Getting Ready to update

By January 18, 2023 OSHA/WHMIS/CLP

Getting Ready to update

On January 4, 2023, Health Canada released an update to the Hazardous Product Regulations, amending it to the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) Seventh Revised Edition and amended Schedule 2 to the Hazardous Products Act.

We expect OSHA (Occupational Safety and Health Administration) to release a Final Rule any day, amending the Hazard Communication Standard 1910.1200 to the Seventh Revised Edition of the GHS book as well.

What does this mean to you?

First and foremost, your Safety Data Sheets (SDS) will need to be updated. Do not panic, you have a 3-year transition period. With that said, it is never too early to get started, and trust me, please do not procrastinate, and leave it to 3-months before the deadline!

What should you do now?

  1. Review your chemical inventory. Identify if all the products are active and require an update.
  2. Once you identify the products that need updating, establish a budget. Whether you will do the updating yourself, need to contact the manufacturers to get updated documents, or outsource to ICC, it will take time and money.
  3. Establish a timeline. Do you want to be an early adopter, midway through the transition or towards the end? If you have many documents, you need to plan early. Consider the resources you have, or the lead-time for an outside provider like ICC.

Since the standardize phrases are different from Version 3 (USA) or Version 5 (Canada), your labels may need to be updated as well. You need to consider the timing of the label change-over, so it matches the SDS.

While you are doing your planning, ICC is as well. We are looking forward to working with everyone again. Contact us to discuss your Safety Data Sheet and Label needs. We look forward to developing a plan together.


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Karrie Ishmael, CDGP

Karrie Ishmael, CDGP

Karrie Ishmael has been with ICC since 1988. She has contributed to ICC's growth in various capacities, including customer service, sales, and marketing. In her current role as ICC's Senior Regulatory Expert and SDS author, Karrie conducts hazardous materials training classes in 49 CFR, IATA, IMDG, TDG along with OSHA and WHMIS hazard communication courses. When not training, she writes safety data sheets for customers to comply with North American and European requirements. She actively participates in many associations, including DGAC, COSTHA and is the former chair of SCHC’s OSHA Alliance Committee.

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