Federal/Provincial Interaction & WHMIS
SDS Format: 16 headings
1. Identification 2. Hazard Identification 3.Composition/info on ingredients 4. First Aid measures 5. Fire-fightining measures 6. Accidental Release measures 7. Handling and Storage 8. Exposure control/personal protection 9. Physical & Chemical properties 10. Stability and Reactivity 11. Toxicological info 12. Ecological info 13. Disposal considerations 14. Transport info 15. Regulatory info 16. Other info
Content on MSDS
1. product information 2. hazardous ingredients 3. physical data 4. fire or explosion hazard 5. reactivity data 6. toxicology properties 7. preventative measures 8.first aid measures 9. preparation information
Product Identification number (PIN)
4 digits for pure chemicals and groups of chemicals which can assist with locating hazard info can be UN or NA origin
Why was Bill C45 Necessary?
C --> Canadian piece of legislation 45--> 45th law that was passed based on westerly mine explosion and subsequent inquiry recommendations to have stricter penalties including criminal negligence causing death and enforcement of them it was the outcome of that recommendation Ottawa, October 31, 2003 -helps ensure organizations are held accountable when they commit criminal offences
GHS Element
Classification Criteria -health and environmental hazards -physical hazards -mixtures Hazard Communication -Labels -SDS
What are the different WHMIS controlled product classes?
Compressed Gases Flammable and Combustible Material Oxidizing Material Poisonous and Infectious Material Corrosive Material Dangerously Reactive Material
Signal Words
Danger or Warning used to emphasize hazard and discriminate between levels of hazards
Penalties
Federal (max) -persons: if injury max 10yr prison -death: life imprisonment -summary conviction: $100,00 fine -indictment: unlimited $ Provincial-Ontario -individual <25L per offence &/ <1yr jail -Corporation: <$500K per offence -Fines subject to 25% victim charge
Precautionary Information
GHS label should include appropriate precautionary info GHS document includes ex. of precautionary statements which can be used intent is to harmonized precautionary statements in the future
What should companies do to avoid penalties?
Gap Analysis: look at what programs are in place for HS, do we have all the programs we need, are they up to date and are they being enforced and effective Work Audits: are they actually being implemented, being shown that everything is being practiced Implement/improve OHS management system, ensure OHS regular compliance: rules and systems Protect action plan by solicitor/client privilege: lawyer creates an audit trial of HS management and how you have been complying, crate a binding document and call it privilege-only person that can look at workplace audits is manager and lawyer-solicitor not allowed to see binder unless passed by lawyer
Federal Legislation
Hazardous Products Act Controlled Products Regulations Ingredient Disclosure List Hazardous Materials Info Review List Hazardous Material Info Review Regulations
What is the purpose of WHMIS?
IDENTIFY hazardous materials in workplace PROVIDE INFO on hazard materials used in workplace ensure CONSISTENCY of hazardous info in Canadian workplaces
SDS Format: 16 headings -Accidental Release Measures
PPE emergency procedures methods and materials fro containment and cleaning up
Prison vs. Jail
Prison-federal Jail-provincial
MSDS requirements
Revision: every 3 years, within 90 days of new hazard info becoming available Location: available and accessible by workers Language: english and french
Roles of SDS in GHS
SDS should provide comprehensive info about chemical substances/mixtures primary use: workplace employees and workers use SDS for info on hazards and get advice on safety precautions
Responsibilities of -Suppliers/Manufacturers -Employer -Worker
Suppliers/Manufacturers -classify products -supplier labels for all controlled products manufactured processed, packaged, imported/sold by suppliers and apply to containers of controlled products as condition of sale -MSDS -Provide MSDS to costumers Employer -classify products produced in the workplace -provide MSDS -workplace labels -worker education Workers -participate in training -apply knowledge -inform employer when they have inadequate info on a controlled product
Pictogram Shape and Colour
Transport: have background and symbol currently used Other sectors: black symbol, white back, red diamond frame where a transport pictogram appears, GHS pictogram for same hazard shouldn't appear
SDS Format: 16 headings -Transport info
UN number UN proper shipping name environmental hazards special precautions
International Mandate
adopted at UN conference on Environmental and Development (UNICED) in 1992 in Brazil globally harmonized hazard classification and compatible labelling system, SDS, easily understand symbols should be available in 2000 Canada didn't adopt this until 2015
Key elements of WHMIS
also ways to provide info to workers about the hazards of controlled products used on the job 1. MSDS 2. Labels: WHMIS label must be affixed to container before product can be used, provides info on basic hazards, proper handling procedures, first aid 3. Training: developed by employers in consultation with joint health and safety committees designed to teach workers, how to apply info printed on MSDS and labels or consultation
SDS Format: 16 headings -First Aid Measures
by root of exposure -inhalation -skin contact -eye contact -ingestion
