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GUIDANCE MANUAL
Workplace Health Hazard Regulation (M.R. 53/88)
Introduction
Exemptions
Fugitive Emissions and Hazardous Wastes
Prevention Plan
Inventory List
Evaluation
Determining Occupational Exposure Limts (O.E.L.'s)
Monitoring
Controls
Records
Introduction
The Workplace Health Hazard Regulation is one half of a legislative package that also
includes the Manitoba Workplace Hazardous Materials Information System WHMIS Regulation.
The WHMIS regulation is a component of the federal WHMIS program. The relationships are
described briefly as follows.
The Federal Hazardous Products Act and Controlled Products Regulations require Canadian
suppliers and importers to classify any products they 'sell", (a very broad
definition), that meet the criteria of being Controlled Products. The legislation defines
the Controlled Product classification criteria. For any products meeting any
classification criterion, the supplier must label it with a special label and provide a
Material Safety Data Sheet (MSDS) with it.
Other Federal legislation, (Hazardous Materials Information Review Act and Regulations)
, define a procedure which allows suppliers to omit certain confidential business
information from labels and MSDSs.
The Manitoba WHMIS regulation requires employers to ensure that Controlled Products
received are properly labelled with the Supplier Label. They must also obtain MSDSs for
Controlled Products. For Controlled Products produced in the workplace, WHMIS requires the
employer to provide Workplace Labels and MSDSs. In addition, WHMIS requires employers to
provide training and instruction to workers who work with or near a Controlled Product.
WHMIS also provides a mechanism for employers to omit certain confidential business
information from labels and MSDSs.
The foregoing legislation is primarily concerned with the provision of information. The
Workplace Health Hazard Regulation (WHHR) provides the process for the application of this
information to safeguard the health of workers. The WHHR is an action-oriented regulation
rather than being information-oriented.
The structure of this manual is designed for the use of people who may not have a
strong background in WHMIS based requirements. The chapters are presented in the same
logical manner that would be used by most workplaces to implement the regulation.
The intent of the manual is designed to be performance oriented. There is not a heavy
emphasis placed here on a clause-by-clause discussion of the regulation. The emphasis here
is to describe the actions required by the WHHR in plain straight forward terms.
It should be noted however that the clause-by-clause compliance to the regulation does
rest with the employer. The employer should always refer to the actual regulation to
determine exact compliance requirements.
Exemptions
There are a number of situations which may limit the application of the Workplace
Health Hazard Regulation (WHHR). These situations are listed below in the order of the
most general to the most specific.
- Workplace Definition (W210 Sec. 1)
The regulation can only apply if the
situation involves a workplace as defined by the Workplace Safety and Health Act, (W210).
That is, a workplace means any building, site, workshop, structure, mine, mobile vehicle,
or any other premises or location whether indoors or outdoors in which one or more
workers, or self-employed persons, are engaged in work or have worked.
This definition provides the framework for the application of all regulations issued
under the authority of W210. If the situation at hand does not meet the definition of a
workplace, (such as a residential dwelling), then the WHHR does not apply.
In those instances involving chemicals used in the domestic setting, the area Public
Health Inspector may be able to offer some assistance.
- Jurisdiction (W210 Sec. 3)
Manitoba provincial legislation does not have force
in those workplaces which are ordinarily within the jurisdiction of the Parliament of
Canada. These federal workplaces include federal departments and agencies, banks,
interprovincial railroads, shipping, airlines, interprovincial trucking, ports, grain
elevators, and workplaces of a like nature. In the case of a provincially regulated
activity (i.e. construction), within a Federally regulated workplace (i.e. airport) , a
Safety and Health Officer should be contacted to advise which jurisdiction is applicable.
If there is a concern which is, or may be within the federal jurisdiction, then an
Occupational Safety and Health Officer from Labour Canada should be contacted to ensure
that the response to the concern is delivered by the appropriate jurisdiction.
This procedure is no different from the method in use now. Concerns from federal
workplaces are actioned by federal officers. The WHHR can only be enforced at workplaces
within the provincial jurisdiction.
- Presence of Controlled Product (Sec. 4(1))
In considering the application of
the WHHR in a "provincial" workplace, at least one Controlled Product must be
involved. The definition of a Controlled Product is noted in great detail in the Workplace
Hazardous Materials Information System (WHMIS) Core Material Program Manual. It includes:
compressed gas, flammable and combustible material, oxidizing material, poisonous and
infectious material, corrosive material, and dangerously reactive material. Under the
Federal Controlled Products Regulations (Section 33) , the supplier is responsible for the
classification of materials to see if they fit into any of the above categories. Note that
a supplier here means the manufacturer, processor, packager, importer or seller of a
Controlled Product.
