Health and Safety ReportVolume 10, Issue 3

Top 5 questions about GHS answered


After years of anticipation, the implementation of the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) is one step closer to reality in the United States (U.S.). This change has implications for Canadians and Americans alike, and raises many questions. Here are the top five questions - and the answers - that CCOHS is asked about the GHS.

1. What are Canada's timelines for implementing the GHS in WHMIS?


This is the most common GHS question that CCOHS is asked and, unfortunately, the answer is that the implementation timelines for Canada are still unknown. Federal WHMIS regulators are working on finalizing their proposed changes to WHMIS to implement the GHS. Health Canada is expected to post detailed information on their website about how WHMIS may change, for public consultation. In addition to public consultation, Health Canada has identified these remaining steps:

• an economic analysis


• revision of the federal legislation, including the Hazardous Products Act and the Controlled Product Regulations


• revision of WHMIS regulations by the provincial and territorial governments

With Canadian laws often taking one or two years to be updated, CCOHS estimates that there won't be new WHMIS laws until 2013 or later. Then it is expected that there will be a "transition period" for suppliers and employers to switch from old-to-new WHMIS requirements (possibly a two or three year transition period).

2. Are GHS safety data sheets (SDSs) accepted in Canada today?


Yes, they are, with a few important considerations.

For some time now the WHMIS program has had a policy to accept a number of different MSDS formats, including the 16-section GHS SDS format, in place of the 9-heading format required by the Controlled Products Regulations. However, it is very important to note that the MSDS/SDS must contain all of the WHMIS required content as specified in the Controlled Products Regulations (Schedule I, Column III). It is also important to note that the GHS hazard classification may not always be the same as the WHMIS classification and there are differences in terminology between the two systems. Therefore, care should to be taken to communicate messages that are consistent with the WHMIS hazard communication system.

3. Are GHS labels accepted in Canada today?


No, they are not.

The National Office of WHMIS does not have a policy to accept GHS labels. There are some important differences in the label requirements of the two systems. For example, the WHMIS regulations require:

• the use of applicable WHMIS symbols - the GHS requires pictograms, but the pictograms are not identical to the WHMIS symbols;


• the use of a hatched border - the GHS does not require a specific label border; and


• reference to the material safety data sheet - there is no similar requirement in the GHS.

Note: It remains to be seen if the hatched border and reference to the SDS will be retained after the GHS is implemented in Canada.

4. I am a Canadian manufacturer shipping hazardous products to the U.S. How will changes to the Occupational Safety & Health Administration (OSHA) Hazard Communication Standard affect me?


This is a good question. As an exporter of hazardous products to the U.S., you will have to comply with the new "GHS" requirements of the OSHA Hazard Communication Standard when they become law. Keep in mind that a multi-year transition period is expected, so you will have time to reclassify your products and prepare OSHA GHS compliant SDSs and labels. However, depending on factors such the number of raw materials/ingredients used in your products, and the number of SDSs and labels that you must produce or update, you may want to get started sooner rather than later.

On the other hand, if you are a U.S. company shipping hazardous products into Canada, you will be impacted by WHMIS laws. While the company importing products into Canada is legally responsible, you may be asked to provide the WHMIS labels on your products as support, or as a condition of sale.

5. Should I be training on the GHS now?


The primary goal of training is that all target audiences know how to recognize and interpret label and/or SDS information, and take appropriate precautions. Until the new laws come into force, you should continue to train on your existing hazard communication system (Canadian WHMIS or OSHA HazCom).

If you are an American supplier, employer, or worker, you should check the OSHA website for current information regarding implementation of the GHS in the U.S., and the new Hazard Communication Standard requirements. Training resources will likely be published very soon.

If you are a Canadian supplier, employer, or worker, the CCOHS "WHMIS after GHS" courses will help increase your awareness about potential changes. However, company-wide training is not a good idea until the possible requirements for GHS implementation into WHMIS are published.

LATE BREAKING NEWS

The U.S. OSHA GHS Final Rule was published in the Federal Register on March 26, 2012. The effective date of the final rule is 60 days after the date of publication. For more information, see the Hazard Communication from OSHA.

