Safety Data Sheet Compliance Tool

The purpose of this document is to assist suppliers with the preparation of a Safety Data Sheet (SDS) for a hazardous product by providing key information about specific regulatory requirements and best practices to address the most common SDS non-compliances identified by Health Canada.

This document is not intended to provide a comprehensive review of the requirements of the Hazardous Products Act (HPA) and the Hazardous Products Regulations (HPR), or to replace the Technical Guidance on the Requirements of the Hazardous Products Act and the Hazardous Products Regulations (the Technical Guidance). This document should be read in conjunction with the Act and the Regulations, and the Technical Guidance.

The HPA requires suppliers of hazardous products to communicate the hazards associated with their products via product labels and SDSs as a condition of sale and importation for workplace use.

SDSs provide more detailed hazard information about the product than the label. In addition to being an important resource for workplaces and workers, the SDS may also be used by first responders, such as firefighters and emergency medical services, and occupational health and safety officers to learn about the product(s), including the hazards, personal protection, and safe handling and emergency measures.

Section 1

Identification

Information Elements

  • Product Identifier
  • Other Means of Identification
  • Recommended Use and restrictions on use
  • Initial Supplier Identifier
  • Emergency Telephone Number, and any restrictions on the use of that number, if applicable

Most common non-compliances

  • The Canadian Transport Emergency Centre (CANUTEC) phone numbers are listed as the emergency telephone numbers.
  • Recommended use and restrictions on use are not disclosed.
  • Recommended use is not specific enough.
  • Data for the information element “Other means of identification” is not disclosed (such as the CAS numbers, synonyms, etc., for substances and short-form names, code names, etc., for mixtures).
  • The product identifier and the initial supplier identifier disclosed on the safety data sheet (SDS) and the label do not match.

Tips

  • Use and restrictions

    Information about the recommended use and the restrictions on use of the hazardous product must be disclosed and should not be vague.
    • General statements on recommended use are not acceptable. The recommended use of the product should be presented on the safety data sheet (SDS) as a brief description of what the product is used for or does. For example, “Product use: Flame retardant” is acceptable, while “Product use: Industrial use,” “Commercial use,” “Additive” or “Construction” are not acceptable.
    • The reason for the restriction on use should be disclosed.

  • Initial supplier identifier information

    A Canadian distributor that buys a hazardous product, relabels the hazardous product and then sells it is considered the initial supplier. Therefore, its name, address and telephone number must be disclosed on the SDS and label.
  • A Canadian importer that imports a hazardous product and resells it within Canada must disclose its own information as the initial supplier identifier, namely, its name, address and telephone number.
    • The contact information of the foreign-based supplier may be disclosed on the SDS and label as long as the Canadian importer’s information is also disclosed.
  • A Canadian importer that imports a hazardous product from a foreign supplier for use in its own workplace in Canada only is exempt from having its own information as the initial supplier identifier, as long as the name, address and telephone number of the foreign supplier are present on the SDS and label.

  • Emergency telephone number

    The Canadian Transport Emergency Centre (CANUTEC) telephone numbers must not be listed as emergency telephone number. The overall mandate of CANUTEC is to promote public safety in the transportation of dangerous goods by all modes, and CANUTEC cannot provide any information on the storage, use or handling of the product. If an alternate telephone number is available, it must be disclosed. If there is no telephone number available, the expression “Not available” or an indication to that effect must be disclosed.
  • The emergency telephone number does not have to be a 24/7 number. However, any restrictions on the use of that telephone number, if applicable, must be disclosed on the SDS.
  • Suppliers should also disclose, if applicable, a statement to contact the local poison control centre.
  • Non-Canadian telephone numbers should include the complete international dialling code.
  • If the language spoken at the emergency telephone number is neither English nor French, this should also be included on the SDS.

Section 2

Hazard identification

Information Elements

  • Classification of the hazardous product
  • Symbol(s)
  • Signal word
  • Hazard statement(s)
  • Precautionary statement(s)
  • Other hazards

Most common non-compliances

  • Hazard classifications are incomplete or missing.
  • Appropriate symbols corresponding to the disclosed classifications are missing.
  • In situations where both signal words “Danger” and “Warning” are applicable, both are disclosed on the safety data sheet (SDS).
  • Signal words are repeated multiple times on the SDS.
  • Hazard or precautionary statements are missing.
  • The forward slash is retained in hazard and precautionary statements for which a choice is to be made in order to include any relevant or appropriate information.
  • Three full periods (“…”) are retained in hazard statements and precautionary statements.
  • Hazard statements which have been combined together do not communicate the intended message of the individual statements, as required.
  • Precautionary statements which have been combined together do not communicate the intended message of the individual statements, as required.
  • The percent of unknown acute toxicity is missing for a product that is a mixture and is classified as an acute toxicant.

