A manufacturer/supplier who plans to sell a product to be used in a workplace environment in Canada is required to classify the chemical merchandise. The chemical product must under go a comparison of physical, chemical and toxic properties with a detailed list of WHMIS criteria. The list can be found in Part IV of the Controlled Products Regulations CPR act. In case the product is determined to meet at least one of the following WHMIS criteria:
1. Compressed Gas
2. Flammable Gases/Liquids/Solids & Aerosol
3. Combustible Liquids
4. Reactive Flammable Materials
5. Oxidizing material
6. Poisonous and Infectious Material
7. Biohazardous Infectious Material
8. Corrosive Material
9. Dangerously Reactive Material
The product becomes automatically a WHMIS controlled product and therefore subject to the WHMIS requirements.
Before the chemical product under goes the comparison of physical, chemical and toxic properties, manufacturer/supplier wants to make sure that the chemical product is excluded under Section 12 of the Hazardous Products Act HPA. Products that are excluded are exempted from both federal and provincial WHMIS requirements, which are:
1. Consumer Products
2. Cosmetics
3. Dangerous Goods in Shipment
4. Explosives
5. Food and Drugs
6. Hazardous Waste
7. Manufactured Articles
8. Pesticides
9. Radioactive Materials
10. Tobacco and Tobacco Products
11. Wood and Wood Products
In this case manufacturer/supplier has classified the chemical product to be WHMIS controlled product, his duty is to properly label the product with a WHMIS label, prepare and provide the customer with an MSDS. An MSDS must be reviewed to ensure that it is still compliant. Further, under WHMIS regulations the MSDS must be reviewed every three years.
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