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Q.
What do you do if suppliers don't send updated SDS to you by the end of the year?
A.
The requirement is for the supplier to provide the SDS when the product is sold. If they don't you
can contact Health Canada for enforcement. As a reminder, it is the employer's responsibility to
ensure they have the SDS. Employers should first reach out to the supplier to get the SDS, prior to
contacting Health Canada for enforcement.
Q.
Suppliers are supposed to notify the employer of the changes, what does this look like?
1. A letter that goes along with the updated SDS, explaining the main changes?
2. Is electronic notification sufficient, paper copies are not necessary?
A.
The supplier has 180 days to revise the labels and 90 days to revise the SDS when significant
changes are made to the product. The supplier needs to attach a cover page with the updated
SDS, explaining the changes.
Paper copies are always acceptable. However, an electronic copy may be sent as an attachment, in
an email. Simply sending a link to a website is not acceptable.
Q.
Do the changes to the HPR comply with GHS, are other countries doing the same?
A.
The HPR is based on the GHS, however each country has some differences in what they choose
to implement. For example, the United States and Canada have decided to implement different
elements of the GHS.
Q.
Pregnant women working with Chemicals – are there any provisions for safe use of
chemicals for them specifically?
A.
It is the supplier's responsibility to identify health and safety hazards of the hazardous product,
including potential harm for pregnant women. These concerns would be addressed in the SDS
regarding reproductive hazards.
Q.
Do all workers at my workplace require WHMIS training?
A.
As per Ontario Regulation 860, WHMIS training is required for workers who work with or who may
be exposed in the course of their work to a hazardous product.
Q.
Do I have to do WHMIS training every year?
A.
There is no specific requirement for annual WHMIS refresher training in the WHMIS Regulation,
however this is a best practice. Training must be updated and implemented when work conditions
change that may affect the health or safety of a worker, such as introducing new products, new
information about safe handling, storage and use of chemicals.
See next question/answer for what is required annually.
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