Tips

  • Hazardous Products Regulations (HPR) Classification

    The appropriate category or subcategory of the hazard classification must be disclosed as outlined within the HPR, or as a name that is a substantive equivalent.
  • The category of the hazard class or a description of the identified hazard must be disclosed for Physical Hazards Not Otherwise Classified and Health Hazards Not Otherwise Classified classifications.
  • Abbreviations and acronyms must not be used to disclose hazard classifications as they are not considered to be substantive equivalents.
  • Suppliers should outline the specific criteria that resulted in the hazardous product being classified within the Physical Hazards Not Otherwise Classified or Health Hazards Not Otherwise Classified classifications.
  • When a hazardous product is classified as “Physical Hazards Not Otherwise Classified” or “Health Hazards Not Otherwise Classified” or both, the classifications must be disclosed within Section 2.
  • In situations where hazard classifications are conducted under other hazard communication systems (such as the Occupational Safety and Health Administration [OHSA] Hazard Communication Standard [HCS]), the safety data sheet (SDS) should disclose that the classification was also done according to the HPR.
  • When a product is classified as an acute toxicant, the SDS must disclose the % amount of the mixture that consists of an ingredient or ingredients of unknown acute toxicity.

  • Signal Word

    The most protective signal word, i.e., “Danger,” must be used and the signal word “Warning” must be omitted in situations where both signal words are required.
  • The same signal word, “Danger” or “Warning,” must not be repeated.

  • Hazard Statement and Precautionary Statement

    Hazard and precautionary statements prescribed for appropriate hazard classes must be disclosed, and are adopted from the Globally Harmonized System (GHS) of Classification and Labelling of Chemicals, while Schedule 5 of the HPR specifies the prescribed hazard statements for hazard classes not covered by the GHS (e.g., Combustible Dusts) that must be disclosed.
  • When a forward slash or diagonal mark [/] appears in a hazard statement or a precautionary statement, a choice of relevant options for the product from among the separated text must be selected. The forward slash can be replaced with a comma and all irrelevant information should be removed from the statement.
    • For example, based on the supplier’s determination of the product, the precautionary statement P260, “Do not breathe dust/fumes/gas/vapours/spray,” may be disclosed as follows for a hazardous product that is a liquid: “Do not breathe fumes, gas, vapour or spray.” In the case of a solid that is a powder, the statement could be written as: “Do not breathe dust or fumes generated during processing.”
  • When three full periods [...] appear in a hazard statement or a precautionary statement, they indicate that not all applicable conditions are listed, and the applicable conditions must be specified.
    • For example, in the case of P264 Wash…thoroughly after handling, the “…” must be replaced by an indication of what should be washed, such as, “Wash your hands and all exposed skin thoroughly after handling.”

  • Other Hazards

    Information regarding or a description of other hazards known to the supplier that does not result in classification but may contribute to the overall hazards of the product must be disclosed within Section 2.

Section 3

Composition / information on ingredients

Information Elements

  • If the product is a material or substance
    • Chemical name
    • Common name and synonyms
    • CAS registry number and any unique identifiers
    • Chemical name of impurities, stabilizing solvents, and stabilizing additives classified
  • If the product is a mixture (for each material or substance classified in any category or subcategory of a health hazard class)
    • Chemical name
    • Common name and synonyms
    • CAS registry number and any unique identifiers
    • Concentration

Most common non-compliances

  • Unit of concentration is not provided.
  • Unit of concentration is only partially disclosed (e.g., “percentage” or “%” instead of specifying % by weight or % by volume).
  • The hazardous ingredient common name and synonyms are not disclosed.
  • The concentration of a hazardous ingredient in a mixture that is classified in a health hazard category, is not disclosed.
  • The statement to the effect that the actual concentration is withheld as a trade secret is not disclosed in situations where prescribed concentration ranges are used.
  • Prescribed concentration ranges and actual concentration ranges are both used to disclose ingredient concentrations on the safety data sheet (SDS) without clearly indicating the ingredients to which the statement that the actual concentration is being withheld as a trade secret through the use of the prescribed concentration ranges applies.
  • There is no link as to which ingredients are the subject of the claim for exemption under the Hazardous Materials Information Review Act (HMIRA).

