The deadline for completing your workplace's transition to WHMIS 2015 is just weeks away. By December 1, provincially regulated workplaces must be fully compliant with Canada's new standard for classifying, labelling and communicating information about hazard products in the workplace. Federally regulated workplaces have until May 31, 2019.
If a Ministry of Labour inspector stops by your workplace - for any reason - you'll be expected to demonstrate compliance. "WHMIS 2015 is very much on inspectors' radar," says WSPS Consultant Tova Larsen. "They know this deadline is coming."
Tova has crafted four simple questions to help you check on your workplace's compliance. If you answer no to any of them, she also has advice on where to focus your efforts.
The end of a 3-year transition
For the last three years, firms in Canada that use, manufacture or distribute hazardous substances have been transitioning from WHMIS 1988 to WHMIS 2015, a new, globally harmonized system for protecting the health and safety of workers who handle hazardous chemicals.
Features of the new system include:
- a distinction between hazards to property and hazards to people - physical hazard and health hazard classes
- supplier labels that use globally standardized language, pictograms, signal words and hazard statements
- standardized 16-section safety data sheets (SDSs)
Verify your compliance with these 4 questions
Confirm that your workplace is fully compliant with WHMIS 2015 by asking yourself the following questions. If you answer no to any, you've got work to do.
- Is your hazardous materials inventory up to date?
- Do these materials have WHMIS 2015 labels on them?
- Do you have updated SDSs to accompany them?
- Has your staff received WHMIS 2015 training?
The last question is critical, says Tova. "When checking for compliance throughout the transition period, what mattered most to inspectors was that employers were supporting workers' right to know - whether your staff really understood the hazards and how to work safely."
Found compliance gaps?
If your workplace is not yet compliant, Tova has this advice:
- Train your people - right now.
- Conduct a chemical inventory. "Clear your decks of products you don't need so you know which ones to focus on."
Still have products with old labels? Amendments to the WHMIS regulation published on November 2 clarify that workplaces should obtain a new WHMIS 2015 supplier label wherever possible. If you cannot obtain this label, affix a label that meets WHMIS 2015 requirements. In either case, obtain the updated SDS.
Generic and workplace-specific training are key requirements. Generic training teaches workers how to use pictograms, labels and safety data sheets. The workplace-specific training ensures workers understand how to safely use, handle, store, and dispose of hazardous products. "Your staff must be able to articulate that this is the product, these are the hazards, this is how I work safely with it," explains Tova.
To this end, inspectors will check that
- you have programs and procedures in place
- products have labels meeting WHMIS 2015 requirements
- education and training are complete and records are up to date
- you have an up-to-date electronic or print inventory of SDSs
"While WHMIS 2015 safety data sheets no longer expire arbitrarily after three years, the onus is now on employers to demonstrate they're staying on top of updates made to SDS. As you transition, this is a great time to consider going with a reputable provider to manage your safety sheets for you. They update them as needed in the background so you don't have to."
How we can help
- (M)SDS Management Service. Now available through WSPS, the CCOHS online (M)SDS Management Service puts all of your SDSs in one convenient, secure location that staff can access anytime.
- WSPS experts are on hand to help you with any aspect of your WHMIS 2015 program, from program development to training. Call our on-duty consultant to learn more: 1-877-494-WSPS (9777)
- Free downloads, e-courses, on-site and public training, and more on our WHMIS 2015 resource page