This session will provide a quick overview of the requirements for the Canadian Safety Data Sheet (SDS). Current Canadian SDSs must comply with the Hazardous Products Regulations (HPR) and in particular, GHS Version 5 statements. If you manufacture or sell product(s) in other countries, you must have an SDS that is compliant for the country you are looking to sell to. Sending your US SDS and simply translating into Canadian French does not mean that your product SDS is compliant here - a fact that is often overlooked by many.

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Can I Use My International SDS in Canada?
www.delltech.com
519-858-5021

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Kirsten Alcock B.Sc. Hons
Manager, Product Safety Group
kirsten@delltech.com
519.858.5074
Ivy Tang B.Sc.
Product Safety Specialist
itang@delltech.com
519.858.5021 ext 2043

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Dell Tech Laboratories Ltd.
Dell Tech Services
• US/CAN consumer labeling consultation (CCCR and CPSC)
• Claims support and Performance Testing
• Green Seal, EcoLogo, EPA Safer Choice
• US/CAN GHS compliant SDSs
• E-liquids and Vaping device regulations
• Cosmetic Notifications, Pesticide registration, Medical Device labeling, Fertilizers
• Non-prescription Drugs and NHP regulations
• Translation of Technical Documents
• Transportation Consulting

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Disclaimer
The information provided in this webinar is not legal advice. If you are uncertain about the
interpretation of the WHMIS regulations, please contact Health Canada directly. If you are
concerned about confidentiality, Dell Tech can contact these agencies on your behalf.
Health Canada
Address Locator 0900C2
Ottawa, Ontario
K1A 0K9
hc.whmis-simdut.sc@canada.ca
www.whmis.gc.ca
613-957-2991 or 1 866-225-0709

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Outline of Presentation
1. What is an SDS?
2. What is GHS?
3. Can I use my international SDS in Canada?
4. What is unique to a Canadian SDS?
5. Different Sections within an SDS
6. Future Changes to WHMIS in Canada
7. Question Period

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What is an SDS
A Safety Data Sheet discloses hazard information of a product, including health and
physical effects, chemical composition, storage and handling, first aid measures,
and other information important to the occupational health and safety of the
worker.

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The Globally Harmonized System of Classification and
Labelling of Chemicals (GHS) is an international standard
for hazardous material classification.
Each country that is interested in adopting the GHS can
adopt varying degrees - they can pick and choose which
pieces to implement into their own regulations. Each
country is responsible for its own enforcement.
There are more than 65 countries that have adopted the
GHS or are in the process of adopting.
As a result of this, one SDS CANNOT be used worldwide!
There is nothing Global about the GHS.
Canada and the US adopted the GHS at different times
which has lead to some confusion about what can be used
within each country.

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Different countries adopted different versions of the GHS. For example, our
largest trading partner, the USA officially adopted the 3rd Revised Edition of the
UN GHS in 2012, hence HazCom 2012.
Canada adopted the 5th Revised Edition of UN GHS in 2015 – hence WHMIS 2015
As a result of adopting the GHS in different time periods, the US is on an earlier
version of the GHS than Canada.
The EU is aligned with portions of the 6th and 7th Revised Editions of UN GHS.
Canada and the US are looking to move forward and align with Revision 7.

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Can I Use My International SDS in Canada?
This is one of the most common questions we receive from our clients.
The answer?
It depends.
There are requirements that must be on a Canadian SDS to be used here.

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What is Unique to a Canadian SDS?
• SDSs for use in Canada must follow Schedule 1 of the Hazardous Products
Regulations
• Schedule 1: Information Elements on Safety Data Sheet
• This schedule provides all the required headings in Column 1 along with the
Specific Information Elements in Column 2
• The appropriate French translations are provided by Health Canada
https://laws-lois.justice.gc.ca/eng/regulations/sor-2015-17/page-24.html#h-820068

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Section 1: Identification
• A Canadian SDS has 5 specific information elements in this section
• One of the main issues we find is the Canadian address information is missing
from the international SDS.
• Initial Supplier Identifier is required. Has this been listed on your SDS?
• Can the Emergency Telephone Number even be reached from Canada?