SDS Format: 16 headings -Composition/info on ingredients
chemical name common name and synonyms CAS registration number unique identifiers chemical name of impurities stabilizing solvent and additives
SDS Format: 16 headings -Stability and Reactivity
chemical stability possibility of hazardous reactions conditions to avoid incomplete materials hazard decomposition products
What is the GHS
common and coherent approach to defining and classifying hazards and communicating info on labels and SDS target audiences include workers, consumers, transport workers, and emergency responders provides the underlying infrastructure for establishment of national, comprehensive chemical safety programs
Example of exempted products from WHMIS
consumer products-under hazardous products act explosives food and drug act pesticides-pest control products act atomic energy control act wood or wood products manufactured articles tobacco or tobacco products hazardous waste
SDS Format: 16 headings -Exposure control/personal protection
control parameters engineer controls PPE
Scope of GHS
covers all hazardous chemical substances, dilute solutions and mixtures pharmaceuticals, food, cosmetics, pesticides residues in food not covered at point of international intake but will be covered where workers may be exposed and in transport
Canadian Implementation of GHS-July 2015
currently in force-supplier has began to use and follow requirements for SDS transition period right now, after all rules should be followed
Physical Hazards
definitions, test methods and classification criteria for transport were used as a basis for work since they were already harmonized based on existing TDG requirement ex. explosives, flammability, self-reactive, gases under pressure
worker and education programs
developed in consultation with joint HS reviewed at least once/year or more often if -conditions at workplace change -new info on a controlled product becomes available all workers who work with or in proximity to a controlled product receive training training includes: -generic instructions-labels, MSDS -specific training-trainingi n work place -how WHMIS works -hazards of groups of products which have similar properties -work procedures for groups of products
SDS Format: 16 headings -Ecological Info
ecotoxicity persistence degradability bioaccumulative potential mobility in soil
Benefits of having a harmonization system
enhance protection of humans and environment facilitate international trade in chemicals reduce need for testing and evaluation assist countries and international organisms to ensure sound management of chemicals
Hazardous Materials Info Review Act
establishes a commission to rule on claims and appeals related to trade secret claims
Federal vs. Provincial Legislation
federal: -grandfather -supersedes provincial legislation -has made provinces responsible for H&S in provincial workers -is responsible for setting laws for H&S for federal employees & may set laws for all provinces when there is a general need or they believe there is an overall benefit for Canadians -eg. WHMIS, TDGA, Bill C45 Provincial -report back to federal
Indictment
formal accusation that a person has committed a crime
product identifier
identification of product by generic name, trade...specified by supplier, identifier on data sheet must be identical with identifier on product label
SDS Format: 16 headings -disposal considerations
info on sale handling for disposal and methods of disposal including any contaminated packaging
Why is classification of products necessary?
is the determination of whether a product meets the criteria for any WHMIS classes determines whether a product is controlled determines what goes on WHMIS label, ie. symbol, statement... what info is provided on MSDS what training is required for workers
What does Bill C45 say?
legislation makes organization criminally liable: as a result of the actions of senior officers who oversee day to day operations but who may not be directors/executives when officers with executive/operational authority intentionally commit/direct employees to commit crimes to benefit organizations when officers with executive or operational authority become aware of offences being committed by other employees but don't take action to stop them when the actions of those with authority and other employees, taken as a whole, demonstrate a lack of care that constitutes criminal negligence
Controlled Products
materials that are determined to be hazardous according to WHMIS criteria are called controlled products
Manufacturer and Supplier Identifier
name, address, emergency number
Ingredient Disclosure List
names of chemicals that must be identified on MSDS
confidential business info
national authorities should establish appropriate mechanisms for CBI protection. CBI will not be harmonized under GHS CBI protection shouldn't compromise health and safety of users CBI claims should be limited to number of chemicals and concentration of mixtures
What is WHMIS
national system for disclosing info on the hazardous materials used in Canadian workplaces designed to provide employees and workers with a uniform level of info about hazardous materials in workplace legislation is the result of co-operation among federal and provincial government in Canada with input from both labour and industry came into effect October 31, 1988 there are both federal and provincial regulations that specify requirements for WHMIS
Why is the GHS needed?
