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WHMIS stands for the Workplace Hazardous Materials Information System. It is a comprehensive system for providing health and safety information on hazardous products intended for use, handling, or storage in Canadian workplaces.
A WHMIS program ensures that the information about hazardous products is effectively communicated to workers. Effective communication of information means that workers understand the WHMIS system, know the hazards of the products they work with, know and apply the safe work procedures specific to their jobs and tasks, and know how to respond in an emergency.
Please refer to the following OSH Answers documents for information about WHMIS 2015:
The changes to the federal Hazardous Products Act (HPA) and the new Hazardous Products Regulations (HPR) from Health Canada set out the supplier duties within Canada for WHMIS 2015. These federal laws apply to suppliers, importers, and distributors of hazardous products intended for use, handling, or storage in Canadian workplaces.
The Hazardous Products Regulations set out specific hazard classification criteria for each hazard class included in WHMIS 2015. If a product covered by the Hazardous Products Act meets the criteria to be included in one or more of the WHMIS 2015 hazard classes, it is referred to as a "hazardous product". All hazardous products used, handled, or stored in the workplace are covered by the WHMIS regulations, and a WHMIS program including education and training must be in place.
Each jurisdiction (that is – each province and territory as well as where occupational health and safety laws govern federal employees and those businesses that follow federal legislation) also has their own individual WHMIS regulations. While based on the federal requirements, the jurisdictional occupational health and safety (OH&S) legislation covers how the WHMIS system is implemented within the workplace and is related to the employer duties, education and training, workplace labels, and any other workplace requirements.
The WHMIS program should be developed by the employer, in consultation with the health and safety committee or representative.
As an employer, your responsibilities may include to:
As a worker, your responsibilities may include to:
Employers are ultimately responsible for the WHMIS program. The health and safety committee (or representative) helps by making sure workers have the right to participate. Committees may have different roles in different workplaces. For example, some committees may be involved with the development of the WHMIS program, the development of the education and training, or with monitoring and auditing. The committee may find concerns during their inspections, or may make suggestions or follow up about solutions.
The main elements of a WHMIS program are:
The employer has the responsibility to know, at all times, what hazardous products are in the workplace and in what amount. A good chemical or product inventory system and corresponding procurement procedures are essential. For example, part of the procurement process for WHMIS is to make sure the supplier has provided the correct and most current labels and SDSs for hazardous products.
It is usually the responsibility of the person in charge of procurement to develop and maintain the inventory. Product inventories will help to:
See the OSH Answers document Chemical Inventory for more information.
B. Hazard Identification
When a product is brought into the workplace, it is essential to know the hazards of the product. A summary of the hazards is found on the product's SDS. Review the SDS to make sure the information is complete and accurate. You may need additional information from other sources (such as journals, text books, local jurisdictions, etc.). Knowing the hazards will help you make informed decisions about use, storage, disposal, education, training, and emergency response.
Under WHMIS, employers who produce hazardous products for use in their own workplaces have the duty to assess the hazards, classify the hazards of the products, and provide proper labels and SDSs. Under general occupational health and safety laws, employers are also responsible for safe storage and use of hazardous products.
Make sure all hazardous products are labelled appropriately, and that SDSs are available. Include WHMIS requirements on your inspection checklist, such as:
In addition to regular inspections, it may be advisable to have a specific WHMIS inspection at least once a year.
See the OSH Answers document for information on effective workplace inspections.
D. Worker Education and Training
All workers who work with a hazardous product (or who may be exposed to a hazardous product) must learn about the hazards associated with these products. The hazard information should include the information received from the supplier, as well as any other information that the employer is aware of about the use, storage, and handling of each product.
Education and training can be thought of as two separate parts.
Examples of topics that should be covered during education and training include:
Workers should be able to answer these questions for every hazardous product they work with:
E. Review and Evaluation
The WHMIS program should be reviewed at least annually or more often if there are changes in the working conditions. Is the frequency of conducting the chemical inventory, SDS inventory, and label inspection adequate? Are the floor plans up-to-date?
This review would also determine if the current WHMIS education and training is covering all hazardous products that workers may be exposed to, and whether the workers are adequately informed and instructed about these hazards. Refresher education and training is generally required:
Employers must periodically evaluate workers' knowledge using written tests, practical demonstrations, and other suitable means.
F. Document and Record Keeping
Documents and records help the employer to show due diligence and compliance. How long these documents and records must be kept may vary by jurisdiction.
Documents are a “medium” that contains information. Examples of documents may include the actual education and training material, inventory lists, SDS, label, or the inspection checklist forms. Documents should be dated, and indicate when there is a revision.
Records are documents that state the result achieved or provide evidence of activities performed. Examples of records include inspection results, steps taken to control hazards, attendance at sessions, courses completed, survey results, or annual reviews.
Suppliers must prepare and maintain documents, including copies of labels and SDS, as well as sales and purchasing information, and provide these documents to the Minister or to an inspector upon request. Suppliers must maintain their documents for six years or for any other period that may be prescribed. Employers may also need to keep SDSs on record for a set time period (e.g., Manitoba requires employers keep SDSs on record for up to 30 years).
Employers who prepare supplier labels and SDSs for products produced and used in the workplace would need to follow similar requirements.
The following is an example of a WHMIS program implementation checklist. Adapt this checklist for your workplace's needs.
|Table 1 |
WHMIS Program Checklist
|Activity||Time Needed||Assigned To||Date Completed|
|Assign responsibility for WHMIS implementation |
|Establish an inventory of all products|
|Determine which products (used or produced) are classified as hazardous products under WHMIS.|
|WHMIS lables and SDSs|
|Get SDSs for hazardous products already in the workplace.|
|Develop a process for procurement (requesting and receiving) of SDSs with new purchases.|
|Develop a method to make the most current SDSs readily available to workers.|
|Develop a process to ensure that supplier labels are on (or available) for all new hazardous products received.|
|Develop a process to create and provide workplace labels and other means of identification where required.|
|Identify and evaluate the hazards of hazardous products in the workplace (for example, consider the quantities to be used and stored, and the work processes where these products are used).|
|Based on the hazard evaluation, determine where the following workplace controls may need to be established or upgraded: |
|Review first aid procedures, and upgrade them if required.|
|Review spill control procedures, and upgrade them if required.|
|Review firefighting procedures, and upgrade them if required.|
|Notify the local fire department of the location, types, and quantities of hazardous products used and stored.|
|Worker education and training|
|Complete the WHMIS Education and Training Checklist |
|Evaluate WHMIS program|
|Establish periodic review process for the following: |
|WHMIS Education and Training|
Sample WHMIS Program Checklist is adapted from WorkSafeBC and WorkSafeNB.