Variances under WHMIS and OSHA Hazard Communication | Help Center

Canada/US Variances under WHMIS and OSHA Hazard Communication

Recently, Health Canada released a document outlining the variances between Canada’s WHMIS and the United States’ OSHA Hazcom regulations.

You can read the full document here.

For the most part, it is easier than ever to prepare a document that is compliant with the USA and Canada. Let’s look at some of the variances you need to consider:

Supplier identifier:

This is a tricky one. Canada wants the WHMIS SDS to have a Canadian address and phone number, and the US wants an OSHA document with a US address and phone number. The issue is that many US-based companies do not have a Canadian address, and vice versa.

Section 11:

There is a lot of the same in section 11, but one of the differences on the US OSHA SDS is a statement relating to whether the substance is on the National Toxicology Program (NTP) Report on Carcinogens (latest edition) or has been found to be a potential carcinogen in the International Agency for Research on Cancer (IARC) Monographs (latest edition), or by OSHA. This is an easy fix on a US/CA document; add it in the carcinogenicity section, and Health Canada will not mind, as it is supplemental information.

Prescribed concentration ranges:

Health Canada allows specific concentration ranges to protect confidential information. The only other option in Canada is to register the trade secret with the HMIRA. Although OSHA would like specific ranges on SDS, if the information is a trade secret, it can be listed as proprietary with a trade secret statement. See the OSHA Hazcom regulations for full details.

Bulk shipments:

In Canada, no label is required for bulk shipments and unpackaged hazardous products. In the US, the label must be placed on the immediate container.

Bilingual SDS:

In Canada, both English and French SDSs and labels are mandatory. In the US, English is the only mandatory language. The US allows for additional languages, so having French on a US product is not an issue.

Explosives:

Canada did not adopt the explosive hazard class, unlike the US.

PHNOC/HHNOC/HNOC:

In Canada, Physical Hazards Not Otherwise Classified (PHNOC) and Health Hazards Not Otherwise Classified (HHNOC) are divided, whereas in the US, they are all within the Hazards Not Otherwise Classified (HNOC) category.

Need help understanding if a US-Canada SDS is right for you? ICC Compliance Center has a team of full-time Regulatory Experts who have years of experience and are certified/recognized in their field of expertise. Ask us your tough questions by calling 888.442.9628 (USA) or 888.977.4834 (Canada).