In many cases, hazardous materials in Manitoba workplaces are raw materials and will
have already been classified by their manufacturer. If a Manitoba workplace imports or
produces a hazardous material which may fit the definition of a Controlled Product, then
that workplace must arrange to classify the material. (See the WHMIS Core Material Program
Manual - Classification).
If there are no Controlled Products used, stored or handled at a workplace, AND there
are no Controlled Products in fugitive emissions produced or disposed of at a workplace,
AND there are no Controlled Products in hazardous wastes produced, stored, handled or
disposed of at a workplace; THEN the WHHR does not apply.
In order to determine if these situations exist, the employer must check every material
which is received, produced or disposed of in a workplace to see if any fit any of the
Controlled Product classifications. This is no small task and must be undertaken whether
or not the employer wishes to take this exemption. Only after it has been determined that
no Controlled Products are present in the workplace can it be determined that the WHHR
does not apply.
- Wood, Tobacco, Manufactured Articles (Sec. 4(3))
The WHHR does not apply to
wood and wood products. A wood product is intended to mean a structured item. Wood-related
products which are not excluded by this exemption include turpentine, paper, wood pulp,
and the formaldehyde emitted by particle board. These materials are derived from wood and
are not products made of wood. Therefore, they may be subject to WHHR requirements. Paper
is exempt from WHHR because it is a manufactured article, not because it is a product made
from wood.
The WHHR does not apply to tobacco and tobacco products. The intention here does not
include tobacco smoke as a tobacco product. Even though tobacco smoke is not a tobacco
product, it may not be a good idea to use the WHHR to justify a no smoking policy since
tobacco smoke may not meet the definition of being a fugitive emission.
The WHHR does not apply to manufactured articles. These articles are those which:
- are formed to a specific shape or design; AND
- have a use which is dependent on the shape or design; AND
- under normal conditions of use do not release or otherwise cause a person to be exposed
to a Controlled Product.
Points i) and ii) are quite straight-forward. They generally mean that the manufactured
article has some physical shape and structure i.e. desk, wall, machine, equipment, tool.
Point iii) is somewhat more complicated. The definition talks about normal conditions of
use. This generally is intended to exclude hazards which are due to installation or abuse.
For example, consider an electric arc welding rod. When it sits on the bench, it poses no
hazard. However, its normal condition of use is during the welding process. At these
times, a worker may be exposed to a Controlled Product and thus the WHHR would apply.
In another example consider a chair which is lit on fire. A burning process is not a
normal condition of use and thus the WHHR would not apply.
In a final example, consider the laying of carpet with a glue containing a solvent. The
carpet is a new installation and therefore could be considered for an exemption but the
glue is handled as a normal condition of use and thus the WHHR would apply.
- Other Federal Legislation (Sec. 4(2))
There is a partial exemption from parts
of the WHMIS Regulation and hence parts of the WHHR for those hazardous materials
regulated by other federal legislation. The exemption for these products covers only with
respect to the Supplier Label and Material Safety Data Sheet. The reason this exemption
was granted was that the labelling required under the appropriate legislation was deemed
to be at least as informative as the WHMIS labelling.
As may be noted later, a partial labelling exemption does not provide any relief from
the main requirements of the WHHR.
The materials eligible for this partial exemption include:
- explosive within the meaning of The Explosives Act (Canada);
- cosmetic, device, drug or food within the meaning of The Food and Drugs Act (Canada);
- control product within the meaning of The Pest Control Products Act (Canada);
- prescribed substance within the meaning of The Atomic Energy Control Act (Canada); or
- product, material or substance packaged as a consumer product and in quantities normally
used by the consuming public.
Please remember that the exemption applies only to the requirement for a Supplier Label
and M.S.D.S. The requirements for training, inventory, evaluation of health hazards,
monitoring, controls, prevention plan, and records still remain in force.
A clarification should be offered for point (e) above.
