Health Canada Hazardous Products Act Inspections

April 8, 2020

Health Canada Hazardous Products Act Inspection

Health Canada’s recent HPA/HPR inspections revealed significant gaps in Safety Data Sheet audits. Inspectors identified various instances of missing information, highlighting the need for improved compliance. In this blog, we have provided a summary of the types of information that are commonly found missing in safety data sheets.

  1. Hazardous Product Identification

    Missing synonyms for hazardous products on SDS

    For example: Missing synonyms for Benzene products: Benzene, benzol 
    Complete synonyms for Benzene product: Benzol; aromatic hydrocarbons (C6H6); cyclohexatriene

  2. Chemical Hazard Identification

    Variance between the HPR classification on the SDS vs. the official language of the HPR classification

    For example: SDS wording may be “Toxic to Reproduction – Category 2”, while HPR classification criteria wording would be: “Reproductive Toxicity – Category 2”.

    Incomplete hazard statements

    Hazard statements are missing from the SDS or are incomplete. Hazard statements should be specified for each hazard classification. 

    Incomplete precautionary statements

    For example: An incomplete precautionary statement P280 would be: “Wear protective gloves/protective clothing and eye protection” 
    While a complete precautionary statement P280 would be: “Wear nitrile protective gloves, nitrile protective clothing and chemical splash goggles.”

    Missing precautionary statement numbers

    For example: the SDS has a missing precautionary statement number: do NOT induce vomiting. A complete precautionary statement number would be:  P331 Do NOT induce vomiting.

    Missing specific instructions in precautionary statements

    For example: the SDS is missing specific instructions in the precautionary statement, such as: P230 Keep wetted with.
    A complete precautionary statement would be: P230 Keep wetted with water

    Providing information on specific hazards on SDS for a hazardous product

    The SDS should describe the nature of hazardous combustion products. These hazardous combustion products will include carbon monoxide, carbon dioxide, sulfur dioxide and soot.

    Missing information and specifics on hazards of the hazardous product

    Using the term "intermediate" to describe the use of a product is not specific enough as to what the product does, and it should list specific restrictions on use. 
    For example: "This product is used in industrial processes to reduce corrosion."

  3. Chemical Composition / Information on Ingredients

    Product or ingredient missing actual concentration range

    Concentration needs to be disclosed on SDS. For Benzene, Methylbenzene, Ethylbenzene, Dimethylbenzene and Polycyclic Aromatic Hydrocarbons an SDS variable is not acceptable. 
    Concentration ranges are to be reported as actual if possible.  There are limitations to how broad concentration ranges may be.

    Titles for Subcategories of SDS sections need to be complete

    For SDS Section 7: Handling and Storage, a subsection titled “Handling” is incomplete. The subsection should be titled “Precautions for safe handling”. The subcategories or fields have specific titles as specified by legislation.

  4. Exposure Controls and Personal Protection Equipment

    Missing and incomplete information on specifics of PPE

    Ensure accuracy and specifics of CSA standards are included with PPE recommendations. 

    Incomplete information: Industrial Eye and Face Protectors 
    Correct information:
    CSA Standard CAN/CSAZ94.3-92 Eye and Face Protection.

    OEL information not listed by province/territory in Canada

    List the hazardous ingredients OELs for various provinces / territories in Canada

    Check the accuracy and current information for OELs and classifications 

    OEL and classification information changes on a regular basis ensure the information on your SDS matches the regulatory guidelines for each jurisdiction listed. The source and validity of the OEL needs to be checked.

  5. Regulatory Information

    Remove all reference to MSDS and WHMIS 1988 on SDS

    Since the Controlled Products Act and Controlled Products Regulations are repealed any information on WHMIS 1988 and MSDS is no longer valid and needs to be repealed.

  6. Revision Dates on SDS

    Up to date expiry dates on the last revision of SDS

    For example, a last revision date of March 31, 2016 would need to be reviewed and updated.

    Use of clear language on SDSs 

    Terms like “vacated” is unclear for describing the Hydrogen Sulphide OEL. Or using the term “inhalable fraction and vapor” used for Diesel can be misleading.

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