WHMIS - WHMIS Program

WHMIS stands for the Workplace Hazardous Materials Information System. It is a comprehensive system for providing health and safety information on hazardous products intended for use, handling, or storage in Canadian workplaces.

A WHMIS program ensures that the information about hazardous products is effectively communicated to workers. Effective communication of information means that workers understand the WHMIS system, know the hazards of the products they work with, know and apply the safe work procedures specific to their jobs and tasks, and know how to respond in an emergency.

Please refer to the following OSH Answers documents for more information about WHMIS:

• WHMIS – General
• WHMIS – Pictograms
• WHMIS – Labels
• WHMIS – Hazard Classes and Categories
• WHMIS – Safety Data Sheets (SDSs)
• WHMIS – Education and Training
• WHMIS – Glossary
• WHMIS – Confidential Business Information (CBI)
• WHMIS – Variances
• WHMIS – Laboratories

The federal Hazardous Products Act (HPA) and the Hazardous Products Regulations (HPR) from Health Canada set out the supplier duties within Canada for WHMIS. These federal laws apply to suppliers, importers, and distributors of hazardous products intended for use, handling, or storage in Canadian workplaces.

The Hazardous Products Regulations set out specific hazard classification criteria for each hazard class included in WHMIS. If a product covered by the Hazardous Products Act meets the criteria to be included in one or more of the WHMIS hazard classes, it is referred to as a "hazardous product." All hazardous products used, handled, or stored in the workplace are covered by the WHMIS regulations, and a WHMIS program, including education and training, must be in place.

Each jurisdiction (that is – each province and territory, as well as where occupational health and safety laws govern federal employees and those businesses that follow federal legislation) also has its own individual WHMIS regulations. While based on the federal requirements, the jurisdictional occupational health and safety legislation covers how the WHMIS system is implemented within the workplace and is related to the employer duties, education and training, workplace labels, and any other workplace requirements.

The WHMIS program should be developed by the employer in consultation with the health and safety committee or representative.

As an employer, your responsibilities may include to:

• Know exactly what hazardous products are present and how they are used, handled, or stored in the workplace.
• Keep and maintain accurate records about the identity and amount of hazardous products.
• Identify the hazards associated with the use, storage, handling, and disposal of the hazardous products.
• Ensure that WHMIS requirements regarding labels and safety data sheets (SDSs) are met.
• Provide workers with easy access to information, including SDSs.
• Develop compliant WHMIS labels and SDSs for hazardous products produced for use in the workplace.
• Determine who may be exposed to the hazardous products.
• Educate and train workers who may be exposed.
• Develop procedures for
  • Safe use, handling, storage, and disposal of a hazardous product
  • When the product is in a pipe, piping system, vessel, tank car, etc.
  • How to protect workers who may be exposed
  • What must be done in an emergency that involves the hazardous product
• Update SDSs and labels when significant new data is obtained from the supplier, and ensure workers receive education and training about the significant new data.
• For products classified under WHMIS 1988 that are still present at the workplace, obtain a current SDS from the supplier (if the current SDS matches the formulation of the product on site). If no SDS is available, the employer must author a new SDS for that product following WHMIS criteria and produce a supplier or workplace label. 
• Monitor the implementation and effectiveness of the program.

As a worker, your responsibilities may include to:

• Participate in WHMIS education and training.
• Follow instructions and safe work procedures.
• Be familiar with all hazardous products you are handling or to which you may be exposed (such as during a spill or fire). Do not use a product unless you have been trained in safe work procedures.
• Ensure that labels are in good condition. Do not use products without labels.
• Know how to access the SDSs, and understand the information on the SDS.
• Ask for help if you have questions.
• Report any concerns.

Employers are ultimately responsible for the WHMIS program. The health and safety committee (or representative) helps by making sure workers have the right to participate. Committees may have different roles in different workplaces. For example, some committees may be involved with the development of the WHMIS program, the development of education and training, or monitoring and auditing. The committee may find concerns during their inspections or may make suggestions or follow up about solutions.

The main elements of a WHMIS program are:

1. Purchasing and Inventory
2. Hazard Identification
3. Inspections
4. Worker Education and Training
5. Review and Evaluation
6. Document and Record-Keeping

A. Purchasing and Inventory

The employer has the responsibility to know, at all times, what hazardous products are in the workplace and in what amount. A good chemical or product inventory system and corresponding procurement procedures are essential. For example, part of the procurement process for WHMIS is to make sure the supplier has provided the correct and most current labels and SDSs for hazardous products.