Tips

  • Chemical name, Common Name and Synonyms

    It is not acceptable to use “not available” or “not applicable” for the chemical name of a material or substance, or the chemical name and concentration of hazardous ingredients in a mixture.
  • Common names and synonyms that may be used in the workplace to identify a substance must be included on the safety data sheet (SDS). Where the chemical identity of the ingredient is part of a claim for exemption under the Hazardous Materials Information Review Act (HMIRA), common names and synonyms are not required for that ingredient.
    • For example, methylbenzene is a synonym for toluene.
  • Ingredients in a hazardous product that is a mixture that are classified in a category or subcategory of a health hazard class and contributes to the classification of the hazardous product, must be identified in section 3. These ingredients must be consistent with the health hazard class identified in Section 2 of the SDS and the toxic health effects identified in Section 11 of the SDS.
  • If a mixture contains an ingredient classified as a Health Hazard Not Otherwise Classified (HHNOC) at a concentration of 1% or more, the chemical name and concentration or concentration range must be disclosed on the SDS.

  • Concentration

    The units used to calculate the percentage must be provided, if the concentration is expressed as a percentage.
    • For example, the unit of concentration may be identified as “% by weight” or “% by volume” or “% weight/volume”. Disclosing the unit of concentration as “percentage” or “%” is not acceptable to identify the unit of concentration.

  • Claim for exemption under the Hazardous Materials Information Review Act (HMIRA)

    A clear and accurate link between all of the applicable confidential business information and the HMIRA claim for exemption information (such as the assigned HMIRA Registry Number) must be disclosed.

    Example: Chemical Identity and Concentration

    No HMIRA claim

    Section 3: Composition / Information on Ingredients
    SubstanceCAS Number% (w/w)
    Methanol67-56-125%
    Trichloroisocyanuric Acid87-90-10.1%

    HMIRA claim filed

    Section 3: Composition / Information on Ingredients
    SubstanceCAS Number% (w/w)
    Alcohol *Proprietary *Proprietary *
    Trichloroisocyanuric Acid87-90-10.1%
    * HMIRA RN:3333 - Filing Date January 1, 2021

    HMIRA claim granted

    Section 3: Composition / Information on Ingredients
    SubstanceCAS Number% (w/w)
    Alcohol *Proprietary *Proprietary *
    Trichloroisocyanuric Acid87-90-10.1%
    * HMIRA RN:3333 - Date granted January 3, 2022

Section 4

First-aid measures

Information Elements

  • Description of necessary first-aid measures, by routes of exposure (inhalation, ingestion, skin and eye contact)
  • Most important acute or delayed symptoms and effects
  • Indication of immediate medical attention and special treatment needed, if necessary

Most common non-compliances

  • The information on the most important symptoms and effects (acute or delayed) is missing or there is only reference to Section 11 (e.g. “See Section 11”).
  • There is only partial disclosure of the most important symptoms and effects, whether acute or delayed (i.e. either missing information on the symptoms, or on the effects).
  • The indication of immediate medical attention and special treatment does not provide the adequate level of response needed for the hazard classifications specified in Section 2.
  • Information on seeking immediate medical attention is missing, or is indicated as “no additional information available,” which is not appropriate based on the hazard classification of the product.

Tips

  • Necessary First-Aid Measures

    The recommended first-aid responses provided must be consistent with the classified hazards of the product and the description of the various toxic health effects provided respectively in Section 2 and Section 11 of the safety data sheet (SDS).

  • Most Important Symptoms and Effects

    The most important symptoms and effects (acute or delayed) for all classified health hazards must be provided. Simply repeating hazard statements or referring the reader to Section 11 of the SDS is not acceptable.
  • Information on clinical testing and medical monitoring for delayed effects that would be useful for health care professionals should be disclosed.

  • Immediate Medical Attention and Special Treatment

    Information describing the immediate medical attention and special treatment that may be necessary (e.g. Known antidotes and any contraindications) as a result of exposure to the product must be disclosed, if necessary.
  • The indication of immediate medical attention and special treatment must reflect the appropriate level of response when assessed with the information disclosed in Section 2.
    • For example, if the hazard statement in Section 2 states “Immediately call a Poison Centre or doctor,” then the disclosure of “Call a Poison Centre if you feel unwell” in Section 4 is not acceptable.

Section 5

Firefighting measures

Information Elements

  • Suitable and unsuitable extinguishing media
  • Specific hazards arising from the hazardous product, such as the nature of any hazardous combustion products
  • Special protective equipment and precautions for fire-fighters

Most common non-compliances

  • The indication of special protective equipment for firefighters does not sufficiently identify the type of protection needed.
  • Suitable and unsuitable extinguishing media are not disclosed.
  • Suitable extinguishing media is disclosed but unsuitable extinguishing media is not disclosed.
  • Thermal decomposition products are disclosed as combustion products.
  • Combustion products are not disclosed.
  • Information on specific hazards arising from the hazardous product, such as the nature of any hazardous combustion product, is not disclosed for products with fire hazard classifications such as combustible dusts, organic peroxides, or self-heating substances and mixtures.

