Health Canada Hazardous Products Act Inspections
April 8, 2020
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.
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
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."
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.
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.
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.
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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