FAQ – GHS Symbols on SDS in Canada and the United States

Frequently Asked SDS Symbols Questions

How many times have you thought you understood a requirement, only to second guess yourself about whether you got that right or not? It could be something relatively straight forward, or something a bit more complicated. Everyone has these moments occasionally, especially with the implementation of GHS around the world. At ICC, two of the questions that seem to pop up from time to time, revolve around symbols on SDSs.

Do GHS pictograms have to appear on an SDS?

The answer: No. The ‘pictogram,’ specifically, doesn’t have to appear. This answer, in part, boils down to terminology.

In both Canada, under WHMIS 2015 Hazardous Products Regulations (HPR) requirements, and in the United States, under Hazcom 2012 requirements, Section 2 of an SDS is required to list the label ‘information elements’ that are applicable to the product. Hazard ‘symbols’ being one of the required ‘information elements’.

In both the United States and in Canada, ‘pictogram’ is defined as a “symbolalong with other “elements, such as a border or background color”. So a complete GHS ‘pictogram’ is actually two part; a graphic symbol on the inside, and a frame surrounding it. Both countries include an allowance only to show a ‘symbol’ (ie. not a ‘pictogram’), or, just the name of the symbol, on the SDS [Hazcom 2012, Appendix D, Table D.1, Item 2(b); WHMIS 2015 Hazardous Products Regulations, Schedule 1, Item 2(b)].

So … no complete ‘pictogram’ is required on the SDS in the US or in Canada.

If I choose to show a complete ‘pictogram’, and not just the ‘name’ of the symbol on the SDS in Section 2, do I have to use a red frame?

The answer: No. the ‘pictogram’ would not have to show a red frame on the SDS.

As mentioned above, in both countries, what is required on the SDS is the ‘symbol’ and not the complete ‘pictogram’ [Hazcom 2012, Appendix D, Table D.1, Item 2(b); HPR, Schedule 1, Item 2(b)]. What that means, is that if you choose to include a complete ‘pictogram’ on your Hazcom 2012 or WHMIS 2015 SDS (ie. the ‘symbolplus the frame), you can include the frame in the color you prefer since the requirement on the SDS is for the ‘symbol’ only and not the ‘pictogram’. There is no specific requirement in Hazcom 2012 or the HPR to have a red framed pictogram on the SDS. The red frame requirement is only on the label (Hazcom 2012, Appendix C, Section C.2.3.1; HPR, Part 3, Section 3.1).

As an example, Section 2 of an SDS for a product classified as a Flammable Liquid – Category 3 and an Eye Irritant – Category 2A, may appear as any of the following 3 options:

Option 1 Option 2 Option 3
Label elements Label elements Label elements
Hazard pictogram(s) Hazard pictogram(s) Hazard pictogram(s)
Insert GHS Red flame & Exclamation Mark Insert GHS Black flame & Exclamation Mark Exclamation Mark

Don’t Forget

The above SDS information is applicable in Canada and the United States. Section 2 SDS requirements may vary, depending on what region of the world you are dealing with.

Should you have any questions regarding SDS’s, please contact ICC Compliance Center at 1-888-442-9628 (USA) or 1-888-977-4834 (Canada).

Toni-Ann McLean

Toni-Ann McLean

Toni-Ann McLean has over 17 years experience with writing MSDSs/SDSs for the protection of workers and emergency personnel, as well as determining labeling requirements for the protection of consumers, and of workers and emergency personnel. She specializes in Canadian WHMIS regulations (WHMIS 1988, WHMIS 2015), US OSHA regulations (29 CFR, Hazcom 2012), US and Canadian consumer regulations (US CPSC FHSA & Canadian CCCR 2001), and European regulations (EU DSD/DPD/CLP, CHIP).She is also knowledgable in US Right to Know legislation, EU REACH and Canadian Health and Safety legislation. Toni-Ann has been an active member of the Society for Chemical Hazard Communication (SCHC) for over 13 years where she has learned about upcoming changes to Health & Safety regulations, as well as maintained up to date knowledge of a wide variety of world-wide Health & Safety legislation. She was awarded an SCHC certificate for more than 160 hours of professional development training. Toni-Ann additionally is a current SDS Registered Professional (SDSRP), under the American Industrial Hygiene Association’s (AIHA) SDS & Label Authoring Registry Program.