Tips

  • Extinguishing Media

    The specific extinguishing media that is suitable to use in fire-fighting measures must be disclosed.
    • For example, specify carbon dioxide, dry chemical powder or appropriate foam.
  • The specific extinguishing media that would not be appropriate to use (unsuitable) in fire-fighting measures must be disclosed.
    • For example, if a specific extinguishing media may cause chemical or physical reactions resulting in an additional potential hazard, this information must be included on the safety data sheet (SDS).
    • For example, if the product reacts with water and other common extinguishants, this information must be included on the SDS such as “Water is not effective for extinguishing a fire. It may not cool product below its flash point.”
  • If there are no known unsuitable extinguishing media, “Not applicable” or an indication to that effect must be disclosed.

  • Specific Hazards

    Information on specific hazards arising from the hazardous product must be disclosed.
    • For example: (a) fire hazards of the product, (b) reactivity hazards that relate to fire and explosion potential, and/or (c) any additional hazards created by fire conditions.
    • For example, the statement may include the following information: Flammable liquid and vapour. Can ignite at room temperature. Releases vapour that can form an explosive mixture with air. Can accumulate static charge by flow, splashing or agitation. Forms corrosive chemicals on contact with water. May accumulate in hazardous amounts in low-lying areas, especially inside confined spaces, resulting in a fire and/or health hazard.
  • The hazards of expected combustion products and whether increased temperatures in a fire situation can increase the hazards of the product must be disclosed.
    • For example, a product that does not release toxic vapours at room temperature may release toxic vapours in a fire situation. Evacuate the area. Fight fire from a safe distance or a protected location. Approach fire from upwind to avoid hazardous vapours or gases.

  • Special Protective Equipment for Fire-Fighters

    Special protective equipment for fire fighters must be disclosed, as applicable, and must be consistent with the product’s classification.

  • Precautions for Fire-Fighters

    Important precautions that firefighters should take considering the product’s hazards and any other specific hazards arising from the product in a fire situation must be disclosed.

Section 6

Accidental release measures

Information Elements

  • Personal precautions
  • Protective equipment
  • Emergency procedures
  • Methods and materials for containment and cleaning up

Most common non-compliances

  • Information for flammable products does not disclose containment methods and emergency procedures such as removal of ignition sources, use of non-sparking tools, applicable ventilation conditions, etc.
  • Personal precautions, protective equipment and emergency procedures reference an inappropriate physical form, such as “fumes/mists/vapours” when fumes cannot occur.
  • Information on methods and materials for containment and cleaning does not disclose adequate detail.
  • The methods and materials for containment are not disclosed.
  • Information on personal precautions, protective equipment and emergency procedures is missing or only references another section of the safety data sheet (SDS).

Tips

  • Personal Precautions and Protective Equipment

    All hazards associated with the product in the event of an accidental spill or leak should be disclosed.
  • Precautions to protect non-emergency personnel and emergency responders must also be disclosed.
    • For example, “Evacuate the area immediately. Isolate the hazard area. Keep out unnecessary and unprotected personnel”; “Vapours travel far and are heavier than air”; “Flashback ignition can occur.”

  • Emergency Procedures

    Emergency procedures (e.g., evacuate area, isolate hazard area, keep away unprotected personnel, consult with experts) must be provided.

  • Containment and Clean Up

    Advice on inappropriate containment or clean-up techniques that should be avoided in light of the product’s physical or chemical properties should be disclosed.
  • If the product is classified as flammable, the containment methods and emergency procedures must include measures such as removal of ignition sources, use of non-sparking tools, applicable ventilation conditions, etc., as applicable.
  • In the event of an accidental release, necessary protective equipment (e.g., gloves, safety goggles) specific to the product that should be used to prevent the possibility of the hazardous product from coming into contact with skin, eyes, respiratory system and clothing must be disclosed.
  • General advice on how to clean up the product in case of a spill, including the need for containment and the use of absorbents or neutralizing chemicals, and, if appropriate, advice for small and large spills must be provided.
  • Recommended methods of containment (e.g., capping, covering drains), neutralization and decontamination and the recommended materials and equipment for containment must be disclosed.
  • Information on inappropriate clean-up procedures based on the product’s physical and/or chemical properties should be disclosed.
  • Recommendations regarding methods and materials for containment and cleaning up must be appropriate for the physical form of the product that is the subject of an accidental release.
    • For example, only recommend sweeping for products that are solids (including the use of an absorbent on a liquid product), not for liquids or gases.
  • Information on inappropriate containment measures based on the product’s physical and/or chemical properties should be disclosed.
  • Recommended clean-up procedures (e.g., vacuuming, wiping) and the appropriate materials (e.g., absorbent material) and equipment (e.g., non-sparking tools) to be used after accidental release of the product must be disclosed.