- Reasonably Practicable (Sec. 3(a))
The WHHR can only be imposed on employers
to the extent that it is reasonably practicable. This determination is a judgement call in
every case. Since W210 generally limits actions to those reasonably practicable, therefore
all regulations are limited by this principle. It is certainly possible for an employer to
attempt to justify noncompliance with the WHHR on the basis of the requirements not being
reasonably practicable for the particular circumstances.
Each claim would be evaluated by the normal review process: Workplace Committee, Safety
and Health Officer, Director, Manitoba Labour Board, as the case may be.
- Offices and Stores (Sec. 5)
There is a section in the WHHR which allows an
exemption to be claimed for certain types of workplaces where there is a minimum risk to
workers. The workplaces eligible for this exemption include offices, retail
establishments, and those workplaces which under normal circumstances only present a risk
to a worker as the result of equipment or piping system failure.
It should be noted that a potentially large number of workplaces can attempt to claim
this exemption including sophisticated chemical processing plants. The keys to this
exemption are the phrases, "under normal circumstances", and risk "as a
result of failure of equipment ...". Some employers may claim sloppy conditions
(always present) , to be abnormal circumstances, and ignore emissions and leaks from
perpetually broken equipment. These types of arguments would require action by a Safety
and Health Officer since the normal conditions at the workplace and the state of equipment
repair is under the control of the employer.
In order to apply for this exemption, the employer (in consultation with the Safety and
Health Committee/Representative) would fill out a form. This form is called the Notice of
Claim of Exemption and is attached to the Regulation as Schedule D. The form asks the
listing of "Possible Health Hazards" and what "Controls" are to be
used in an emergency.
This form is then given to the Workplace Safety and Health Committee/Representative and
posted in the workplace. There is no requirement for this form to be approved by the
Division.
- Exemption from Monitoring (Sec. 24, 28(1), 30(1))
If there is reason to
believe that a worker may be exposed to a Controlled Product at a level between 1/2 of the
Occupational Exposure Limit (O.E.L.) and the O.E.L., then there is normally a requirement
for the employer to conduct monitoring to determine the actual exposure levels. If the
employer wishes, he may gain an exemption from the requirement to monitor by instead
directly implementing control measures. This does not provide an exemption from the duty
to monitor after control measures have been implemented to ensure that the control
measures have been effective.
- Evaluation (Sec. 18)
In Chapter 5 of this manual, (Inventory List), the
procedure is described whereby all Controlled Products in a workplace must be entered on
an inventory list. In Chapter 6 (Evaluation), the procedure is described whereby all the
materials on the inventory must be evaluated to determine which ones may pose a health
hazard. The employer in consultation with the Safety and Health Committee/Representative
is responsible for this evaluation. If the evaluation indicates that some Controlled
Products do not pose a health hazard, then no further work need be done for those products
regarding the setting of O.E.L.s, monitoring or controls.
This would seem to be a very reasonable procedure since excessive effort should not be
expended in areas which do not present a hazard to workers.
A concern would arise if an employer and Safety and Health Committee/Representative
were to specify that their Controlled Products did not pose a health hazard, (having done
little or no conscientious evaluation of the health effects) . It would then be possible
for that workplace to gain an exemption from having to set O.E.L.s, do monitoring, or
implement controls. In this case, workers might be exposed to significant health risks and
no mechanism for correction would be in place.
In a situation such as that above, a Safety and Health Officer could order a proper
evaluation be made under Section 18(1) by indicating the officer's opinion that certain
Controlled Products might pose a Health Hazard. In order to appeal this type of order, the
workplace would have to show that there was no health hazard, (in effect they'd have to do
the evaluations in order to appeal an order requiring them to do the evaluations).
Fugitive Emissions and Hazardous Waste
The subject areas of emissions and waste are likely to cause some confusion within
workplaces The various pieces of legislation within the WHMIS framework are not completely
consistent regarding the requirements for these types of materials.
The following subsections will discuss fugitive emissions and hazardous waste
separately.
Fugitive Emissions
The WHHR defines a fugitive emission as a material containing a Controlled Product that
escapes from: process equipment, emission control equipment, a product or device in the
workplace, or from any facility which constitutes part of a workplace. Examples of these
emissions could include propane fork lift truck exhaust, welding fume, solvent vapours
from dip tanks, and off-gassing from production reactions.
The Hazardous Products Act and Controlled Products Regulations are silent about
fugitive emissions (hereafter FE), since they are generated within a workplace and are not
a Federal responsibility. The two Manitoba regulations, (WHMIS and WHHR), both discuss FE.