no country has ability to identify and specifically regulate every hazardous chemical product adoption of requirement for info to comparing the product helps address protection needs many diff. countries have come to the same concentration about using info dissemination as a regulatory means to address chemical hazards while similar, they are diff enough to require multiple labels and SDS for the same product in international trade countries with systems have diff requirements for hazard definition as well as info to be included on label or MSDS ex. a product may be considered flammable or toxic in one country but not in another to which it is being shipped diff. impact both protection and trade area of trade, need to comply with multiple regulations regarding hazard classification and labelling is costly and time consuming small-->medium enterprises are effectively precluded from international trade in chemicals due to the regulatory burden of compliance
Provincial Legislation
occupational HS legislation requires employers to provide -labels -MSDS -worker education enabled by the Hazardous Products Act
SDS Format: 16 headings -Physical and Chemical properties
odour pH solubility flash point
Key Label Elements
product identifier, supplier identifier, chemical identifier, hazard pictograms, signal words, hazard statement, precautionary info
SDS Format: 16 headings -Identification
product name recommended use restriction on use supplier identifier->name, address, number(s), emergency number restriction on use
Principles of Harmonization
protection wil lonen be reduced; comprehensibility will be key all types of chemicals will be covered; based on intrinsic properties/hazards of chemicals all systems will have to be changed
Supplier Label
provided by a supplier of controlled products disclosing info and displaying the hazards symbol that apply to product hazard symbol hatched border product identifier supplier identifier risk phrases precautionary measures first aid statement reference to MSDS English and French
Hazardous Material Info Review Regulations
providing criteria for determining validity of a trade secret claim
Workplace Label
put on a controlled product in workplace requires less info than a supplier label Product Identifier: Chemical X Safe handling advice: gloves, eye protection, use in well ventilated areas Reference to MSDS
Training under GHS (WHMIS 2015) in Canada
require employers to develop, implement and maintain worker WHMIS education and training program requirements don't change with WHMIS 2015
Controlled Products Regulations
requirements specifying form and content of supplier labels types of arrangements of MSDS conditions of exemptions details of criteria that define controlled products
Hazardous Products Act
requires suppliers of controlled products to provide MSDSs and labels as a condition of sale and importation
SDS Format: 16 headings -Toxicological Info
route of exposure symptoms related to physical, chemical, toxicological characteristics effect of ST and LT exposure
SDS Format: 16 headings -Handling and Storage
safe handling conditions for safe storage
SDS Format: 16 headings -regulatory info
safety health environmental regulations specific to product
Hazard Statements
single harmonized hazard statement for each level of hazard within each hazard class ex. flammable liquid Category 1: extremely flammable liquid and vapour Category 2: highly flammable liquid and vapour Category 3: flammable liquid and vapour Category 4: Combustible liquid
Health and Environmental Hazards-Acute Toxicity
skin corrosion/irritation, eye damage/irritation respiratory/skin sensitization reproductive toxicity
Product Use
specifies product use intended by manufacturer or suppliers, uses other than those intended may pose a risk to workers
SDS Format: 16 headings -Fire fighting Measures
suitable and unsuitable extinguishing media specific hazards arising from hazardous product PPE precautions
SDS Format: 16 headings -Hazard identification
symbol/name of symbol signal word hazard statement(s) precautionary statement(S)
What is an MSDS?
technical document which provides info on -health effects -hazards-storage, handling and use -measure to protect workers -emergency procedures intended to supplement info provided on WHMIS label
Tiered Approach to Classification
use to test data for mixture, when available --> use bridging principles, if applicable --> for health and environmental hazards, estimate hazards based on known ingredient info
What does Bill C45 mean?
we have taken a major step toward ensuring employees will be held responsible for criminally negligent acts in the workplace
SDS Format: 16 headings -other info
who wrote it signed off
