The Globally Harmonized System for the Classification and Labelling
(The GHS) - Implementation of the GHS in Canada
Workplace Hazardous Materials Information System (WHMIS)
Introduction
The GHS includes harmonized classification criteria and hazard communication
elements, i.e., labels and safety data sheets (SDSs). This document compares
the GHS and the WHMIS sector in a number of categories; (a) GHS vs WHMIS
for classification criteria, physical, health and environmental hazards,
(b) classification criteria for mixtures, (c) hazard communication for
labelling requirements, including symbols and (d) material safety data
sheets (MSDSs).
In general, the GHS hazard classes and the overall classification criteria
found within those hazard classes mirror those of the current WHMIS program.
However, in many cases, the GHS has designated specific categories within
hazard classes, which is a distinction not made in the existing WHMIS
criteria. The GHS includes classification criteria for explosives which
are exempt under WHMIS. Yet there are other hazard classes under WHMIS,
such as Class D3, biohazardous materials, for which there is no GHS category.
There are a number of similarities between the key label elements found
in the GHS and in WHMIS. Both systems require product identifier, supplier
identifier, hazard symbols, hazard statement/risk phrases and precautionary
information/first aid measures. Note that the definition of risk phrase
in the Controlled Products Regulations (CPR) "means, in
respect of a controlled product or a class, division or subdivision of
controlled products, a statement identifying a hazard that may arise from
the nature of the controlled product or the class, division or subdivision
of controlled products" and is considered to be equivalent to a hazard
statement. The GHS has standardized hazard statements but no specific
phrases specified in the CPR. Currently, there are only suggested
examples of risk phrases on the WHMIS Web site. The GHS includes identifying
hazardous ingredients on a label but also includes that a competent authority
may choose to give suppliers discretion to include chemical identities
on the SDS rather than on the label. In addition, the current WHMIS label
must have a statement indicating that a MSDS is available. WHMIS has the
hatched border for which there is no comparable border under the GHS.
Adoption of the GHS label in Canada will mean changes to the current WHMIS
regulations.
Hazard symbols are another aspect of label requirements that are similar
for both WHMIS and GHS. Generally, the hazard glyphs are similar in both
systems but the symbol shape and colour are different. Upon implementation
of GHS there will need to be changes to all of the currently used WHMIS
hazard symbols which means that the CPR will have to be amended
to replace its currently used symbols.
WHMIS has adopted a nine heading material safety data sheet (MSDS\s)
requirement (CPR Section 12 and Schedule I). The 9 headings are:
hazardous ingredients, preparation information, product information, physical
data, fire or explosion hazard data, reactivity data, toxicological properties,
preventative measures and first aid measures. However, as an administrative
policy, MSDSs for WHMIS controlled products which use the International
Labour Organization (ILO), International Standards Organization (ISO)
or European Commission (EC) 16 heading format are accepted as meeting
compliance requirements of Section 12 of the CPR , provided that
all 16 headings are disclosed (in the sequence recommended by these other
standards) and that the required content specified under Schedule I, Column
III of the CPR is addressed. Under the ILO heading "Regulatory
Information", the following statement should appear: "This product has
been classified in accordance with the hazard criteria of the Controlled
Products Regulations and the MSDS contains all the information required
by the Controlled Products Regulations."
The GHS requirements for safety data sheet (SDS) are for a 16 heading
modified ILO. The GHS 16 heading SDS has requirements for most of the
information already required for in the WHMIS MSDS. There are some additional
requirements such as transportation information, and for classification,
label elements and symbols.
Based on the fact that all chemicals and chemical products in commerce
are made in a workplace (including consumer products), handled during
shipment and transport by workers, and often used by workers, there is
no complete exemption from the scope of the GHS for any particular type
of chemical or product. Labelling of pharmaceuticals, food additives,
cosmetics, and pesticide residues are not covered in the GHS at the point
of consumer use or intentional intake. However, these types of chemicals
are covered under the GHS where workers may be exposed. Under WHMIS, a
number of products are excluded, namely:
- (a) explosive within the meaning of the Explosives Act;
- (b) cosmetic, device, drug or food within the meaning of the
Food and Drugs Act;
- (c) control product within the meaning of the Pest Control
Products Act;
- (d) nuclear substance, within the meaning of the Nuclear
Safety and Control Act, that is radioactive;
- (e) hazardous waste;
- (f) product, material or substance included in Part II of Schedule
I of the Hazardous Products Act and packaged as a consumer product;
- (g) wood or product made of wood;
- (h) tobacco or a tobacco product as defined in section 2 of
the Tobacco Act; or
- (i) manufactured article.
Adoption of the GHS may provide impetus for a review of these exclusions
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