WHMIS After GHS
Imagine a chemical substance with a specific CAS (Chemical Abstract Services) Number and a specific lethal dose value that is simultaneously described as “Toxic” in North America, “Harmful” in Australia and Europe, “Moderately toxic” in China, “Hazardous” in New Zealand and “Non-toxic” in India. Imagine the legal complications and difficulty filing official paperwork in order to export this substance from one country to another. Imagine the number of different labels required for this product let alone how you accurately communicate the hazards associated with this product to workers who might use it. In a world dependant on global trade such difficulties can seriously undermine economic progress. It was this, and other environmental issues, that world trade representatives sought to address in the early 1990’s.
In 1992, in Rio de Janeiro, representatives from around the world met at a meeting that was to become known as the Earth Summit. The discussions centered mainly on social and environmental challenges facing the globe. However there were also talks about the barriers nations faced that were interfering with the free flow of commerce. Out of those discussions came a resolution to try and standardize the way we identify and communicate about chemicals and other hazardous substances. Not just within a nation or continent, but to implement a worldwide standard that would help to overcome, if not altogether eliminate, those impediments. A decade later the first draft of the Globally Harmonized System for the Classification and Labelling of Chemicals (GHS) was created and adopted by the United Nations. The current version of GHS is the third revised edition of 2009 (GHS Purple Book)2. It is this version of GHS that many in Canada expect to be adopted. Health Canada is the organization that has been given the task of coordinating the Canadian position.
Many are tempted to view the length of time to implement these changes with derision. While it is true that the wheels of government turn slowly, it is important to appreciate the complexity of the task and the fact that Health Canada is committed to a tripartite consultative process that includes federal and provincial governments, industry and labour.3 The presence of so many players and so many different view points and interests means that in mid 2011 we can still only speak about anticipated changes.
It is important to understand that Canada’s national system of hazard communication, WHMIS, will not be replaced by GHS. Instead, government documents usually refer to the proposed system as “WHMIS after GHS”. The areas that will see changes include: classification rules, label requirements and information documents (formerly known as Material Safety Data Sheets [MSDS’s]; henceforth to be called Safety Data Sheets [SDS]).
There will be many more classes of hazards under the GHS system and probably covering more substances. It is expected that there will be three general groups and classes within each group as follows:
Physical Hazards – 16 classes
Health Hazards – 10 classes
Environmental Hazards – 2 classes
Furthermore each class may be subdivided into one or more categories. There will also likely be 5 new classes covering: explosives, aspiration hazards, specific target organ toxicity – single exposure, hazardous to the aquatic environment and hazardous to the ozone layer4.
Supplier labels will still be required under the new rules. They should look similar to what we are all used to seeing under WHMIS. It is possible that the specific chemical name will appear under the product identifier and new “signal words” (such as ‘Danger’ or ‘Warning’) will be required to be used as per appropriate regulations. Hopefully, the requirement for the familiar hatched border will be retained in WHMIS after GHS.
Material Safety Data Sheets (MSDS’s) will be known simply as Safety Data Sheets (SDS’s) in WHMIS after GHS. We can expect that the long standing deficiency of having non-standardized information documents will finally be addressed. SDS’s will follow the 16-heading format already adopted by ANSI and ILO. This format has already been used for many American based products and will help to ensure that the same type of information will be presented in the same order, with the same headings. It is expected that the rules for updating SDS’s will be retained – every 3 years or when new information becomes available.
In an ever changing world nothing stays the same. Even the venerable WHMIS regulations must be amended and updated. It has taken awhile in coming, but rest assured change is coming.