Supplier (Importer | Distributor)
Under WHMIS 2015, suppliers will continue to:
- Ensure the appropriate classification of hazardous products (formerly Controlled Products)
- Provide labels for hazardous products
- Provide SDSs (formerly MSDSs) for hazardous products
WHMIS 2015 has many hazard classes. Most classes have criteria similar to those for WHMIS 1988 classes and divisions. Some new classes have been added, for example, Aspiration Hazard. The WHMIS 2015 hazard classes have subdivisions (called "categories" or "types") that reflect varying degrees of hazard. Note that there is specific guidance for classifying mixtures for health hazards.
The hazard classifications of a product are based on comparison of all available hazard data to the WHMIS 2015 criteria. This data must have been generated by test methods that are scientifically sound and valid.
Requirements for supplier labels include a product and supplier identifier in addition to standardized pictograms, signal words, hazard statements, and precautionary statements. Most hazard classes and categories will have a prescribed pictogram, signal word, hazard statement and precautionary statements. Supplier labels must be provided in both English and French.
The label must be accurate at the time of sale or import, for each sale or import. There is an exemption period for updating labels (and SDSs) when significant new data becomes available. The significant new data must be provided separately until the update is complete.
SDSs follow a standard 16-section format with specified headings. There is some new information required, for example, inclusion of the WHMIS 2015 classification, and label elements in Section 2. The SDS must be provided in both English and French.
The SDSs must be accurate at the time of sale or import, for each sale or import. It is a requirement to update the SDS when significant new information becomes available. The significant new data must be provided separately until the update is complete.
Trade secret rules continue to apply.
Suppliers (or employers) who apply to withhold confidential business information (CBI) must continue to meet label and SDS requirements. These requirements include the details of any safety precautions workers need to take when using the product and the first aid treatment required in the case of exposure. This approach balances the worker’s right to know with industry’s right to protect CBI.