Why Canada’s SDSs Still Require a 3-Year Update Cycle

The transition to WHMIS 2015 (Canada’s GHS-aligned system) marked a significant step forward in standardizing workplace hazard communication across the country. While the federal rules brought clarity, they also introduced a crucial nuance regarding Safety Data Sheet (SDS) validity that many suppliers overlook: the ongoing conflict between federal and provincial requirements.

If you supply hazardous products in Canada, understanding this distinction is key to maintaining compliance and supporting your customers.

Under the federal Hazardous Products Regulations (HPR), the strict, mandatory three-year expiry date for supplier SDSs was abolished back in 2015. This change shifted the onus for updates from a rigid timeline to a trigger-based event.

Federally, an SDS must now be updated only when Significant New Data becomes available.

You might ask yourself – What is “Significant New Data“?

This is any information about a hazardous product that changes its hazard classification or alters the way an individual can safely handle, store, or protect themselves from its hazards. This includes, but is not limited to, new toxicological findings (like carcinogen data) or major changes to physical properties. If the product’s classification as a whole is impacted, an update is required.

In short, if no new significant data emerges, the federal government did not require the supplier to update the SDS based solely on its age.

The Provincial Mandate: The 3-Year Rule Lives On

Despite the federal change, several provincial and territorial Occupational Health and Safety (OHS) jurisdictions have maintained a version of the three-year rule as an employer requirement.

These jurisdictions require the employer (your customer) to ensure the SDS available in the workplace is no older than three years. To ensure their compliance, the employer must obtain an up-to-date SDS from the supplier if the current one reaches three years of age.

For suppliers, this means the most reliable way to service the Canadian market compliantly is to proactively update your SDSs every three years for all products sold into these regions.

The jurisdictions that currently enforce the three-year requirement for the employer to obtain an updated SDS include:

British Columbia
Saskatchewan
Yukon
Northwest Territories
Nunavut
Nova Scotia
Newfoundland and Labrador

If you sell to any of these regions, the three-year clock is still ticking for your products.

To maintain seamless compliance across Canada and protect your customers from OHS violations, your strategy should be two-fold:

Monitor for Significant New Data: Always be vigilant for new toxicological or physical-chemical information that triggers a mandatory federal update (must be reflected on the SDS within 90 days of becoming available).
Schedule Proactive Updates: Regardless of hazard changes, schedule a review and update of all SDSs every three years if you supply products to British Columbia, Saskatchewan, Yukon, Northwest Territories, or Nunavut.

Don’t let a procedural loophole become a compliance risk. Ensure your Safety Data Sheets are current, accurate, and meet the specific legislative needs of every province you operate in.

Staying ahead of regulatory expectations isn’t just a compliance requirement—it’s a core component of operational resilience. By aligning your update cycles with both overarching standards and jurisdictional mandates, you strengthen downstream partnerships, mitigate risk exposure, and reinforce your organization’s commitment to safety excellence. If you’re looking to streamline SDS lifecycle management and embed a more proactive compliance posture, connect with us today to activate a future-ready SDS strategy. Call ICC today at 888.442.9628 (USA) or 888.977.4834 (Canada) or send us an email.