OSHA requires chemical manufacturers, distributors, importers, and employers to record this new information and communicate it. When you become newly aware of this information, you must revise the labels. Labels must happen within 6 months of acquiring the new information.
Any chemical shipped after that 6-month timeframe must contain the new information. SDS should be modified in 3 months. In this case, the manufacturer or importer must add this new information to the SDS and labels. This must occur before the chemical is introduced to the workplace again. How often should safety data sheets be updated? And how often do MSDS need to be replaced?
When preparing the sheets, you must ensure the information accurately reflects the scientific evidence behind the hazard classification. A Safety Data Sheet shall be reviewed at least every 3 years. Records of SDS updates such as content, date, and version revision, shall be kept for 3 years. Suppliers and employers must update SDSs and labels within 6 months since new information concerning a chemical is made available.
Suppliers should also periodically review label and SDSs every 5 years even if no new information has been provided. Ref: GHS in Singapore. We do not provide consultancy services. If you have questions or need any help, please contact our sponsor. You may also find an expert in CSP business directory below. We had to count the sheets to provide this overview. A different customer had paper sheets in a binder, but were not tracking date nor type of sheet.
The short is answer is you still need to update your safety data sheets. But like anything you are trying to manage if you want to ensure you have up-to-date sheets you will need to have some measure of performance. Please feel free to contact us if you have any more questions about the requirements to update your safety data sheets. By Lisa Hallsworth. Survey for Virtual Chemical Safety Education. By Rob Hallsworth. Millions of Canadians are exposed to chemical hazards in the workplace every year.
Click here to see our previous newsletters. As a general principle, making copies of SDS s whether paper or electronic readily available to workers who may be exposed to a hazardous product means that they must be located close to the workers and accessible during each shift. It would not be acceptable, for example, to keep safety data sheets, or a computer terminal for accessing safety data sheets, in an office that is remote from the shop floor or that is locked during the night shift.
The employer is not required to provide paper copies of SDS s. Members of the public have access to SDS s through their local medical officer of health section An employer must ensure that a worker who works with, or may be exposed to a hazardous product is informed about all hazard information the supplier has provided about the product. In general, this means the information on supplier labels and safety data sheets, but it can also include other information such as letters from the supplier in response to inquiries from the employer.
Similarly, if a hazardous product is produced in the workplace, the employer must ensure every worker who works with or may be exposed to the product is informed about all hazard information the employer is or ought to be aware of concerning its use, handling and storage subsection 6 2 , WHMIS Reg. To understand what hazard information the employer is or ought to be aware of the following are considered to be sources of occupational health and safety information that the employer should know about:.
A worker education program on hazardous materials must include instruction on the following subsection 7 1 , WHMIS Reg. Under the OHSA , an employer has a general duty to ensure a worker exposed or likely to be exposed to a hazardous product receives and participates in prescribed instruction and training subsection 42 1 , OHSA. The following points are intended to guide workplace parties and inspectors when determining which workers should participate in instruction and training:.
In developing and implementing the program, the employer must consult the joint health and safety committee or health and safety representative subsection 42 2 , OHSA. There is no specific requirement to keep records of WHMIS training, but an employer may wish to do so to be able to demonstrate to an inspector that workers have received appropriate information and instruction.
The employer must ensure, so far as is reasonably practicable, that the WHMIS education program results in workers being able to use the information to protect their health and safety subsection 7 3 , WHMIS Reg. It is left to the individual employer to devise the means to determine that a worker has been properly trained and instructed. For example, the employer may ask workers to take some form of written or oral test, or to participate in a practical demonstration of their knowledge.
Subsection 7 3 of the WHMIS Regulation includes the phrase so far as is reasonably practicable because it is recognized the employer may have difficulty at times determining with certainty what workers have learned, due either to language or literacy problems.
In general, workers should be able to answer the following questions for every hazardous product they use. At least once a year, the employer must review the training and instruction provided to workers, in consultation with the joint health and safety committee or health and safety representative of the workplace, if any subsection 42 3 , OHSA. This review must take place more often if:.
A change in circumstances could include a change in workplace conditions, or a hazardous product new to the workplace, or new hazard information about a product already in use. The requirement for a review of the education program does not necessarily mean that workers will need retraining.
An employer may demonstrate that reviews have been conducted in various ways, for example, through the keeping of records, or in the minutes of a joint health and safety committee meeting. Therefore, workers should be paid at their regular or premium rate in accordance with their collective agreement, if any, or the Employment Standards Act, To do this assessment, the employer must go through the same steps that a supplier goes through when classifying products intended for sale to other workplaces.
The employer should:. If the material meets the criteria of any category or sub-category of a WHMIS hazard class, it is a hazardous product. A copy of it must be available to workers and given to the joint health and safety committee or health and safety representative if any , or else it must be given to a representative of the workers if there is no joint health and safety committee or health and safety representative subsection 39 2 , OHSA.
Assistance to the employer to properly assess and classify hazardous products is available from private consultants and from the Canadian Centre for Occupational Health and Safety. The WHMIS Regulation provides complete or partial exemptions for various hazardous products, including hazardous waste.
While WHMIS label and SDS requirements do not apply to these products, if any of them are used, handled or stored at a workplace, the employer is still required to train workers who are or may be exposed. Various laws govern the sale and use of these products and include labelling and other information requirements.
Worker training should result in workers being able to understand the existing product labels and information and using the products safely. Hazardous waste is defined as a hazardous product that is acquired or generated for recycling or recovery or is intended for disposal subsection 1 1 , WHMIS Reg.
An employer is required to ensure the safe storage and handling of hazardous waste through a combination of identification and worker education subsection 4 4 , WHMIS Reg. Any means of container identification would be considered acceptable, as long as it is understood by the workers.
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