Update on WHMIS Amendments to Align with GHS Revisions 7 & 8

In December 2022, WHMIS was amended to align with the 7th edition of GHS and certain provisions of the 8th edition. For simplification, going forward WHMIS will not be known by any specific year.

The following workplace health and safety legislation is affected by these amendments: 

Workplace Hazardous Materials Information System (WHMIS) 
Hazardous Products Act (HPA) 
Hazardous Products Regulations (HPR).

Summary of GHS Revisions:

In 2015, Canada adopted GHS revision 5th. In this latest update, Health Canada has aligned Canada’s Hazardous Products Act with the 7th and 8th revision.

Implementation Timeline:

Businesses will have a three-year transition to comply with the registered amendments. Compliance is mandated by December 2025. Chemscape expects to see an increase in updated supplier/manufacturer Safety Data Sheets (SDS) and will be ready to incorporate the new SDS into our customers’ inventory.

What Changes are Required to Comply with GHS 7 & 8?

Manufacturers/Suppliers:

If you manufacture hazardous products, your Safety Data Sheets may need to be updated. Products with these classifications may require changes: Flammable Gases, Aerosols, and Gases Under Pressure.
GHS revisions have also been made to the information required on an SDS, primarily modifications to the physical and chemical properties in Section 9.
New and more specific elements have been introduced, including physical state, colour, particle characteristics, kinematic viscosity, and relative vapour density. Odour threshold and evaporation rate were removed. A SDS can still provide these elements as additional information; however, the information cannot be false or misleading.
Another amendment specifies that hazardous ingredients that are present in a mixture at concentrations above the relevant cutoff levels must be disclosed, regardless of whether the hazardous ingredient contributes to the classification of the mixture as a hazardous product or not.

Employers:

Employers need to update their education and training programs to help workers understand the WHMIS changes, especially the updated Hazard Classes and Categories:

Flammable Gases,
Aerosols,
Gases Under Pressure.

Amendments Highlights:

Physical Hazard Classifications
Flammable Gases	Subdividing Category 1 (extremely flammable gases) into two Subcategories: Subcategory 1A – includes pyrophoric gases and chemically unstable gases. Subcategory 1B – includes flammable non-pyrophoric gases and chemically stable gases with a lower flammability hazard than 1A. Addition of definitions for “chemically unstable gas” and “pyrophoric gas”. Repealing provisions in Part 3, Labelling, that would no longer apply
Flammable Aerosols	Name change to “Aerosols”. Addition of Category 3 for non-flammable aerosols. Removal of “flammable aerosol” definition. Addition/deletion of provisions in regards to labelling and classification, the most significant of which is a new provision indicating that products in the Aerosols hazard class need not be classified in any category of the Gases Under Pressure hazard class.
Oxidizing Solids	Addition of new test procedure. Expansion of classification criteria.
Combustible Dust	Addition of a second Hazard Statement: May form explosible mixture dust-air mixture.
Chemicals Under Pressure	New physical hazard class – “Chemicals Under Pressure” with pictogram, signal word, hazard statements and precautionary statements. Includes Categories 1, 2 and 3

Health Hazard Classifications
Acute toxicity	Amending and/or adding definitions. Addition to and/or correction of the classification criteria.
Carcinogenicity Germ Cell Mutagenicity Respiratory Sensitization Serious Eye Damage/Eye Irritation	Amending and/or adding definitions.
Reproductive Toxicity	Amending and/or adding definitions.
Reproductive Toxicity – Category 2	Addition to and/or correction of the classification criteria.
Skin Corrosion Skin Irritation	Change classification criteria from reference of corrosive effects “in at least one of three animals” to “in at least one animal”. Amending and/or adding definitions.
Combustible Dusts – Category 1 Organic Peroxides – Type G Specific Target Organ Toxicity – Single Exposure – Category 3	Addition to and/or correction of the classification criteria.
SDS Amendments	Schedule 1, Information Elements on Safety Data Sheets: Section 2 - Hazard Identification Section 3 - Composition/Information on Ingredients. Notable is the disclosure requirement for all hazardous ingredients which are present in a mixture above its relevant cut-off limits regardless of whether that ingredient contributes to the classification of the mixture. Section 9 – Physical and Chemical Properties New property added: Particle Characteristics Property deleted: Evaporation Rate Properties renamed: ‘Appearance’ changed to’ Physical State’ and ‘Colour’. ‘Vapour density’ renamed to ‘Relative Vapour Density’. ‘Viscosity’ renamed ‘Kinematic Viscosity’. ‘Initial Boiling Point and Boiling Range’ renamed to ‘Boiling Point or Initial Boiling Point and Boiling Range’. Section 14 – Transport Information
	Clarification of the following: Classification in the most severe hazard category/sub-category for which criteria are met. Non-allowed use for certain animal studies. Label exemptions for certain laboratory samples. Applicable exemptions for products ‘sold to an employer who has filed’ a CBI claim.
	Amendment of provisions dealing with “substances and mixtures, that when in contact with water, emit a toxic gaseous substance (Water-Activated Toxicants)”. Concerns required supplemental hazard statements where selection is “based on the toxicity of the emitted gaseous substance”.
	Amendments to Part 4, Safety Data Sheets, to better align with Part 3, Labelling, in terms of combining hazard statements and precautionary statements as well as noting that the omission of non-applicable precautionary statements for labels also apply to safety data sheets. The Part 4 amendments also clarify that the reduced information allowed on a label due to container size also applies to safety data sheets.
	Addition of the allowed use of narrower concentration ranges that still fall within prescribed ranges for disclosure of hazardous ingredients.
	Requirements for when significant new data is discovered and subsequent supply of the amended safety data sheet and/or label. The amended safety data sheet and/or label must include the changes “that result from the significant new data, rather than the new studies or data themselves”.

Please Note: This table is a summary of amendments.

How is Chemscape Preparing for the Change and How Can We Help You?

Chemscape has taken the following actions to prepare for the GHS revisions:

Proactively updated our system to align with the GHS revision 7/8 hazardous products classifications, H-statements, and P-statements.
Created a new WHMIS course (WHMIS 2023 and Beyond) to support our clients in the transition.
Notified our clients about the changes and encouraged any chemical producers to review their SDS against the updated WHMIS/HPR regulation.
Continually add new SDS to our database and reach out to manufacturers for updated SDS every 3 years at a minimum.
Prominently displays the SDS issue date on every client’s portal.
Since 2013, Chemscape has professionally and successfully authored SDS sheets to the Globally Harmonized System (GHS) standards.
Offers clients high-quality SDS authoring and labelling services to meet regulatory and product lifecycle changes.

Chemscape Authors SDS Services to Assist your with GHS Transition

Since 2013, Chemscape has authored SDS sheets for the Globally Harmonized System (GHS). We are well trained and experienced in the required elements and structure of SDS Authoring, including these recent amendments. Contact us today to learn more about our authoring services.