April 2022
Do Safety Data Sheets expire? Do I need to check up on them? We used to check our sheets every 3 years, do we still need to do this under the new Global Harmonization System? These questions, and other similar ones continue to come in on a regular basis. Unfortunately, the implementation of WHMIS 2015 was less than smooth and was not well communicated nation wide. So hopefully we can shed some light on what's going on, and answer some of your questions!
Under the old WHMIS 1988 system the Controlled Products Regulations (CPR)s required that Safety Data Sheets be updated every 3 years. Although this could be burdensome and frustrating for some, it was easy to understand as it was a universal requirement across the country, for all provinces. Unfortunately, this is no longer the case under the new WHMIS 2015 requirements. So yes, you MIGHT need to update your sheets every 3 years, MAYBE. Clear right?
With the new WHMIS 2015 system comes the switch from the Controlled Products Regulations to the Hazardous Products Regulation (HPR) and the removal of the 3 year refresher requirement. Sounds simple? Unfortunately it is not. While Health Canada, at the federal level, has removed the 3 year expiry it is up to the provinces to actually implement the regulation. In doing so, about half of the provinces decided to retain the 3 year expiry while the others left it out. Not sure if your province retained the 3 year refresher requirement? Check the WHMIS regulations for your province, or contact us and we can help you out.
So what if your province is one of the provinces that has decided not to re-implement the 3 year refresher requirement? Are there different requirements for the other provinces? Unfortunately, for these other provinces, there is no set rule and instead the refresher schedule is left to the end user. While we expected more guidance from the provinces on these vague requirements COVID-19 hit soon after the implementation of WHMIS 2015 and no news has come down from the provinces since. So what to do?
With no guidance provided by the provinces half the country has been left in the dark as to what is expected. So without any guidance we recommend using industry standards as a best practice. With half of the provinces/territories still following a 3 year refresher schedule we are recommending to our clients from the other provinces follow a similar timeline, until further guidance is provided by your specific province. Hopefully additional information will be coming soon, but in the meantime a safe practice of following the other provinces is recommended. Good luck, and hopefully the provinces will get their act together soon!
The SDS Smart Team
April 2022
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