Still have questions, or need more help? Look no further:

• WHMIS After GHS Fact Sheets, CCOHS
  
  
• WHMIS After GHS: An Introduction e-course, CCOHS
  
  
• WHMIS After GHS: How Suppliers can Prepare e-course, CCOHS
• 
  
  GHS OSH Answers, CCOHS
  
• 
  WHMIS After GHS: Preparing for Change publication, CCOHS
• 
  
  CANLabel™ label writing software, CCOHS
• 
  
  CANWrite™ MSDS writing software, CCOHS
• 
  
  MSDS -> SDS: Not Just Dropping the "M" poster, CCOHS
  
• 
  Hazard Communication, OSHA
  

Remembering lives lost or injured in the workplace


In 2010, more than a thousand workers in Canada lost their lives to a disease or injury they incurred from work-related causes. 1014 workplace deaths were recorded - each one leaving a trail of pain for the families impacted by the loss of a husband, wife, father, mother, brother, sister, son or daughter. And most - if not all - are fatalities that could have been prevented.

To honour those workers across the country whose lives have been lost, who have been injured or disabled on the job, or suffer from occupational diseases, April 28th has been set aside as the National Day of Mourning. The Day of Mourning is an opportunity not only to remember, but also for employees and employers to publicly renew their commitment to improve health and safety in the workplace.

This day of observance was established when the Workers Mourning Day Act was passed in December 1990. Since that time, various events are organized each year by labour organizations across the country to express remembrance for the family, friends, and colleagues who have suffered in carrying out workplace duties. The Canadian flag on Parliament Hill will fly at half-mast. Workers will light candles, don ribbons and black armbands, and observe moments of silence.

Over the years the day of observance, known in most other countries as the Workers' Memorial Day, has spread to over 80 countries and is now an international day of remembrance of workers killed in incidents at work, or by diseases caused by work. In addition, the International Labour Organization (ILO) celebrates the World Day for Safety and Health at Work on April 28th to promote the prevention of occupational accidents and diseases globally.

CCOHS hopes that the annual observance of this day will strengthen the resolve to establish safe conditions in the workplace for all. It is as much a call to protect the living, as it is a day to remember the dead.

To help you promote awareness of this important day and serve as a powerful reminder to reflect on the importance of safety in the workplace, CCOHS has designed a new poster and pin.

The CCOHS website has more information about the National Day of Mourning.

For further statistical information, visit AWCBC National Work Injuries Statistics Program.

This month's Health and Safety To Go! podcast shines the spotlight on work-related asthma, and features an encore presentation of Improving the Lives of Shift Workers.

Feature podcast: Putting the Spotlight on Work-Related Asthma

Dr. Michael Pysklywec, Occupational Health Physician at the Occupational Health Clinics for Ontario Workers Inc., explains what work-related asthma is, who's most at risk, and how this condition is diagnosed.

The podcast runs 8:58 minutes. Listen to the podcast now.

Encore podcast: Improving the Lives of Shift Workers

CCOHS shares tips on how organizations and individual workers can take steps to ease the effects of shift work on their health.

The podcast runs 5:03 minutes. Listen to the podcast now.

CCOHS produces free monthly podcasts on a wide variety of topics designed to keep you current with information, tips, and insights into the health, safety, and well-being of working Canadians. You can download the audio segment to your computer or MP3 player and listen to it at your own convenience... or on the go!

See the complete list of podcast topics. Better yet, subscribe to the series on iTunes and don't miss a single episode.

Manual provides guidance to work safely with chemicals


Chemicals are used in almost every workplace. They can take many forms: solids, liquids, vapours, gases, dusts, fumes or mists. And whether they are cleaning products, the raw materials used to make products or the byproducts of industrial processes, if they are not used correctly, chemicals can seriously harm your health and/or your property.

CCOHS' new manual, Implementing a Chemical Safety Program can help you create a workplace that is healthy and safe from the hazards associated with chemicals. Having a chemical safety program in your workplace can help reduce health and safety risks, lower environmental impact, and reduce operation costs. It can also help organizations assign responsibilities and accountabilities for chemical safety, and create a culture of prevention and awareness.
The overall goal is to establish a program that considers the entire lifecycle of the chemical or process - beginning with purchasing and including identification, labelling inventory, use, storage, record-keeping, and disposal.

Implementing a Chemical Safety Program provides the information, samples, and checklists you need to start or improve your chemical safety program. It can also help you understand how to work safety with chemicals, the health hazards, and storage, handling and other aspects of chemical safety. The actual chemicals that are present and their hazards, as well as the size and complexity of your specific workplace, will determine the level of program that you need. You can adapt and customize the information in the manual to make the program work best for the hazards of the chemicals present in your workplace.

This manual provides organizations with the guidance they need to develop, maintain, and continually improve a chemical safety program, and in the process, create healthier, safer workplaces.

Learn more about Implementing a Chemical Safety Program.

It's that time of year again when we check in with you to see how we're doing. We are continually making improvements to the Report based on feedback we receive from our readers. The Report is now emailed to more than 31,300 every month to readers in more than 110 countries around the world.

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