It is usually the responsibility of the person in charge of procurement to develop and maintain the inventory. Product inventories will help to:

• Make the workplace safer by knowing exactly what products are present, in what quantities, and where the products are stored
• Maintain an up-to-date list of all products
• Identify (and remove) any excess, unused, or unnecessary products
• Implement proper storage and handling techniques, including any specific requirements
• Isolate and store the most hazardous products securely
• Comply with regulatory requirements

See the OSH Answers document Chemical Inventory for more information.

B. Hazard Identification

When a product is brought into the workplace, it is essential to know the hazards of the product. A summary of the hazards is found on the product's SDS. Review the SDS to make sure the information is complete and accurate. You may need additional information from other sources (such as journals, textbooks, local jurisdictions, etc.). Knowing the hazards will help you make informed decisions about use, storage, disposal, education, training, and emergency response.

Under WHMIS, employers who produce hazardous products for use in their own workplaces have the duty to assess the hazards, classify the hazards of the products, and provide proper labels and SDSs. Under general occupational health and safety laws, employers are also responsible for safe storage and use of hazardous products.

C. Inspections

Make sure all hazardous products are labelled appropriately and that SDSs are available. Include WHMIS requirements on your inspection checklist, such as:

• Are the containers in good condition?
• Are all labels in good condition?
• Are any hazardous products present without a label?
• Do workers know to read the label before using a hazardous product?
• Do workers know that they must not use a hazardous product which is not labelled?
• Are all decanted products, which are not used immediately by the person who decanted them, labelled with a workplace label?
• Are SDSs available and in an accessible location for all workers?
• Does the information between the SDS and label for the same product match?
• Are all vessels, pipelines, etc., labelled according to WHMIS requirements?

In addition to regular inspections, it may be advisable to have a specific WHMIS inspection at least once a year.

See the OSH Answers document for information on effective workplace inspections.

D. Worker Education and Training

All workers who work with a hazardous product (or who may be exposed to a hazardous product) must learn about the hazards associated with these products. The hazard information should include the information received from the supplier, as well as any other information that the employer is aware of about the use, storage, and handling of each product.

Education and training can be thought of as two separate parts.

• Education refers to general information, such as how WHMIS works. For example, you will learn about the hazard classes (e.g., why a product is called Corrosive to metals and what information you can find on labels and SDSs).
• Training refers to the site- and job-specific information for employees that will cover your workplace's procedures for storage, handling, use, disposal, emergencies, spills, and what to do in unusual situations.

Examples of topics that should be covered during education and training include:

• The information on both the supplier label and workplace label, when each is required, and what that information means.
• The information on the Safety Data Sheet (SDS) and what that information means.
• The procedures required for the safe use, handling and disposal of each hazardous product.
• Any other procedures that are required when the product is in a pipe, piping system, vessel, tank car, etc.
• All the procedures that must be followed in an emergency that involves a hazardous product.

Workers should be able to answer these questions for every hazardous product they work with:

• What are the hazards of the product?
• How do I protect myself from those hazards?
• What do I do in case of an emergency?
• Where can I get further information?

E. Review and Evaluation

The WHMIS program should be reviewed at least annually or more often if there are changes in the working conditions. Is the frequency of conducting the chemical inventory, SDS inventory, and label inspection adequate? Are the floor plans up-to-date?

This review would also determine if the current WHMIS education and training covers all hazardous products that workers may be exposed to and whether the workers are adequately informed and instructed about these hazards. Refresher education and training is generally required:

• As needed to protect workers' health and safety
• If conditions in the workplace have changed
• If new hazardous products are introduced
• If the products have changed and now have different hazards
• When new hazard information becomes available
• If there is new information about safe use, handling, storage, disposal, or emergency response

Employers must periodically evaluate workers' knowledge using written tests, practical demonstrations, and other suitable means.

F. Document and Record-Keeping

Documents and records help the employer to show due diligence and compliance. How long these documents and records must be kept may vary by jurisdiction.

Documents are “mediums” that contain information. Examples of documents may include the actual education and training material, inventory lists, SDS, label, or the inspection checklist forms. Documents should be dated, and indicate when there is a revision.

Records are documents that state the result achieved or provide evidence of activities performed. Examples of records include inspection results, steps taken to control hazards, attendance at sessions, courses completed, survey results, or annual reviews.

Suppliers must prepare and maintain documents, including copies of labels and SDS, as well as sales and purchasing information, and provide these documents to the Minister or to an inspector upon request. Suppliers must maintain their documents for six years or for any other period that may be prescribed. Employers may also need to keep SDSs on record for a set time period (e.g., Manitoba requires employers to keep SDSs on record for up to 30 years).

Employers who prepare supplier labels and SDSs for products produced and used in the workplace would need to follow similar requirements.

The following is an example of a WHMIS program implementation checklist. Adapt this checklist for your workplace's needs.

Sample WHMIS Program Checklist is adapted from WorkSafeBC and WorkSafeNB.