Globally Harmonized System

After more than a decade of work, the new global system, the Globally Harmonized System (GHS) of Classification and Labelling of Chemicals (GHS), was adopted by the UN Economic and Social Council (ECOSOC) in July 2003. GHS will eventually be adopted in Canada, in order to change WHMIS. All industries will be eventually affected by this change. For now, WHMIS, as we know it, is still in force and will remain until final adoption of the changes proposed by GHS. As there is no draft of any regulations, it is impossible to predict what the regulatory requirements will be and, let alone, provide useful training.

The purpose of this new system is to facilitate communication of dangers associated with hazardous products between different countries. Several countries have already adopted GHS and the harmonization process with their local legislation has already begun.

The regulatory process required to implement GHS is still running its course. But we know that there will be a progressive implementation period.

Canada has worked with other countries to harmonize existing hazard communication systems on chemicals in order to develop a single, globally harmonized system to address classification of chemicals according to their hazards and communicate the related information through labels and safety data sheets. The adoption of GHS is still in process and is certainly not finalized yet. When it is adopted, there will be a transition period to allow employers and suppliers to adapt to the new rules.

How will GHS change WHMIS?

Roles and Responsibilities

Overall, the current roles and responsibilities for suppliers, employers and workers likely will not change in WHMIS after GHS. Suppliers, Importers and Producers duties will continue to include:

Employers must continue to
Workers will still

Classification

How chemicals are classified will be affected. It is likely (but not confirmed) that WHMIS legislation will:

Supplier Labels

Labels requirements will also change, and will probably have a few new requirements. Labels will use new pictograms, as well as a signal word - Warning or Danger.

Under the GHS system, once a chemical is classified, specific signal words, hazard statements and symbols/pictograms are required (prescribed) for each hazard class and category. These elements must appear on the label.

All of the required elements for labels are not yet determined. It is still not clear, for example, if the names of hazardous ingredients will be included on the label, or if the WHMIS hatched border will still be required.

Safety Data Sheets (SDSs)

SDSs will use a 16-section format. There will be standardized information requirements for each section. The 9-section WHMIS format for MSDSs will no longer be acceptable. Another important change to note is that the product classification and some of the label information will probably be required on the SDS. The SDS updating requirements (every 3 years) will likely be required.

How can suppliers prepare now?

Under WHMIS after GHS, suppliers will continue to classify products, create labels and create SDSs (formerly MSDSs) but they will follow the "WHMIS after GHS" requirements.

To prepare to classify a product, suppliers could:

  1. Obtain a copy of the GHS criteria.
  2. Identify the relevant hazard data for their ingredients and products.
  3. Review the data in light of the classification criteria to determine the appropriate hazard classes and categories. Note that there is specific guidance for classifying the health and environmental hazards of mixtures.
  4. Document the rationale and information for future reference.

Once changes to WHMIS legislation have been published, confirm product classifications. Suppliers must use a "weight of evidence" approach to classify products. The validity of research reports and other information must be evaluated as a whole. In some cases a single, well-conducted study will be sufficient.

If they are not already doing so, suppliers could also switch to a 16-section SDS format.

How can employers prepare now?

After GHS implementation, SDSs and labels for products originating within and outside of Canada will share common elements. This standardization should simplify education and training after the initial transition period is over. However employees will need training on both systems until the transition is complete.

During the transition period, employers will be faced with more than their normal number of SDSs -- in addition to the WHMIS-compliant MSDSs for existing stock, new SDSs compliant with WHMIS after GHS requirements may be provided for new shipments of the same products. Keeping up-to-date inventories of all controlled products and the status of the MSDS/SDS will be essential. Furthermore, employers will be required to train all employees for WHMIS and GHS during the transition period.