Do MSDSs prepared under U.S. OSHA Hazard Communication Standard (HCS) meet Canadian requirements?

No. The WHMIS supplier MSDS and label requirements are more prescriptive than those set out under HCS. However, the WHMIS and OSHA closely parallel one another; the main difference between those two regulations is the criteria for updating and MSDS.

In Canada under WHMIS regulations an MSDS is required by law to be updated every three years or in case there is a change in the formulation, which in that case might lead to a new WHMIS classification. On the other hand, OSHA requires an update only in the case if there is a change in formulation or health information. If a manufacturer, supplier or an importer is shipping his product to Canada they must have an MSDS dated with three years and the document must be in the two official languages English and French.

One of the main differences between the two standards is the actual style format in which the information is being presented, such as hazardous ingredients and hazard identity information. WHMIS regulations specifically require a 9 section format MSDS, which are as follows:

Hazardous Ingredients
Preparation Information
Product Information
Physical Data
Fire or Explosion Hazard
Reactivity Data
Toxicological Properties
Preventive Measures
First Aid Measures

OSHA MSDS suggests that an MSDS follows the 16 section format established by the American National Standards Institute (ANSI) standard for preparation of MSDSs (Z400.1), which are as follows:

Identification
Hazard(s) identification
Composition/information on ingredients
First-aid measures
Fire-fighting measures
Accidental release measures
Handling and storage
Exposure controls/personal protection
Physical and chemical properties
Stability and reactivity
Toxicological information
Ecological information
Disposal considerations
Transport information
Regulatory information
Other information

However, since WHMIS regulations were passed, several agencies have made suggestions and approved the 16 section standards and that under one condition that it follows the Canadian WHMIS regulations, in order to meet Canadian requirements.