They are defined identically in both regulations.
Both WHMIS (Sec. 5(1)(e)) and WHHR (Sec. 1O(2)(c)) require that workers working with,
or in proximity to a FE must be instructed in safe handling procedures.
WHMIS Sec. 7(2) specifies that a FE does not need to be labelled with a workplace
label. WHHR Sec. 12 requires that FE locations must be identified with a placard which
contains the same information that is required by a workplace label.
WHMIS Sec. 13(2) specifies that a FE does not require the preparation of an MSDS. WHHR
Sec. 13(1) specifies that a FE does require the preparation of an MSDS. This is obviously
a discrepancy in requirements. The discrepancy between the two regulations is explained in
the following manner. Manitoba's WINIS legislation is based on a model regulation used by
all the provinces. In most other jurisdictions full WHMIS information is not required for
FE.
Consultations in Manitoba indicated that workplaces wanted and needed FE WHMIS
information. For this reason, the WHHR contains more stringent requirements for FE than
does WHMIS.
The intent is that employers must comply with WHHR requirements. This intent is noted
by WHHR Sec. 9(1). FE's containing Controlled Products should require the preparation of
an MSDS and labelling or placard identification.
The WHHR requires that the content and availability of the MSDS for the FE be the same
as for other Controlled Products.
The educational requirements for FE's are the some as for other Controlled Products,
(WHHR Sec. 10).
Hazardous Waste
The requirements for Hazardous Waste (hereafter HW), are more complex than for fugitive
emissions. The federal HPA exempts HW from the application of federal legislation, (HPA
Sec. 12(e)). For clarification, the CPR defines HW as a Controlled Product that is
intended for disposal or is sold for recycling or recovery. The definition in Manitoba's
WHHR modifies this meaning by inserting the word "solely" between
"intended" and "for". This narrows the definition slightly.
WHMIS Sec. 2(4) exempts HW from provincial action except for a broad requirement to
identify and educate to ensure safe storage and handling. WHHR on the other hand does not
allow this exemption. WHHR Sec. 4(1)(c), and 8(b) require the application of full regular
WHMIS requirements to HW containing Controlled Products. This discrepancy between WHMIS
and WHHR results from the same reason as explained for Fugitive Emissions. WHMIS was based
on a model regulation used across the country and did not give adequate protection to
workers. Therefore, WHHR included stronger worker protection requirements.
WHHR Sec. 11 requires the identification of the HW with a workplace label or placard.
Some workplaces find it helpful to use a modified Transportation of Dangerous Goods (TDG)
Label as a HW Workplace Label/Placard.
WHHR Sec. 13(1) requires the preparation of an MSDS for a HW. The content and
availability of the MSDS is the same as for other Controlled Products. The employer has
the option of providing MSDSs for the ingredients in the HW rather than prepare a new MSDS
for the mixture. In this case the employer should attach the MSDSs together and affix a
cover or face sheet containing the HW name.
WHHR Sec. 10 requires educational training and instruction that is similar to the
educational requirements for other Controlled Products under WHMIS.
A HW may be stored while the employer is actively seeking a label, MSDS or educational
information, (WHHR Sec. 9(2)). In this case the HW may not be produced, handled or
disposed of until the proper labels, MSDS and education programs have been implemented.
Sample Hazardous Waste Workplace Label
HW's may not be sold or disposed of unless the HW is properly labelled and an MSDS is
transmitted to the purchaser/receiver (WHHR Sec. 15). MSDSs need not be transmitted with
each shipment as long as the person receiving the HW already has valid MSDSs less than
three years old.
Summary
The intent of WHHR is to ensure that the provisions for labels, MSDSs, and education
required by WHMIS for "regular" Controlled Products are also applied to Fugitive
Emissions and Hazardous Waste.
Prevention Plan
A comprehensive regulation like the WHHR may seem imposing for those workplaces which
do not have a complete hazard control program. It may appear difficult to implement if not
approached in a logical manner. For this reason, a section was included in the regulation
which was designed to assist workplaces to implement the WHHR This section is called Part
V Prevention Plan.
The intent of the Prevention Plan is to provide a framework for the logical application
of the regulation. By viewing the requirements of the WHHR in segments it becomes much
easier to plan workplace action.
Just as the concept of the Prevention Plan is very simple, so is its completion.
