A report from the workers health & safety center
This report is in response to an information request about the Globally Harmonized System for Classification and Labeling of Chemicals (GHS) and its impact on our current Workplace Hazardous Materials Information System (WHMIS).
What is GHS?
GHS is an international initiative to standardize chemical hazard classification and communication globally. WHMIS is our national hazard communication system. According to the Office of WHMIS, Health Canada, GHS will not replace WHMIS and instead:
• WHMIS will be modified to incorporate elements of the GHS;
• Classification rules, label requirements and safety data sheets will be globally standardized; and
• The basic foundations of WHMIS will stay the same and be augmented by additional requirements based on GHS.
When will the integrated system become law?
Seemingly imminent, the integration of GHS into WHMIS has been in the works for a long time. In 1992, the United Nations Conference on Environment and Development (UNCED) adopted an international mandate calling for a “globally harmonized hazard classification and compatible labelling system, including material safety data sheets and easily understandable symbols” by the year 2000. Now developed, GHS has been adopted and implemented by the European Union and other members of the United Nations.
Canada initially planned to integrate GHS into our current WHMIS system by 2008. While an interim policy permits the use of GHS-formatted safety data sheets, full integration failed to emerge by this date. In 2009, a new date for integration was set for 2010. Currently however, budget cuts at the Office of WHMIS, the prorogation of Parliament, and Bill C6: Consumer Products Safety Act all stand in the way of the integration of GHS with WHMIS. The Consumer Products Safety Act meant to prohibit importation of unsafe products will be influenced by GHS, and must be in place before GHS can be integrated into other Canadian legislation such as WHMIS.
While the Assistant Deputy Minister at Health Canada assures labour the integration will eventually take place, perhaps as early as fall 2010, there is no set date for implementation.
Why does Canada want to integrate WHMIS with GHS?
GHS combats safety and global trade problems caused by several different countries using different systems for classifying and communicating hazardous materials. Before harmonization the same hazardous product could be classified as “toxic” in Canada; “harmful” in the European Union; or “moderately toxic” in China . Information required on material safety data sheets differs from country to country as do hazard symbols and label formats.
GHS should offer several benefits to both workers and employers including: consistent hazard information; more efficient administration and enforcement of hazard communication laws (such as WHMIS); easier and more cost effective compliance; and reduction of barriers to international trade.
The Canadian Labour Congress hopes the new integration will lead to more accurate information given to workers on Material Safety Data Sheets (MSDS) and labels.
How will WHMIS change with integration?
No one can say with absolute certainty how WHMIS will change with integration. However, if current plans come to fruition, WHMIS should change as follows. After GHS is incorporated into Canada’s WHMIS the roles, responsibilities and duties of workplace parties should stay the same. For instance, employers will still need to ensure hazardous products are properly labeled, and provide workers with up to date Safety Data Sheets (SDS). (Material Safety Data Sheets (MSDS) will be called SDS in compliance with GHS.) According to Health Canada, SDS will likely need to be updated as frequently as MSDS are updated now — every three years or more often if new information becomes available. Worker training requirements will remain the same. Workers already trained in WHMIS will need to receive training updated WHMIS (GHS elements included).
The GHS will change WHMIS in several key ways, including:
• New classification rules and hazard classes;
• A standardized format for SDS;
• New hazard symbols/pictograms; and
• New label requirements.
Classification and hazard classes
Current Canadian WHMIS uses six main classes to group hazardous materials according to similar properties or hazards. Class B (Flammable and Combustible Material) and Class D (Poisonous and Infectious Material) further break down into sub-classifications called “Divisions”.
In GHS hazards are arranged into three general groups, each with one or more hazards:
• Physical hazards – 16 classes
• Health hazards – 10 classes, and
• Environmental hazards.
As a result, the classification criteria used by suppliers will be different. Biohazardous infectious material (WHMIS Class D3) and products which react with water to release a toxic gas or vapour (part of WHMIS Class F) are not included in GHS. According to Health Canada, these hazards will be retained in Canada’s revised WHMIS, so the level of protection provided by today’s WHMIS will not be reduced. GHS introduces four classes of hazard not presently covered by WHMIS, namely: explosives; aspiration hazards; specific organ toxicity from single exposure; and hazards to the environment with particular emphasis placed on the aquatic environment. Follow this link to see a chart of GHS hazard classes: http://vubiz.com/V5/fModules/3616EN/media/00171444.pdf
1 United Nations Conference on Environment and Development (UNCED) Conference, 1992, Agenda 21, para.19.27.
WHMIS after GHS, CCOHS, Health Canada