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HazCom Guidance Highlights Differences between U.S., Canadian Regulations
Health Canada has released new technical guidance intended to provide suppliers detailed information on Canada’s Hazardous Products Regulations (HPR), which were passed in February 2015, and its Hazardous Products Act (HPA). The new HPR, combined with recent amendments to the HPA, modify Canada’s national hazard communication standard, the Workplace Hazardous Materials Information System (WHMIS), to incorporate the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The updated regulation, WHMIS 2015, takes a similar approach to phasing in the new system as OSHA's revised Hazard Communication Standard. GHS attempts to standardize hazard communication worldwide by requiring a consistent system for classifying chemical hazards, a consistent format for safety data sheets (SDSs), and standardized labels that use pictograms to depict hazards, specific wording to inform workers of hazards, and information on how to protect against those hazards.
Health Canada plans to release this guidance in two phases. The phase-one guidance focuses on classification principles, hazard communication, and confidential business information. Individuals may request a PDF copy of the guidance via Health Canada’s website. Health Canada expects to release the second phase of the technical guidance, which will focus on physical hazard and health hazard classification, this autumn.
“[This guidance] is useful for Canadian manufacturers, consultants, and everyone doing the transition in Canada,” says Denese A. Deeds, CIH, FAIHA, co-founder and president of Industrial Health & Safety Consultants, Inc. in Shelton, Conn. “But it’s also very helpful for U.S. companies that deal with products sold for workplace use in both Canada and the U.S.”
“[This guidance] is very helpful for U.S. companies that deal with products sold for workplace use in both Canada and the U.S.”
Deeds says the guidance will help companies identify products that might have different SDS or labeling requirements under WHMIS 2015 versus OSHA’s HazCom 2012. 
The new guidance also covers variances between Canada’s HPR and OSHA’s HazCom 2012. These differences, set off by orange boxes, are discussed throughout the document. According to the guidance, some of the key variances between the U.S. and Canadian regulations include Canadian requirements for bilingual labels and SDSs, updating information on SDSs and labels when suppliers become aware of “significant new data,” the inclusion of the biohazardous infectious materials hazard class from WHMIS 1988, and label elements for “Physical Hazards Not Otherwise Classified” and “Health Hazards Not Otherwise Classified.” 
Canadian regulators “took what was OSHA’s ‘Hazards Not Otherwise Classified’ category and divided it into health hazards and physical hazards, where we just lump them all together in the U.S.,” Deeds explains. “One of the reasons they did that is because there’s a difference in the labeling requirements. In the U.S., we don’t have to put information on HNOCs on the label, but in Canada it’s required not only to be on the label, but [manufacturers] have to select the appropriate pictogram to use to represent that hazard.”
Even with the differences between the U.S. and Canadian hazard communication regulations, Deeds believes that, in most cases, it will be possible for companies to have one SDS and label that will meet the requirements of both countries’ standards.
The implementation of GHS in Canada will take place over a three-stage transition period to allow provinces and territories to adapt their own regulations and to allow employers, workers, and suppliers time to adjust to the new system. Implementation is expected to be complete by Dec. 1, 2018.
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