Basically the Prevention Plan is a written document which outlines the steps that a
workplace must complete before achieving full compliance with the regulation. The plan can
lay out an agenda of necessary actions on paper with priorities noted, responsibilities
assigned, time frames set and resources allocated. By using this procedure, a workplace
can ensure that worker health is receiving the maximum protection, while at the same time,
resources are utilized in the most efficient manner.
The Prevention Plan required by the regulation contains a minimum of mandatory
information. It is required if any Controlled Products are present in a workplace. The
points which must be included in the plan include the following:
- the workplace identification;
- the date of preparation;
- the name(s) of the author(s);
- the steps to be taken in the next year to ensure that no worker is exposed to a
Designated Material in excess of its 0.E.L. This means that cancer causing chemicals are
controlled to levels as close to zero as is reasonably practicable;
- the steps to be taken in the next year to ensure no exposure to a health hazard.
Other requirements are noted in Chapter 10. Records. These required contents are
obviously only the minimum items of information which a workplace may wish to consider on
a planning document.
Other non-legislated pieces of information which a workplace may want to include on the
plan include the following
- divide the WHHR into small action steps (i.e. collect MSDSs, check purchasing records as
source of inventory list, arrange plant inspection for Controlled Product processes,
collect list of education resources, etc.);
- assign a priority to each action step;
- assign personnel resources to each action step;
- assign monetary, time and technical resources to each person assigned an action step;
- establish time lines for each action step;
- initiate work on action steps in a logical manner. Do high priority steps as early as
possible;
- establish a follow-up mechanism to keep track of the progress on the various action
steps;
- establish a communication system to keep workers advised on the progress towards
completion of the action steps.
If this Prevention Plan is laid-out in a logical manner, it can serve to focus
resources on those actions which are most important. The chances of wasting resources on
inappropriate actions will be reduced and worker health will be protected to the highest
extent possible.
Inventory
The WHHR requires that the employer (in consultation with the Workplace Safety and
Health Committee or Representative), prepare an inventory of all Controlled Products in a
workplace (WHHR Sec. 17(1)).
The preparation of this inventory list is one of the first duties required in a
workplace in order to comply with the WHHR. This list is also a base for further action
under the WHHR and is one of the most important requirements in this legislative package.
If the list is poorly prepared, then the entire control program will be inadequate. If
inappropriate materials are on the list, then resources may be committed to areas for
which there is no need.
Inventory Sources of Information
A number of questions have been asked regarding the sources of information which can be
used to prepare such a list. The regulation does not specify the sources for the inventory
list, but a number of common sense approaches can be considered. It should be kept in mind
that a Controlled Product is one or more of the following:
- compressed gas
- flammable and combustible material
- oxidizing material
- poisonous and infectious material
- corrosive material
- dangerously reactive material
Some sources of information which can be used to assemble the inventory list include
the following:
- Supplier Material Safety Data Sheets
After October 31, 1988 any supplier of a Controlled Product was required to provide an
MSDS with the first shipment of the product. Employers are required by the WHMIS
Regulation (Sec. 12(1)) to obtain these MSDSs. WHMIS requires that these sheets be kept
readily available at the workplace. By checking the information provided on these sheets,
it may be possible to determine which products are Controlled, and thus which ones should
be on the inventory. Many firms have been collecting MSDSs for some time and thus a
file will already exist. This file can be examined to determine some of the materials in
use which should be on the inventory list.
One point to note is that some non-Controlled Products will have MSDSs, (these do not
have to go on the inventory list). There is no requirement that an MSDS report whether or
not a material is a Controlled Product.
- Employer Material Safety Data Sheets
WHMIS (Sec. 13(1)) requires that the employer prepare an MSDS for every Controlled Product
produced in the workplace. Every material which requires an employer MSDS should be on the
inventory list. In most cases however, the inventory list itself will be the instrument by
which decisions are made regarding which materials need an MSDS, (both supplier provided,
and employer prepared).
- Consultation
Consultation with workers is a good method of obtaining suggestions for some of the
Controlled Products that should appear on the inventory list. The workers themselves often
have information about which materials and processes are hazardous. This is a particularly
important source of information for determining which Controlled Products are produced in
the workplace, (especially fugitive emissions and hazardous wastes). The method of
consultation should include discussions with the safety and health
committee/representative as well as with key workers in each part of the workplace.
