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A big deadline is approaching in Canada -- Full compliance with WHMIS 2015 is expected by 1 December 2018 across all Canadian jurisdictions. On 28 March 2018, Health Canada emailed two fact sheets addressing compliance with the Hazardous Products Regulations, otherwise known as WHMIS 2015. The fact sheets published by Health Canada are titled “Employers Transitioning to WHMIS 2015” and “Distributors Transitioning to WHMIS 2015.”
Key deadlines
- 31 May 2018: Last date on which upstream manufacturers or importers can provide controlled products with WHMIS 1988 labels and safety data sheets (SDSs);
- 1 June to 31 August 2018: Last timeframe under which products compliant with WHMIS 1988 may be sold;
- 31 August 2018:
- Last date on which a distributor may sell controlled products with WHMIS 1988 labels and SDSs;
- Last date that an employer can recognize a controlled product as compliant under WHMIS 1988 requirements;
- 1 September 2018: All hazardous products sold, imported or used in Canadian workplaces must be compliant with WHMIS 2015; and
- 1 September to 30 November 2018: Last three months to fully transition into WHMIS 2015 compliance.
Health Canada advises companies to be proactive through the implementation of the WHMIS 2015 transition deadlines and requirements. Both fact sheets are accompanied by best practices to help smooth the transition. For instance, Health Canada recommends developing a transition plan, establishing and maintaining an accurate list of all hazardous products in the workplace and determining if labels and SDSs are either WHMIS 1988 (i.e. the Controlled Products Regulations or CPR) or WHMIS 2015 compliant, understanding hazard classification differences from one hazard communication regime to the next, updating training materials and processes, communicating and requesting WHMIS 2015 compliant SDSs and labels from suppliers, and safely disposing of hazardous products that will not be possible to bring to compliance.
If companies have questions on how to effectively transition to WHMIS 2015, please contact Verisk 3E’s regulatory experts (you may use 3EMonitorSupport@Verisk3E.com) and/or your assigned account executive. Verisk 3E will also host a webinar on WHMIS 2015 on 15 April 2018. To register, please visit our webpage.
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