Section 7

Handling and storage

Information Elements

  • Precautions for safe handling
  • Conditions for safe storage, including any incompatibilities

Most common non-compliances

  • The precautions for safe handling do not disclose adequate detail.
  • The conditions for safe storage do not disclose the incompatibilities, or do not specify various requirements such as the need:
    • to keep containers tightly closed;
    • for a well-ventilated storage area; and/or
    • to protect the product from heat or sunlight.

Tips

  • General

    Information must be provided in a manner that is consistent with the precautionary statements presented in Section 2 and describes all storage and handling requirements relevant to the classification of the hazardous product.
    • For example, if the following classification is listed in Section 2:
    • Corrosive
      • Serious eye damage, category 1
      • Skin corrosion, category 1A
      • Corrosive to metals, category 1
    • Flammable
      • Flammable liquid, category 1
    • Then Section 7 must include information regarding safe handling and safe storage of the hazardous product (including incompatibilities) for a corrosive and flammable product.
  • Address each of the physical and chemical properties of the hazardous product identified in section 9 of the safety data sheet (SDS) that may affect the safe handling or safe storage of the product.
    • For example, if the pH of a liquid product in Section 9 is listed as 1.1, then Section 7 must include a pertinent warning (e.g., avoid skin and eye contact).

  • Precautions for safe handling

    Precautions for safe handling must be disclosed in adequate detail.
    • For example, detailed information such as the need for adequate ventilation, protective equipment, keeping away from ignition sources and washing hands thoroughly must be disclosed, where applicable.

  • Conditions for safe storage

    Conditions for safe storage, including any incompatibilities, must be sufficiently detailed to effectively provide safe storage of the product in light of its classification in a hazard class and its physical and chemical properties.
    • For example, “Keep container closed. Do not store in brass, bronze, copper or copper alloys.”

Section 8

Exposure controls / Personal protection

Information Elements

  • Control parameters, including occupational exposure limit values or biological limit values and the source of those values
  • Appropriate engineering controls
  • Individual protection measures, such as personal protective equipment

Most common non-compliances

  • Personal protective equipment information is not prescriptive or does not provide adequate detail, such as disclosing “use appropriate respiratory measures.”
  • Engineering controls are not appropriately identified based on the product hazard classification.
  • Occupational exposure limit values are incorrectly reported, not present or missing the source of the values.

Tips

  • Control Parameters

    The occupational exposure limit values or biological limit values (as applicable) must be disclosed, including the source of these values.
    • Suppliers should note that occupational exposure limit values may vary between different jurisdictions in Canada.
  • The recommended exposure control measures should be compatible with each other.
    • For example, do not recommend a half-mask respirator when eye protection is also required. In this case, recommend a full-face piece respirator or alternate exposure control measures that provide the same level of protection.
    • For example, a particulate filter will not protect against organic vapours. In this case, where available, specify the type of filter needed.

  • Personal Protective Equipment

    The personal protective equipment identified in section 8 must appropriately address the risk associated with the physical and chemical properties identified in section 9 of the safety data sheet (SDS).
    • For example, if the pH in Section 9 is listed as 1.1, then Section 8 should include a pertinent warning (e.g., wear chemical-resistant protective clothing; wear safety goggles).
  • Materials (e.g., flame resistant, thermal insulation) used to construct protective clothing for products with a thermal hazard should be identified.

Section 9

Physical and chemical properties

Information Elements

  • Appearance, such as physical state and colour
  • Odour
  • Odour threshold
  • pH
  • Melting point and freezing point
  • Initial boiling point and boiling range
  • Flash point
  • Evaporation rate
  • Flammability, in the case of solids and gases
  • Upper and lower flammability or explosive limits
  • Vapour pressure
  • Vapour density
  • Relative density
  • Solubility
  • Partition coefficient — n-octanol/water
  • Auto-ignition temperature
  • Decomposition temperature
  • Viscosity

Most common non-compliances

  • Incorrect disclosure of “not available” vs “not applicable” for individual physical and chemical properties.
  • Odour descriptors do not provide sufficient information on the quality and intensity of the odour, such as disclosing only “mild” or “strong”.
  • Units for the physical and chemical properties are disclosed incorrectly, such as disclosing the melting point and freezing point in units other than degrees Celsius or Fahrenheit.
  • pH is disclosed using qualitative descriptors (such as “slightly basic”).
  • The physical state or form disclosed is not acceptable for the product type, such as a powder to be mixed with water cannot be disclosed as a liquid for its physical state.

