WHMIS Updates & GHS Revision Compliance | Chemscape Safety Technologies Inc.

Summary of GHS Revisions

7 years ago, Canada adopted the 5th revision of the GHS Purple Book. In this latest revision, Health Canada has now aligned Canada’s Hazardous Products Act with the 7th and 8th revision of the GHS Purple Book.

Implementation timeline

Businesses will have three years to transition to comply with the registered amendments. Compliance is expected by December 2025. Chemscape expects to see an increase in updated supplier/manufacturer SDSs and will be ready to make the necessary changes for our customers.

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 certain classifications may have classification changes: Flammable Gases, Aerosols, and Gases Under Pressure.

• Revisions also have been made to the information elements required on SDSs, notably the physical and chemical properties in Section 9.

• Specific elements have been introduced, including physical state, colour, particle characteristics, kinematic viscosity, and relative vapour density. Elements such as odour threshold and evaporation rate were removed. A SDS can still list these elements as additional information, but it cannot be false or misleading.

• Another amendment specifies that all 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 WHMIS and training programs to help workers learn the new WHMIS updates, especially the updated Hazard Classes and Categories - Flammable Gases, Aerosols, Gases Under Pressure.

Transition Period

Suppliers have until December 14, 2025, to bring their SDSs and labels into compliance with the amended regulations.

During this three-year transition period, suppliers can choose to comply with either the former HPR or the amended HPR, but not both. It’s important to note that the hazard classification, SDS, and label of a hazardous product must be fully compliant with the version of the regulation chosen.

This requirement means that for a product to be compliant with the amended WHMIS, both the SDS and the label must meet the requirements of the amended WHMIS.

Consult Your Local Authority

Employer obligations for hazardous products are set out in federal, provincial, and territorial occupational health and safety legislation. More information can be found at WHMIS.org.

Amendments Highlights:

Physical Hazard Classifications

Description

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

Physical Hazard Classifications

Description

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

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’

Clarification of the following:

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

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.

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”

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”

How is Chemscape preparing for the change and how can we help you?

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.

Continues to reach out to manufacturers for any updated SDS on our client’s behalf on a 3-year basis at least.

Prominently displays the SDS date issue so that clients can work with their supply chain to ensure compliant SDS.

Offers clients high-quality SDS authoring and labelling services to meet regulatory and product lifecycle changes.

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

Is the Personal Protective Equipment Recommended on the SDS Enough?

CHAMP

SDS Management

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Product Stewardship Consulting

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Chemical Subsitutions

Oil & Gas

Chemicals

Manufacturing

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SDS Fundamentals

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WHMIS Resources

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Chemical Management Essentials

Health and Safety Meeting Content

WHMIS Updates announced with GHS revision 7 & 8

Summary of GHS Revisions

Implementation timeline

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

Transition Period

Consult Your Local Authority

Amendments Highlights:

How is Chemscape preparing for the change and how can we help you?

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