On May 19th, 2017, Health Canada announced changes to the transition dates for the move from WHMIS 1988 (CPR – Controlled Product Regulation) to WHMIS 2015 (HPR – Hazardous Products Regulation). In short this change gives manufacturers and importers an extra year to bring their systems into compliance with the new act. It also gives distributors an extra 3 months, while there is no change for employers.
On the surface it appears to give everyone more time. Unfortunately, it could mean the distributers and employers have less time as they cannot do their part until manufacturers and importers complete their work. In the worst case scenario, a distributer could have 9 fewer months to make the change if a manufacturer does not complete their changes until May 31, 2018. Likewise, for an employer, they could have 3 months less time if a distributer does not complete their changes until August 31, 2018.
The good news is that many manufacturers and importers are well down the road of conversion. Companies such as 3M, Henkel-Loctite, Air Liquide, Sherwin-Williams and Swish have converted many products to the new WHMIS 2015 format.
How Will You Manage the Change?
As an employer you know the change is coming. If you have an effective process for managing your MSDSs, then updating them to the new SDSs can be managed over the next 19 months. If your process for MSDS’s involves binders, occasional review of the sheets and a plan to “blitz” the update in late November, 2018 you likely are going to face compliance and regulatory issues.
And Remember – it is not just updating the Safety Data Sheets and providing education to employees. The purpose of WHMIS is to inform employers and workers of the hazards associated with the use of chemicals and to ensure that the employer is providing adequate protection and training on that protection for all workers.
Better Hazard Information
With WHMIS 2015 workers will get a clearer understanding of the hazards. Using Acetone as an example, the hazard information changes as follows:
Materials Causing Other Toxic Effects, Toxic Material
Highly flammable liquid and vapor
Causes serious eye irritation
May cause drowsiness or dizziness
May cause damage to organs through prolonged or repeated exposure
This will likely cause more questions and concerns from workers – and employers need to be prepared.
Employer Responsibility – Protecting Workers
As with the older version of WHMIS, the new SDS will provide some information on protecting employees. However, it will not provide the specific instructions an employer must give to a worker. It is the employer’s responsibility to translate “wear appropriate gloves” from the SDS to “wear blue laminate gloves” and to train workers on their use.
As with all types of change in your organization, developing a plan, communicating frequently and adjusting to altered circumstances will be the key to success.