Tips

  • Physical and Chemical Properties

    The appropriate unit of measure must be disclosed.
  • The reference conditions (e.g., temperature, pressure) to which a property is measured against must be disclosed, where appropriate.
  • pH must be disclosed as a numerical value.

  • General

    The table below provides guidelines on the applicability of the information elements to hazardous products in various states. This should be applied only as general guidance. The applicability may differ based on specific properties of the hazardous product. Information elements identified as “Applicable” must be disclosed with the appropriate information or if the information is not available, an indication to the effect must be disclosed.

    Specific Information ElementGasesLiquidsSolids
    9(a)appearance, such as physical state and colourApplicableApplicableApplicable
    9(b)odourApplicableApplicableApplicable
    9(c)odour thresholdApplicableApplicableApplicable
    9(d)pHNot applicableApplicableNot applicable
    9(e)melting point and freezing pointNot applicableApplicableApplicable
    9(f)initial boiling point and boiling rangeNot applicableApplicableApplicable
    9(g)flash pointApplicableApplicableApplicable
    9(h)evaporation rateNot applicableApplicableNot applicable / Applicable*
    9(i)flammability, in the case of solids and gasesApplicableNot applicableApplicable
    9(j)upper and lower flammability or explosive limitsApplicableApplicableApplicable
    9(k)vapour pressureNot applicableApplicableApplicable
    9(l)vapour densityApplicableApplicableNot applicable
    9(m)relative densityApplicableApplicableApplicable
    9(n)solubilityApplicableApplicableApplicable
    9(o)partition coefficient – n-octanol/waterNot applicableApplicableApplicable
    9(p)auto-ignition temperatureApplicableApplicableNot applicable / Applicable*
    9(q)decomposition temperature ApplicableApplicableApplicable
    9(r)viscosity Not applicableApplicableNot applicable / Applicable*
    * The information element may be applicable or not applicable based on the properties of the specific hazardous product.

Section 10

Stability and reactivity

Information Elements

  • Reactivity;
  • Chemical stability;
  • Possibility of hazardous reactions;
  • Conditions to avoid, including static discharge, shock or vibration;
  • Incompatible materials
  • Hazardous decomposition products

Most common non-compliances

  • Combustion products or thermal decomposition products are disclosed as hazardous decomposition products.
  • Information on reactivity is not disclosed.
  • Information on reactivity is disclosed as “not available” when data on the product based on its classification is available.
  • For flammable products, information on conditions to avoid, such as heat, spark or ignition sources, is not disclosed.

Tips

  • Reactivity

    Reactivity hazards of the product under normal and anticipated use, handling and storage conditions must be disclosed and the specific test(s) or observational data used to identify those hazards should be disclosed.
  • Classifiable reactivity hazards, and information on other important reactivity hazards that do not result in classification should be disclosed.
  • Information regarding the nature of the hazardous product (e.g., organic peroxide, oxidizer, self heating) and its ability and conditions under which it may undergo a hazardous chemical change should be disclosed.

  • Chemical stability

    The chemical stability of the product should be disclosed under normal ambient conditions and anticipated use, handling and storage conditions of temperature and pressure.
    • Chemical stability means that the product remains unchanged under the following conditions:
      • Normal ambient temperature and pressure; and
      • Temperature and pressure conditions while in storage or when being used and handled.
  • Inhibitors and stabilizers that are used or may be used to maintain stability should be disclosed.
  • Safety issues associated with changes in the physical appearance of the product should be disclosed.

  • Possibility of hazardous reactions

    Information on the reactions (e.g., polymerization, decomposition) that have been reported or are expected to occur under specified conditions (e.g., acidic conditions or exposure to sunlight) under normal conditions of use, handling or storage, and the consequence(s) of the reaction must be disclosed.
    • For example: Decomposes in the presence of acidic conditions (low pH). Releases a large amount of heat.

  • Conditions to avoid

    Information on conditions to avoid, such as temperature, contact with moisture or air, and exposure to sunlight, including the applicable units of measure, must be disclosed.
    • For example:
      • “Avoid heat, sparks, ignition sources” or “avoid extremely high temperatures, open flame” if the product is flammable.
      • “Avoid storage with strong acids” or “incompatible materials” if the product is a base.
      • “Avoid water and moisture” if the product may react with the water and release a toxic gas.
      • “Keep away from air or oxygen.”
  • The identified conditions to avoid must be consistent with the product’s physical and/or chemical properties.

