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305-BZF-01-IGOT © 2025, Workplace Safety & Prevention Services (WSPS)
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Q.
What do we do if some suppliers have provided an SDS as per the amended Hazardous
Products Regulations (HPR), but others have not yet, so we have a bit of both?
A.
Suppliers have until December 14, 2025, to revise their SDS and supplier labels to make them
compliant with the amended HPR.
Updated WHMIS training will need to be conducted as soon as the workplace starts receiving SDS
and labels that are in line with the amended HPR. The updated WHMIS training can cover all the
relevant changes that will affect the hazardous products found in the workplace, in anticipation
of future changes in the SDS, so that additional retraining will not be required when all SDS have
been revised to comply with the amended HPR.
Q.
Is the United States in alignment with GHS?
A.
GHS was meant for all countries to be in alignment, but in reality, each country is a bit different.
The US has a different transition period with some changes happening in 2026 and others in 2027.
In Canada, we do import a lot from the US, so our suppliers are going to have to work with
their American counterparts to ensure compliance with Canadian regulations, not just the US
regulations.
Q.
What is the obligation of suppliers outside of Canada to ensure products being used
in Canada meet our legislation requirements? What do we do if they don't meet the
requirements of the updated Hazardous Product Regulation (HPR)?
A.
The Hazardous Product Act (HPA) and HPR applies to all provinces and territories in Canada. All
suppliers of hazardous products being supplied anywhere in Canada must comply with the HPA
and HPR.
If their SDSs are not compliant, you can contact Health Canada to enforce the regulations. They
will refer the concern to the appropriate jurisdiction, and in Ontario, the MLITSD Occupational
Hygienists have been given authority to enforce the HPR.
Contact email: whmis-simdut@hc-sc.gc.ca
Q.
What do I do if there isn't a lot of information in an SDS?
A.
Contact the supplier first, to see if concerns can be addressed. If the supplier doesn't comply,
contact the Health Canada for enforcement.
Contact email: whmis-simdut@hc-sc.gc.ca
Q.
If a supplier does not indicate that the material is hazardous in an SDS, does this mean
the material is safe to use without controls?
A.
If there are concerns, confirm with the supplier that it is non hazardous, and if there are any further
concerns with the classification, contact Health Canada. If it is not hazardous, as defined in the
HPR it doesn't need an SDS.
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