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Section 2: Hazard Identification
• Canada has some unique classifications that are not listed on a US SDS:
HHNOC, PHNOC
• Canada uses GHS Version 5 statements whereas the US is on GHS Version 3.
Canada MUST use these statements and cannot go back to earlier versions of
the GHS.

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Ex. CORROSIVE TO METALS
US: Keep only in original container. Absorb spillage to prevent
material damage. Store in corrosive resistant/…container with
resistant inner liner.
CANADA: Keep only in original packaging. Absorb spillage to
prevent material-damage. Store in a corrosion
resistant/…container with resistant inner liner.

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https://www.osha.gov/OshDoc/Directive_pdf/CPL_02-02-079.pdf

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Section 3: Composition/Information on
Ingredients
• Canada requires the chemical name, CAS number and weight percentage (Or
range provided by Health Canada)

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NON-COMPLIANCES!
Ranges that start with 0
Claiming Trade Secret for CAS without applying for one

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• One cannot claim trade secret for CAS OR Chemical name without
registration with the HMIRA
• Receive many SDSs from the US where the claim Trade Secret is being made
for CAS and this is not permitted within Canada

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https://www.canada.ca/en/health-canada/services/environmental-workplace-health/occupational-health-safety/workplace-
hazardous-materials-information-system/claims-exemption-under-hmira/claims-exemption/filing-claim/structure-claim-exemption-
under-hmira.html

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Section 8: Exposure Controls/Personal
Protection
Different provinces have Occupational Exposure Limits
that need to be on the SDS within this section.
Ex. Ontario has a separate list for OEL’s.
https://www.labour.gov.on.ca/english/hs/pubs/oel_table.php
Determine which province you are selling to and ensure the OEL’s are present. Many
European SDS contain the OEL’s for different countries but not those that are
required for Canada. Ensure that you have the provincial ones if they exist.

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Section 14: Transport Information
• Did you include the information for Transportation within Canada?
• Canada follows the Transportation of Dangerous Goods.
• Although similar, there are NA numbers within the DOT that are not applicable
here in Canada. Ex. NA1993
• When you are shipping your product within Canada, the shippers will require
proper shipping instructions and placards in accordance with our regulations:
https://tc.canada.ca/en/corporate-services/acts-regulations/list-
regulations/transportation-dangerous-goods-regulations
• Our labels placards are different from countries such as the US.
• IATA and IMDG for example have different requirements as well. Ensure you are
using these appropriately.

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CANADA
USA

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Section 15: Regulatory Information
Did you include the information on our inventory lists: DSL, NDSL
• We find this is a section that is missing and MUST be known before
importation
• The list can be found here:
https://pollution-waste.canada.ca/substances-search/Substance
• If a chemical is not listed, the amount coming in must be tracked in
accordance with our New Substance Notification Regulations

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Section 16: Other information
Is your SDS 3 years old?
Although federally the three year renewal period was abolished, there are
some provinces that still require the SDS to be within 3 years. One must
determine which provinces you plan on selling your product to before
importation of an expired SDS.

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GHS Revision 7
• Both OSHA and Health Canada have issued proposals to align with GHS
Revision 7.
• Public comment closes May 19th for both countries
• Proposed changes include:
– New hazard category and elements for non-flammable aerosols (Cat 3)
– Potential Addition of ranges for US SDSs
– Updated definitions of terms
– Additional or revised precautionary statements for categories/subcategories

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Links for further information on GHS Version 7
• https://public-inspection.federalregister.gov/2020-28987.pdf
• https://www.regulations.gov/
• https://gazette.gc.ca/rp-pr/p1/2020/2020-12-19/html/reg4-eng.html

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Thank You!
1331 Hyde Park Road, Unit #3
London, ON
N6H 5M5
www.delltech.com

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Kirsten Alcock B.Sc. Hons
Manager, Product Safety Group
kirsten@delltech.com
519.858.5074
Ivy Tang B.Sc.
Product Safety Specialist
itang@delltech.com
519.858.5021 ext 2043