  • Incompatible materials

    Classes of chemicals (e.g., acids, fluorides, chlorides) or specific substances that could react to produce a hazardous situation should be disclosed.
  • Products that are corrosive to metals, the degree of corrosivity and the affected metals should be disclosed.
    • For example, carbon steel reacts explosively with strong oxidizing agents (e.g., perchloric acid), halogens (e.g., chlorine) and reducing agents (e.g., hydroquinone).

Section 11

Toxicological information

Information Elements

  • Information on the likely routes of exposure (inhalation, ingestion, skin and eye contact)
  • Symptoms related to the physical, chemical and toxicological characteristics;
  • Delayed and immediate effects, and chronic effects from short-term and long-term exposure
  • Numerical measures of toxicity, including ATEs

Most common non-compliances

  • Routes of exposure are missing.
  • Numerical measures of toxicity (the acute toxicity estimate, LD50 / LC50 values etc.) are missing, when available.
  • Information on the symptoms related to the physical, chemical and toxicological characteristics, is not disclosed on the ingredients when information on the mixture as a whole is not available.
  • Hazard statements are used to identify the symptoms related to the physical, chemical and toxicological characteristics.
  • Symptoms are not specified for all classifications, or are reported for some and not for others.
  • Information on the delayed or immediate effects after exposure to the product is not listed.
  • Information on chronic effects is not disclosed.
  • The Acute Toxicity Estimate (ATE) is not disclosed.

Tips

  • Toxicological Information

    Relevant human (case reports and/or results of population-based studies) and animal (test or study results) evidence should be disclosed.
  • In vitro data for accepted tests (e.g., skin corrosion tests, mutagenicity tests) should be disclosed.
  • Information on the toxicological properties of the mixture must be disclosed, if available. Otherwise, information on the toxicological properties of the hazardous ingredients, with an indication as to which ingredient(s) the provided information applies must be disclosed.
  • Professional judgment should be used to determine the extent and nature of health hazard disclosure, particularly where the data are extensive, conflicting or contradictory.

  • Likely routes of exposure

    Information on the likely routes of exposure (ingestion, inhalation or skin and eye contact) must be presented.

  • Symptoms

    The symptoms related to the physical, chemical and toxicological characteristics of the substance, mixture or product must be disclosed.
    • They should be disclosed in sequential order, beginning with the first symptoms occurring at low exposures and progressing through to the consequences of severe exposure.

  • Effects

    Information on both the delayed and immediate effects after both short-term and long-term exposure must be disclosed.

  • Numerical Measures of Toxicity

    The numerical measures of toxicity that are available must be disclosed on the safety data sheet (SDS).
    • For example, the acute toxicity estimate of the hazardous product.
  • The acute toxicity estimate (ATE) for a mixture must be disclosed, indicating the specific route of exposure to which the estimate was calculated (oral, dermal, inhalation).

Section 12

Ecological information

Information Elements

  • Ecotoxicity (aquatic and terrestrial, if available)
  • Persistence and degradability
  • Bioaccumulative potential
  • Mobility in soil
  • Other adverse effects

Most common non-compliances

  • The heading is not verbatim as per column 1 of Schedule 1 of the Hazardous Products Regulations (HPR).
  • Information disclosed in this section is false, misleading or likely to create an erroneous impression.

Tips

  • General

    The section number and heading must be disclosed; however, the content of the specific information elements in this section is optional.
  • Information disclosed in this section must not be false, misleading or likely to create an erroneous impression.

Section 13

Disposal considerations

Information Elements

  • Information on safe handling for disposal and methods of disposal, including any contaminated packaging

Most common non-compliances

  • The heading is not verbatim as per column 1 of Schedule 1 of the Hazardous Products Regulations (HPR).
  • Information disclosed in this section is false, misleading or likely to create an erroneous impression.

Tips

  • General

    The section number and heading must be disclosed; however, the content of the specific information elements in this section is optional.
  • Information disclosed in this section must not be false, misleading or likely to create an erroneous impression.

Section 14

Transport information

Information Elements

  • UN number
  • United Nations proper shipping name as provided for in the United Nations Model Regulations
  • Transport hazard class as provided in the United Nations Model Regulations
  • Packing group as provided in the United Nations Model Regulations
  • Environmental hazards according to the International Maritime Dangerous Goods Code and the United Nations Model Regulations
  • Transport in bulk (according to Annex II of the International Convention for the Prevention of Pollution From Ships, 1973, as modified by the Protocol of 1978 (MARPOL 73/78), and the International Code for the Construction and Equipment of Ships carrying Dangerous Chemicals in Bulk (IBC Code))
  • Special precautions in connection with transport or conveyance either within or outside the premises

Most common non-compliances

  • The heading is not verbatim as per column 1 of Schedule 1 of the Hazardous Products Regulations (HPR).
  • Information disclosed in this section is false, misleading or likely to create an erroneous impression.

