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A key difference that distributors of imported hazardous products are struggling with is the treatment of products that require re-labelling with Canadian-compliant labels.<\/p>\n
WHMIS 1988 and WHMIS 2015 both require a “supplier” (seller) to ensure that products have compliant labels- i.e. as outlined in the respective “controlled” or “hazardous” products regulations. Manufacturers and Distributors, as suppliers are usually comfortable in complying when they are preparing\/consolidating shipments of products initially labelled in compliance with the Canadian regulations for GHS-based required wording, pictograms, etc.<\/p>\n
However, when receiving imports other mandatory features such as bilingual English\/French text, a Canadian Supplier name\/address and “non-GHS” classifications may not always be present.<\/p>\n
Ideally the foreign supplier will have the instruction and capability to address Canadian label requirements when fulfilling the order from a Canadian customer- be it the end user or a distributor.<\/p>\n
If the foreign supplier is unable to reliably provide WHMIS-compliant labels, the Canadian importer may supply the labels for application before shipment.<\/p>\n
Practically this may not always be possible depending on the sophistication of the foreign supplier, the volume ordered or the uniqueness of the product. The Canadian distributor may bring non-compliant product to their facility\/agent and re-label the product before delivery to the final customer who will have employees handling and\/or using the product.<\/p>\n
The above options are possible under both the WHMIS 1988 and WHMIS 2015 regulations.<\/p>\n
A third option was available under WHMIS 1988 which most suppliers found most expedient, particularly for skid-load packages, and the only practical option when delivery requirements necessitated direct delivery to the user location- bypassing the distributor\/importer\u2019s facility.<\/p>\n