- Inspection
There is no substitute for determining which Controlled Products are used/produced in a
workplace which can replace a thorough inspection. This should be done by management and
worker members of the safety and health committee. All work areas should be thoroughly
examined. Labels should be inspected for materials which may be considered for the
inventory list. A statement on a label indicating a hazard is sufficient justification to
seek more information on that material for possible addition on the inventory list.
If a material has a WHMIS supplier label on it, then it should automatically be added
to the inventory list.
Sometimes the workplace inspection may be used to supplement information generated by
the examination of purchasing records, (see part e) following). The purchasing records
will indicate which materials are ordered externally, and the plant inspection can be used
to give specific material information which may be used to whittle down which purchased
products can be deleted from the inventory list. The purchasing records are usually very
extensive and the physical examination of the actual individual materials is often
sufficient to determine if they may be Controlled Products.
One of the major benefits of the workplace inspection is the examination of the plant
processes. Each process should be examined to determine if it:
- generates a Controlled Product;
- generates a fugitive emission which is a Controlled Product;
- generates a hazardous waste which is a Controlled Product.
If any of the above are possible, then those generated Controlled Products must be
added to the inventory list. The workplace inspection is the best method of identifying
the Controlled Products which are produced within the workplace.
- Purchasing Records
The most complete method of determining the materials received at a workplace is the
examination of the purchasing records. Most workplaces have records which indicate what
products are purchased from what suppliers. These records are usually quite extensive and
include many materials which are obviously not Controlled Products. The method that
many workplaces use to prepare their first draft inventory list is to review the
purchasing records and list all materials which might possibly be Controlled Products. The
suppliers for these materials are then contacted and asked to send either:
- an MSDS or;
- a statement that their material is not classified as a Controlled Product. A form letter
is useful for this purpose.
By examining the replies from this inquiry, the workplace can then revise the draft
inventory list to include only Controlled Products. Needless to say, when new materials
are required, MSDSs must be obtained and revisions to the inventory list made.
This method of using purchasing records is often the first step a workplace takes in
starting the inventory list.
- Transportation of Dangerous Goods
The Federal Government requires that certain classes of material which are classed as
"dangerous goods" by the Transportation of Dangerous Goods Act are properly
identified by labels and placards. These identifiers are the diamond shaped symbols which
are commonly seen on trucks. This federal legislation is supported provincially by the
Manitoba Dangerous Goods Handling and Transportation Act. In most cases, a material
which must be placarded by TDG will be a Controlled Product under WHMIS. Examination of
the materials received with TDG labels/placards will assist in assuring that the inventory
list is complete.
- Other Sources
Other sources of information to ensure a complete inventory list include the following:
- in-house technical staff;
- in-house workers who may have worked in similar workplaces;
- trade associations;
- union groups;
- external technical resources including consultants;
- technical publications.
Content of Inventory List (Sec. 17(2))
The WHHR specifies very clearly the minimum content of the inventory list. The content
must include:
- identity of the workplace;
- product identifier for each Controlled Product in the workplace. This includes materials
received as well as materials generated;
- location of MSDSs for each Controlled Product;
- maximum quantity of each Controlled Product likely to be present in the workplace;
- date of completion of inventory;
- name(s) of person(s) who prepared the inventory.
Many workplaces have found it useful to computerize the inventory list and to include
other items of information on the list. There is no restriction against doing this as long
as the required information is present.
Other Inventory Requirements
The WHHR has a number of other requirements regarding the inventory list which are
fairly self-explanatory. These include the following requirements:
- the Safety and Health Committee/Representative must be consulted by the employer when
the inventory list is made and maintained, (Sec. 17(1));
- the inventory must be written and posted in the workplace and furnished to the Safety
and Health Committee/Representative, (Sec. 17(2), 17(5));
- when different Controlled Products are introduced into, or removed from use in the
workplace, then another report must be prepared. It is called "Notice of Change of an
Inventory". The report must be prepared within 15 days of a new Controlled product
being introduced into the workplace. It is also required within 60 days of a Controlled
Product being removed from use in a workplace, (Sec. 17(3)).
- all Notices of Change of an Inventory must be posted and copies given to the Safety and
Health Conmittee/Representative, (Sec. 17(5));
- when an inventory list is changed during the year, (usually as noted by the Notice of
Change of an Inventory), then a revised inventory must be prepared within 1 year of the
date of the original inventory list, (Sec. 17(4));
- all inventory lists are designated as records and must be maintained and preserved for
30 years.
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