WHMIS and the Globally Harmonized System of Classification and Labelling of Chemicals (GHS)

The framework for a globally harmonized system (GHS) for classification and labeling of chemicals (labels and safety data sheets) is now in place, after years of international consultations, as led by the United Nations. Canada, like many other countries, is on pace to implement GHS elements in several regulatory areas, by 2008. Among the regulatory areas affected are WHMIS, TDG (to a lesser extent), pesticides and consumer chemicals.

(Ed. -- This document was produced by Hazard Alert Training Inc. in June 2007 as a service to its customers. The information herein summarizes the GHS and how it relates to potential, upcoming regulatory changes and compliance, such as with WHMIS. The information herein should be used for informational and background purposes only. As other news or developments may have occurred related to GHS and the regulatory arena since the time this document was produced, all or part of the information contained herein may no longer be applicable.)

In general, GHS is wider in scope than WHMIS. It will apply to chemicals used in the workplace, to consumer chemicals and to chemicals during transport. It will also apply to chemicals that are currently exempt from WHMIS, e.g., pesticides and pharmaceuticals.

According to Health Canada’s WHMIS Division, WHMIS requirements established under the Hazardous Products Act and associated Controlled Products Regulations will need to be amended – to some degree -- to incorporate the new harmonized (GHS) criteria for hazard classification and requirements for hazard communication; i.e., for MSDSs and labels.

Health Canada is the lead agency responsible for WHMIS in Canada, as the administrator of the Hazardous Products Act (HPA) and the Controlled Products Regulations (CPR). The department's Product Safety Programme (PSP) includes the WHMIS Division. The WHMIS Division is the national WHMIS Coordinator, and includes a national WHMIS secretariat. Visit the WHMIS division website at: www.hc-sc.gc.ca/whmis.

Note that the GHS is not meant to replace hazard communications systems in sectors or areas that already meet or exceed the GHS criteria and requirements. Thus, some regulatory areas, such as TDG, are not impacted as much by the GHS initiative.

Summary of GHS, as related to WHMIS

• The GHS includes changes to existing classification criteria. Products currently classified under WHMIS may need to be re-classified under GHS.
• All types of chemicals will be covered (including dilute solutions and mixtures) and will be based on intrinsic hazards of chemicals.
• Pharmaceuticals, food additives and cosmetics are addressed by GHS, but only where workers are exposed and where such items are in transport.

About GHS and WHMIS Labels

• Under GHS, the classification of a chemical will determine which standardized hazard statements and pictograms (symbols) must appear on the label. In addition, there are suggested precautionary statements for use on the labels (these statements have not been standardized yet).
• The requirements for GHS labels are different than what is required by WHMIS and WHMIS labels will need to be changed to meet the GHS system requirements.

Key GHS and WHMIS Label Requirements

About GHS and WHMIS Safety Data Sheets

• Safety Data Sheets under GHS will need to have 16 sections and include more information in some sections than is required under WHMIS. (WHMIS currently requires only 9 sections, but many Canadian employers/suppliers have already moved to the 16-heading format, which has been accepted by Health Canada for years.)
• Under GHS, the classification and symbols must appear on the safety data sheet. The order of information on a GHS SDS has been set and is different from what is currently required under WHMIS. (See Label elements below.)

The 16 elements in the GHS format for Safety Data Sheets are:

• Substance & Supplier identification
• Hazard Identification
• Composition/ingredients
• First aid
• Accidental release measures
• Fire-fighting measures
• Handling and storage
• Exposure controls/personal protection
• Physical/chemical properties
• Stability/reactivity
• Toxicological information
• Ecological information
• Disposal
• Transport information
• Regulatory information
• Other

GHS Incomplete in Some Aspects

Note that some aspects of GHS are not yet finalized, and the final changes to WHMIS or other regulatory schemes will not likely occur until 2008. It is generally anticipated that further review of GHS elements and regulatory consultation processes will occur in 2006 and 2007, prior to any implementation of GHS by 2008.

Classification of Compressed Gases

Under WHMIS, the Controlled Products Regulations cover compressed gases. Under GHS, there would be some differences. This issue was under review by Health Canada in 2005. The differences between the two classification systems are as follows:

• Under WHMIS: compressed gas, dissolved gas, gas liquefied by compression, and gas liquefied by refrigeration are in one hazard class referred to as “Compressed Gas”.
• Under the GHS, gases which are contained in a receptacle at a pressure are referred to as “Gases Under Pressure” and subdivided into 4 separate categories: compressed gas, liquefied gas, refrigerated liquefied gas, and dissolved gas.
• Health Canada consulted with stakeholder groups in 2005 and is recommending the GHS approach to compressed gases be adopted under WHMIS.

Categories for Skin Corrosion/Irritation in WHMIS & GHS

• Under WHMIS, the Controlled Products Regulations include one category for skin irritation and one for corrosion.
• Under GHS, there are two categories for skin irritation and three for corrosion.
• Health Canada consulted with stakeholder groups in 2005 and is recommending the GHS approach be adopted under WHMIS.
• The CPR and GHS use similar endpoints and cut-off values to classify substances and tested mixtures for skin irritation and corrosion.

WHMIS and GHS Compared

• Both WHMIS and the GHS require a product identifier, supplier identifier, hazard symbols, hazard statement/risk phrases, and precautionary first aid measures.
• The GHS has standardized hazard statements, whereas there are none identified under the current WHMIS standards.
• WHMIS labels must identify that there is an MSDS available for the product. This is not present in the GHS.
• GHS labels require a list a hazardous ingredients as well as a standardized signal word. These two elements are not required on current WHMIS labels.
• WHMIS hazard symbols and GHS hazard symbols are similar, but differ in color and shape.
• There are no chemicals or chemical products exempt from the GHS. A number of products are currently exempt under WHMIS.

Future Watch for GHS

The implementation of GHS elements within the WHMIS regulatory scheme will create a need to review and update/create new Safety Data Sheets. This will be important work for chemical producers/suppliers. Chemical users (i.e., employers/workers using chemicals in the workplace) will need to work with and obtain new Safety Data Sheets as the new GHS elements are implemented.

Training for workers (and employers/suppliers/producers) will be a major issue as GHS moves forward. Workers will need to be trained to understand:

• new hazard classes introduced with GHS
• new format for safety data sheets
• the type/amount of information contained on new labels and safety data sheets

For more information on GHS and WHMIS, refer to the WHMIS Division pages on Health Canada’s website at www.hc-sc.gc.ca/whmis.