OSHA Hazcom 2012 is based on version 3 of the UN GHS regulations while Canada WHMIS refers to version 5. While both versions have 28 classification categories, the differences are in the phrasing. Differences also arise in the way WHMIS has adopted version 5 with inclusions and exceptions. For trade with Canada and for preparation of the data sheets and labels one must adopt appropriate GHS for classification. The newer HPR is different from the older CPR in the subdivision of physical hazard classes. Canada has adopted all physical hazard classes save for the explosives hazard class. At the same time it has included combustible dust, asphyxiants, pyrophoric gases and physical hazards not otherwise classified in its list. Apart from including all GHS health hazard classes, WHMIS has also retained biohazardous infectious materials hazard class for enhanced worker safety. In the matter of labelling different symbols and pictograms are required in comparison to previous CPR. There are exemptions chemical manufacturers and dealers must be aware of. Small containers below 100 ml are exempt from applying precautionary statements as are containers of 3 ml or less. Likewise bulk shipment and unackaged hazardous products are exempt from labeling requirements. If a product is packaged in multiple containers then the outer container does not need to have a WHMIS label affixed provided the inner container bears a label.
Exemptions in GHS for classification are but one part of compliances. Another part is that SDS and labels must be in English as well as French languages. If an American company supplies to a Canadian distributor then that distributor may omit name of the supplier in the label. All carcinogenic ingredients based substances must have a label and SDS if the concentration of such substances is 0.1% or more. There is more if one goes into details of the new WHMIS guidelines and it requires an expert to unravel the complexities and to get the SDS and labels right to be in full compliance.
Suppliers and importers have a period of 90 days to update SDS and 180 days to update labels. If significant new information about a hazardous product becomes available the supplier may communicate the same to buyer in Canada.
There are similarities in the Canadian WHMIS GHS implementation and OSHA but with a few changes. ICSDS scientific experts are knowledgeable about both implementations and assure chemical suppliers in both countries of perfect services for preparation of perfect GHS SDS and labels that are in full compliance in both countries.