Across the board retraining in WHMIS (Workplace Hazardous Materials Information System) will likely be required in Canadian workplaces within the next few years upon the introduction of a new international standard.
The globally harmonized system (GHS) for classifying and labelling chemicals will introduce a universal template for conveying product information in safety data sheets and a consistent labelling format using pictograms.
Manufacturers and suppliers will also be following new rules for identifying health, physical and environmental hazards that will give purchasers and users a more comprehensive breakdown of a product’s potential harmful effects.
These include additional categories of disclosure such as risk to the ozone layer and aquatic environment, which will broaden the scope of the material safety data sheets (MSDS) currently mandated through WHMIS.
“It is going to make it a lot simpler for workers on the shop floor,” says Rob Parker, senior occupational hygienist with Pinchin Environmental Ltd. “With the current system, you can have an MSDS format that is different from product to product. This will standardize it. GHS will also standardize risk phrases.”
Many of the details are still unknown as Health Canada works toward its stated March 2013 target date for releasing draft regulations. However, Canada’s commitment to the new system is longstanding, beginning with the initial adoption of the concept in 1992 at the United Nations Earth Summit in Rio de Janeiro, Brazil.
The original objective to develop an easily understandable global system “if feasible, by the year 2000,” proved to be somewhat optimistic as the work progressed. GHS draws from requirements and approaches in four existing systems, including those used in Canada, the United States and the European Union as well as the United Nations’ recommendations on the transport of dangerous goods – while taking into account the needs of developing nations and recent scientific advancements.
Progress to implementation
“None of this has been put into law here in Canada, so we make assumptions based on what other jurisdictions are doing,” says Renzo Dalla Via, senior research specialist with the Ontario-based training and advocacy organization, Workplace Safety & Prevention Services (WSPS). “Our assumption is Canada intends to be ready for when the U.S. and European Union are fully implementing GHS.”
Toward this end, a joint Canada-U.S. working group was established last year to share expertise and synchronize the two countries’ efforts as much as possible. Canadian federal officials are currently aiming to have the regulations finalized by January 2014, with implementation to follow in 2015. Provincial governments would then have to enact complementary regulations under their own occupational health and safety statutes.
The U.S. Occupational Safety & Health Administration (OSHA) recently amended its Hazard Communications Standard to correspond with GHS, although the complete switchover to the new rules is expected to be phased in over the next four years. The European Union similarly adopted new regulations in 2009, with plans to incrementally phase them in by 2015.
Products entering Canada must continue to comply with the current Canadian rules until GHS is formally adopted here.
“I’m sure we are going to see dual labels on products for a period of time,” says Pinchin Environmental’s Parker. “A lot of companies are already moving to the new safety sheet format. We are seeing that now with things coming from some of the European countries and the U.S., and they will need to be WHMIS-compliant here.”
Even after GHS is adopted, discussion thus far indicates at least two rules not explicitly stated in GHS will continue to apply in Canada. Safety data sheets will have to be updated at a minimum interval of three years, while labelling and product information must be in both English and French.
Training requirements
Safety advocates and educators endorse GHS’ greater reliance on pictograms to communicate warnings but caution that it will take some time and repeated exposure to the images before users reflexively associate a message with a symbol.
“WSPS has been doing a significant amount of work around pictograms and their ability to transcend language and literacy obstacles, but it does require training for it to become known and for it to become inculcated into society,” says Sandra Miller, vice-president of innovation and knowledge mobilization with WSPS. “Information about the pictograms needs to be posted in places where the activity is taking place and workers will need to know who they should go to for further guidance.”
Current regulations mandate WHMIS training for all employees who handle or may be exposed to hazardous products or materials. This training typically takes two to three hours to complete. An annual program review is required, which may also entail refresher training if new controlled products have been introduced into the workplace, or product information or workplace conditions change.
The next step
Nevertheless, GHS is ultimately about messaging, not substance. It aims to simplify and clarify communication about risk but the products may remain as persistently risky.
“It’s one of the tools in the toolkit but our real goal is actually to end up with safer products,” asserts Stephen Ashkin, executive director of the Green Cleaning Network and an advisor to the U.S. Green Building Council (USGBC) on green cleaning standards in LEED (Leadership in Energy and Environmental Design) for Existing Buildings: Operations and Maintenance (EB:O&M).
Ashkin sees a role for ingredient disclosure and more precise labelling in that objective.
“If we can get manufacturers to disclose all the ingredients they use and standardize the nomenclature for those ingredients, we really believe it will be in manufacturers’ interest to produce safer products,” he says.
Barbara Carss is editor-in-chief of Canadian Property Management magazine.
