Health Canada Hazardous Products Act Inspections

April 8, 2020

Health Canada Hazardous Products Act Inspection

Recent provincial HPA/HPR inspections on chemical suppliers by Health Canada have focused on Safety Data Sheet audits.  Included below is some observations on missing information on SDSs made by inspectors:

  1. Hazardous Product Identification

    Missing synonyms for hazardous products on SDS

    Missing synonyms for Benzene product: 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

    SDS wording: “Toxic to Reproduction – Category 2”.
    HPR classification criteria wording: “Reproductive Toxicity – Category 2”.

    Incomplete hazard statements

    Hazard statements are missing off the SDS or incomplete. Hazard statements are specified for each hazard classification. 

    Incomplete precautionary statements

    Incomplete precautionary statement P280: “Wear protective gloves/protective clothing and eye protection” 
    Complete precautionary statement P280: “Wear nitrile protective gloves, nitrile protective clothing and chemical splash goggles.”

    Missing precautionary statement numbers

    missing precautionary statement number: do NOT induce vomiting
    complete precautionary statement:  P331 Do NOT induce vomiting

    Missing specific instructions in precautionary statements

    missing specific instructions in precautionary statement: P230 Keep wetted with…
    complete precautionary statement: P230 Keep wetted with water

    Providing information on specific hazards on SDS for a hazardous product

    i.e. Describe the nature of hazard of hazardous combustion products. 
    Hazardous combustion products will include carbon monoxide, carbon dioxide, sulfur dioxide and soot.

    Missing information and specifics on hazards of the hazardous product

    i.e. 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. 
    This product is used in industrial processes to reduce corrosion.

  3. Chemical Composition / Information on Ingredients

    Product or ingredient missing actual concentration range

    Concentration need to be disclosed on SDS. For Benzene, Methylbenzene, Ethylbenzene, Dimethylbenzene and Polycyclic Aromatic Hydrocarbons 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: 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

    i.e. last revision date of March 31, 2016 would need to be reviewed and updated.

    Use of clear language on SDSs 

    i.e. 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.