As a supplier of hazardous product when do I need to review my SDSs under WHMIS 2015 now that the 3-year rule is gone?
If you are a supplier, under WHMIS 2015, you need to ensure the SDS and label is accurate at the time of every sale and importation of the hazardous product.
This ensures ongoing quality assurance by suppliers and a greater level of production maintained for workers rather than a 3-year review and update under the old WHMIS 1988 system.
Do I need to provide and SDS with every shipment of a hazardous product if it is sent to the same customer and the SDS has not been updated?
An SDS is not required to be provided with every shipment of the same hazardous product sold to the exact same customer, as long as they have received the most up-to-date SDS available for that hazardous product and compliant with HPR.
You can refer to 5.11(b) of the Hazardous Products Regulations (HPR) for more information.
What is considered significant new data for an SDS to be updated?
An SDS and label for a hazardous product needs to be updated when “significant new data” becomes available for the product. Any data that changes the classification of a hazardous product or changes the ways to protect against the hazard(s) presented by the hazardous product.
How long do I have to update the SDS after significant new data is found on the hazardous product?
Suppliers have 90 to 180 days, from the date the new information becomes available to update their SDS and label to reflect the significant new data.
If there is a sale of importation the product during that period, the new information including the date the changes became available, must be communicated to the purchaser or to the importer.