Canada - GHS Status

Canada has recently (January 2023) started the transition to the Seventh revised edition of the Globally Harmonized System of Classification and Labelling of Chemicals (GHS7). The transition will take place over the next three years to allow manufacturers and importers to implement the updates.

Canada has adopted the Workplace Hazardous Materials Information System (WHMIS) as its national hazard communication standard. Canada adopts the Globally Harmonized System for Classification and Labelling of Chemicals (GHS) by amending the Hazardous Products Act (HPA) and publishing the Hazardous Products Regulations (HPR) for hazardous products in the workplace. Amendments to the HPR and Schedule 2 of the HPA were published on 4 January 2023 to align with the seventh revised edition of GHS (GHS 7). These amendments came into force on 15 December 2022, and provide for a transitional period of three years, which will end on 14 December 2025.

Before transitioning to the GHS7, Canada used the fifth revised edition of the GHS to classify hazardous chemicals.

Local Adaptation of GHS

The following GHS hazard categories are exempt from classification under the Canadian WHMIS:

• Explosives, all categories
• Desensitized Explosives, all categories
• Acute Toxicity, Category 5
• Skin Corrosion/Irritation, Category 3
• Aspiration Hazard, Category 2

The environmental hazard classes are non-mandatory in Canada and include the following:

• Hazardous to the aquatic environment (acute and chronic toxicity), all categories
• Hazardous to the ozone layer

In addition to the standard GHS hazard classes, Canada has introduced the following additional hazard classes:

• Combustible dust
• Simple asphyxiants
• Biohazardous infectious materials
• Hazard not otherwise classified (HNOC)

GHS Labelling Requirement

According to the WHMIS standard, the label of hazardous chemicals must be prepared according to the provisions of GHS 7. The label must be in both English and French. It must be legible as well as durable and contain the following elements:

• Product identifier: the brand name, chemical name, common name, generic name or trade name of the hazardous product.
• Hazard pictogram consisting of a distinctive red square set on one of its points with a black hazard symbol on a white background.
• Signal word.
• Hazard statement(s).
• Precautionary statement(s).
• Initial supplier identifier: the name, address, and phone number of the Canadian manufacturer or Canadian importer.
• Supplemental label information may be required depending on the products classification. Labels for mixtures containing compounds of unknown toxicity in quantities greater than 1%. must include a statement of the percentage of the ingredient(s) of unknown toxicity. Supplemental information on precautionary actions, hazards not yet covered by the GHS, the physical state of a product, or the route of exposure may also be included on the labels.

Suppliers and importers are required to update a label within 180 days of becoming aware of any ‘significant new data’.

Conditions for exemption from labelling of hazardous products

• If the inner container label is visible and readable through the outer container, or if the outer container has a label that complies with the Transportation of Dangerous Goods Regulations (TDG Regulations), then the outer container for hazardous materials packaged in multi-containers does not require a WHMIS label.
• Small volume containers: Small volume containers (100 ml or less) are exempt from the requirement to carry precautionary statements or hazard statements on the label.
• Small volume containers (3 ml or less): If the label prevents the product from being used as intended, a label that is durable and legible only while in transport and storage is required.
• Bulk shipments and unpackaged hazardous substances are exempt from labelling requirements. This exemption also applies to hazardous products sold without packaging. All label information must be provided in sections 1 and 2 of the SDS.

Safety Data Sheet

Manufactures and suppliers of hazardous substances are required under the Hazardous Products Act (HPA) and the Hazardous Products Regulations (HPR) to provide updated information regarding the substance in the form of a Safety Data Sheet (SDS). The format and content of the SDS are set by the HPR. A Canadian SDS must:

• Be in both English and French.
• Contain the 16 standard sections (sections 12 to 15 only require headings to be present, no information needs to be provided in these sections).
• Be revised every 3 years.
• Be updated by suppliers and importers with new data within 90 days.
• Include the name and contact information of the Canadian manufacturer or importer.
• Include an emergency telephone number for information in the event of an accident or emergency situations.
• Include a pictogram (no specific format or size is required).

GHS in Work-Environment

The implementation of GHS in the work-environment is the responsibility of Canada's national hazard communication standard, i.e. the Workplace Hazardous Materials Information System (WHMIS). The WHMIS regulations have been implemented in all jurisdictions in Canada. Furthermore, the WHMIS provides regulation and information on hazardous substances intended for use, handling, or storage in Canadian workplaces. Since 2018 all suppliers of hazardous substances to workplaces, and employers which use hazardous substances in their workplaces, are required to be in compliance with WHMIS 2015.

GHS in Transportation

In Canada, the national transport of dangerous goods is regulated under the Transportation of Dangerous Goods Act of 1992 (TDG Act), which sets the ground for the transport of dangerous substances in Canada.  Moreover, the Canadian government is planning to update and align the Canadian regulation with international trade in 2023. This update would focus on improving and reducing Canada’s technical standards and regulations, bringing it to the newest UN update.