Clearing up confusion on SDSs and the 3-year expiration rule
November 13, 2018
Do Safety Data Sheets Expire?
WHMIS 2015 is in full effect as of Dec. 1, 2018, and with the 3-year expiration rule changing on SDSs, it is causing some confusion if workplaces need to keep reviewing their SDS inventory on a regular basis.
Going forward, WHMIS 2015 requires suppliers to continuously review and update their SDSs if changes to the product occur. Suppliers have a duty to communicate this to customers with the most current SDS for the hazardous product at the point of sale. This change is supposed to improve upon the 3-year rule.
What Can Prompt a Change in an SDS?
A new chemical composition in the manufacturing of a product can introduce new hazards. Recent health studies could reveal increased hazards of a substance. Transportation and OHS regulations continuously change prompting SDS revisions for some products. Adoption of new GHS revision standards (i.e. USA is currently at Rev.4 and adoption Rev.7 in Feb 2019) can introduce new classifications.
What Are the Employer Responsibilities Under WHMIS?
As an employer, WHMIS requirements are governed under provincial, territorial and federal occupational safety and health laws and regulations. Employers need to ensure SDSs are available to workers, hazardous products are properly labelled, and workers receive education and training on the safe handling, storage and disposal of those hazardous products in the workplace. The disappearance of the 3-year rule does not mean you can let the dust accumulate on your SDS. The intention is that review is a continuous process of assessing the hazards at your worksite.
SDS Expiry Dates by Province
Depending on your provincial or territorial jurisdiction, some employers have obligations under WHMIS 2015 to ensure SDSs for hazardous products in your workplace are not more than three years old. BC, Saskatchewan, the Northwest Territories and Nunavut are jurisdictions with these workplace expectations for their employers. This means you will need to check if anything significant has changed on the SDS and record that you have done the review.
Chemscape provides this level of service and compliance for employers by checking with manufacturers/suppliers for SDS updates on a 3-year cycle and date mark the SDS in the system. Get in touch with the team at Chemscape to learn more about our SDS Management Solutions.