16 |
12 |
Reproductive toxicity |
17 |
6 |
Development toxicity |
64 |
67 |
Mutagenicity |
67 |
69 |
Synergism |
18 |
18 |
Preventive measures |
|
|
Leak/spill procedures |
– |
1 |
Waste disposal |
– |
2 |
Handling procedures |
4 |
5 |
Storage |
– |
9 |
First aid measures (See Note 3) |
|
|
Aspiration risk |
37 |
45 |
Remove advice to administer water in cases of ingestion |
80 |
97 |
CPR |
55 |
98 |
Eye contact measures |
56 |
29 |
Skin contact measures |
84 |
92 |
Hazard classification (See Note 4) |
|
|
Class B |
2 |
– |
Class D1 |
36 |
35 |
Class D2 |
29 |
28 |
Class E |
13 |
8 |
Format—wording |
36 |
57 |
Headings |
70 |
6 |
Registry number—date of filing |
147 |
94 |
Total |
2,103 |
2,028 |
Number of claims—controlled products |
245 |
225 |
Average number of violation occurrences per claim |
8.6 |
9 |
|