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Joint Health Canada and United States Occupational Safety and Health Administration Guidance

Joint Health Canada and United States Occupational Safety and Health Administration Guidance

When creating a safety data sheets (SDS), whether it is for Canada or United States, both regulations consider the Globally Harmonized System of Classification and Labelling of Chemicals (GHS). This helps regulatory bodies coordinate regulations so that hazards in both countries are understood and have similar meanings. Basically, apples are apples and oranges are oranges. Even though that was the intention for GHS, everyone knows this is not the case. Every regulatory body has made minor variances to accommodate their own regulations based on scientific data and there understanding on how to manage chemicals. But that is another topic.

The 2016-17 Regulatory Cooperation Council (RCC) decided to reduce these differences by developing a joint guidance on compliance for classification and labelling for hazards not mention in GHS. They fall under 3 headers “Hazards Not Otherwise Classified” (HNOC) and “Physical Hazards Not Otherwise Classified” (PHNOC) and “Health Hazards Not Otherwise Classified” (HHNOC). In Canada, they incorporated 2 of these headers, HHNOC and PHNOC. In the United States they incorporated 1 header, HNOC.

In this joint guidance document, it explains how to handle classifications and each header is defined by its own regulatory body. For example, in the United States OSHA defines an HNOC as “an adverse physical or health effect identified through evaluation of scientific evidence during the classification process that does not meet the specified criteria for the physical and health hazard classes….” Basically, what this means is an Acute Toxicity Category 5 Hazard would be considered a HNOC whereas an Acute Toxicity Hazard Category 4 would not. Simply because the Acute Toxicity Hazard Category 4 is incorporated already to Occupational Safety and Health Administration (OSHA). In Canada PHNOCs and HHNOCs are handled separately and cover any hazard that is not covered already in the Hazardous Products Regulations (HPR). OSHA does not differentiate.

The joint guidance document also explains how to handle labelling and classification when dealing with Canada and United States based on the small differences. For example, OSHA does not consider HNOC to be mandatory on labelling, whereas HPR does require labelling for HHNOC and PHNOC. Another example is if an exclamation pictogram is required for a HHNOC or a PHNOC then it is only required once. It does not have to show more than once if it coincides with additional HPR pictograms. There are several other recommendations in this joint guidance developed by the RCC. Let ICC help you classify your SDS for full compliance to either OSHA or HPR.

Let ICC Compliance help you classify your safety data sheets for full compliance to either OSHA or HPR. Our team of experts is just a call away for our customers at 855.734.5469 or send us an email, we’re happy to help.

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Rick Mastroianni

Rick Mastroianni joined the ICC Regulatory Experts team in 2022. He has many years of experience as an SDS Author, including preparing regulatory-compliant label text for product applications. His regulatory knowledge includes OSHA, WHMIS, CCCR, and EU CLP. Currently, his primary focus with our Regulatory Experts team is the creation of safety data sheets and labels for the different jurisdictions in North America and Europe.

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