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Regulatory Blog | ICC » safety

WHMIS 2015 – Administrative Aspects

by Clifton Brown on August 21, 2015 at 2:49 pm · in Clifton's Blog, Regulation Updates, WHMIS 2015

Looking at WHMIS 2015 from an administrative point of view

Despite the publicity and awareness campaigns around the labels, SDS and classification aspects of WHMIS 2015, there are a few administrative areas that shouldn’t be overlooked.

These elements of the Hazardous Products Act (HPA) and Regulations (HPR) are not related to GHS, but deal with aspects that are important to those with Supplier obligations.

Some of these have become fairly common knowledge (e.g. Canadian supplier, including same supplier on label/SDS, etc.); others have not been widely discussed.

Document Creation/Retention – HPA 14.3

Every Supplier selling (more on this later) or importing a hazardous product for use, handling or storage in a Canadian work place must maintain a “true copy” of both the SDS and label relating to the product at the time of import or sale.
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Time Requirements Under OSHA HazCom 2012

by Paula Reavis on August 13, 2015 at 9:00 am · in GHS (OSHA HazCom & WHMIS 2015), Paula's Blog

Hassock 2012 chemical classification time requirements

As a new order for classifications and label text is begun, the song “Time Is On My Side” by The Rolling Stones comes to my mind. Take a listen here to remind yourself of the rhythm and lyrics. I and many other SDS and Label authors approach each new request with optimism and the hope that a perfect world exists. Believing all of the information needed is supplied by the client, the data needed is readily available and the time needed for work is plentiful.

For any given order there could be multiple products and each product requires an SDS and Label. Each of the products is probably a mixture. In some cases the products are actually mixtures made up of other mixtures. Some of the products have trade secret claims. Taken together, this means we authors start to question what Mick Jagger is saying. Is time really on my side?
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OSHA Plays Video Games for Safety

by Paula Reavis on August 6, 2015 at 9:00 am · in GHS (OSHA HazCom & WHMIS 2015), Paula's Blog, Safety


In 1983 the science fiction film “War Games” was released. The film is set in America at the height of the Cold War where the threat of nuclear war is a topic of much speculation. The plot surrounds a hacker named David, his access to the supercomputer with artificial intelligence called War Operation Plan Response (WOPR) and a friendly game of “Global Thermonuclear War”. This game among others on WOPR was designed to teach the artificial intelligence strategy and planning. A classic line from this movie is, “Shall we play a game?” which is uttered by WOPR.

Apparently, OSHA is following in these same footsteps. OSHA has released a game. (Note: Unity Player required to play)
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Does the Safety Dance Song Really Improve Workplace Safety?

by Paula Reavis on July 16, 2015 at 9:00 am · in Paula's Blog

Workplace Safety Dance

Dancing for Safety

Trying to maintain workplace safety is never easy. Companies write best practices, policies and guidelines regularly to keep workers safe. Where there is often a breakdown is in having people actually follow those practices, policies and guidelines. As a former educator, engaging students and having them work with me rather than against me could be challenging. Even though my subject matter was science and my students were high school students, the data is clear. Music is a powerful tool to help with learning, driving concepts home and strengthening the mind.

So, to get workers involved with their own safety perhaps the 1980s song “Safety Dance” by the band Men Without Hats can be used. (Click here to hear the song) Granted the lyrics are not exactly written for workplace safety but the rhythm of the song and the chorus can be used to ask some basic questions every employee should ask every day.
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OSHA Issues Updated Interim Enforcement Guidance

by Emily Walter on June 3, 2015 at 11:33 am · in Emily's Blog, GHS (OSHA HazCom & WHMIS 2015), Industry News, Safety

new osha updates on hassock 2012 enforcement guidance

On May 29, 2015, the US Department of Labor’s Occupational Safety and Health Administration (OSHA) published an “Interim Enforcement Guidance for Hazard Communication 2012 (HCS 2012) June 1, 2015 Effective Date” in response to petitions from the National Association of Chemical Distributors (NACD). The new enforcement document is a follow-up to the guidance that OSHA published on February 9, 2015, and further clarifies the guidance for manufacturers, importers and distributors of hazardous chemicals.

According to the memorandum, the incorporation of additional clarification to the revised Hazard Communication directive “has led to a minor delay in completing review and clearance of the directive”.  OSHA now anticipates that the revised directive will be approved shortly after June 1, 2015. Upon issuance of the Hazard Communication directive, the Interim Enforcement Guidance will be cancelled.
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