Tips

  • General

    The section number and heading must be disclosed; however, the content of the specific information elements in this section is optional.
  • Information disclosed in this section must not be false, misleading or likely to create an erroneous impression.

Section 15

Regulatory information

Information Elements

  • Safety, health and environmental regulations, made within or outside Canada, that apply to the product in question

Most common non-compliances

  • The heading is not verbatim as per column 1 of Schedule 1 of the Hazardous Products Regulations (HPR).
  • Information disclosed in this section is false, misleading or likely to create an erroneous impression.

Tips

  • General

    The section number and heading must be disclosed; however, the content of the specific information elements in this section is optional.
  • Information disclosed in this section must not be false, misleading or likely to create an erroneous impression.

Section 16

Other information

Information Elements

  • Date of latest revision

Most common non-compliances

  • The revision date is located in the header or footer of the safety data sheet (SDS), but not in the section “Other information”.

Tips

  • Date of latest revision

    The date of the latest revision of the safety data sheet (SDS) must appear in Section 16 of the SDS.

  • Other Information

    While the Hazardous Products Regulations (HPR) does not set out a mandatory period for an SDS to be revised, suppliers should ensure that the accuracy of the information is validated on an ongoing basis to ensure the SDS is accurate at the time of sale or import as per the requirement of the Hazardous Products Act (HPA).
  • Some jurisdictions may have a requirement where suppliers may need to provide a current (and possibly revised) SDS to employers who are required by provincial and territorial occupational health and safety legislation to obtain a current SDS within a specific time frame that does not involve the sale of a hazardous product.
  • Acronyms and abbreviations should be explained in Section 16 if they are used in any section of the SDS, with the exception of the classification disclosed in Section 2 where no abbreviation is accepted.

General Tips

  • The correct number must precede each of the 16 standardized headings. The 16 standardized headings must be presented verbatim in the order set out in column 1 of Schedule 1 of the Hazardous Products Regulations (HPR).
    • For example, for Section 2, the item must be “2” and must precede the heading “Hazard identification” listed in Column 1 of Schedule 1 of the HPR. It must therefore appear as “2 Hazard identification.”
  • Biohazardous Infectious Materials (BIM) safety data sheets (SDSs) must include both the 16 items set out in Schedule 1 and the 9 items set out in Schedule 2 of the HPR.
  • The product identifier and initial supplier identifier presented on the SDS and the label of the product must be identical.
  • Information presented within each section must be consistent with information presented in all other sections of the SDS.
    • For example, Section 6 specific information elements should be consistent with the hazards identified in Section 2; Section 11 should address the applicable hazard classifications disclosed in Section 2.
  • If specific information does not apply to the hazardous product based on available data, the statement “Not applicable” or an indication to that effect must be clearly stated.
    • For example, for gases, relative density must be disclosed as not applicable, or an indication to that effect must be stated.
  • If specific Information cannot be included on the SDS because no data is available, the statement “Not available” or an indication to that effect must be clearly stated.
    • For example, if solubility is not available for a liquid, it must be disclosed as not available or an indication to that effect must be stated.
  • The information on the SDS must be available in both English and French, and must be presented as a single bilingual document or two separate unilingual documents.
  • The required information must not be false, misleading or likely to create an erroneous impression about the hazardous product.
  • If significant new data (SND) becomes available within 90 days prior to sale, the supplier must provide at the time of sale during this period either:
    • An updated SDS with the SND included; or
    • The current SDS without the SND, and provide in writing the SND and the date that it became available.
  • The supplier must keep the SDS for six years after the end of the year to which it relates.
  • References to the Hazardous Materials Information Review Commission (HMIRC) must be changed to Hazardous Materials Information Review Act (HMIRA).
  • The transition periods to fully comply with the Hazardous Products Act (HPA) and the HPR is complete. Suppliers must ensure that the labels and SDSs of hazardous products disclose the required information specified under the current version of the HPA and HPR.
    • For example, section 2 of the SDS must disclose the HPR classifications and pictograms, not the previous Controlled Product Regulations classification and pictograms.

Note: The “Tips” sections include information on the regulatory requirements that suppliers must comply with, which is denoted by the usage of the term “must.” The “Tips” sections also include best practices that are recommended to be followed, which are denoted by the usage of the term “should.”