WHMIS 2015: 4 top training questions from employers

By Jessie Callaghan, CCOHS

Canada's Workplace Hazardous Materials Information System (WHMIS) changed on February 11, 2015 to align with the Globally Harmonized System of Classification and Labelling of Chemicals (GHS). This new WHMIS is called "WHMIS 2015" and the original version is now referred to as "WHMIS 1988."

WHMIS 2015 questions have been pouring into the Canadian Centre for Occupational Health and Safety (CCOHS)'s free Safety InfoLine service. Here are employers' top questions:

1. When does WHMIS 2015 start for workplaces?

Implementation has already begun. Part of the confusion around the start time has to do with the way occupational health and safety (OH&S) laws work in Canada:

• Health Canada is responsible for WHMIS 2015 laws that spell out supplier requirements for classification, labels and data sheets for hazardous products in the workplace. These laws came into force in February 2015 and include a multi-year transition period.
• WHMIS laws pertaining to employer responsibilities and WHMIS education and training for workers - fall under federal/provincial/territorial OH&S legislation. Some jurisdictions have already updated their laws; others are in transition. The goal is to have all of the OH&S legislation updated by the end of 2016.

Even if the WHMIS 2015 legislation in your jurisdiction has not been enacted, employers can receive WHMIS 2015 products into the workplace.

2. Which WHMIS system should I train on now?

Some workplaces think they have until 2018 to start WHMIS 2015 education and training. Workers actually need to be educated and trained before they use a hazardous product with a WHMIS 2015 label and Safety Data Sheets (SDSs).

In addition, as long as there are products with WHMIS 1988 labels and Material Safety Data Sheet (MSDS)s in your workplace, workers will need to understand WHMIS 1988. Any new workers will need training on both systems.

Once your workplace no longer has products with WHMIS 1988 labels, you will no longer need to train on WHMIS 1988.

3. What are the requirements for WHMIS education and training?

• how WHMIS works
• hazard classes
• information found on the supplier label and workplace label, and what that information means
• information found on the SDS, and what that information means

WHMIS training refers to the site- and job-specific information that covers your workplace's procedures for storage, handling, safe use, disposal, emergencies, and spills. After completing WHMIS education and training, workers should understand

• the hazards of the product(s) they work with
• how to protect themselves from those hazards
• what to do in case of an emergency
• where to find more information about hazardous products

If conditions at the workplace change or if new information about a hazardous product becomes available, review the content of your WHMIS education and training program. In some jurisdictions, an annual WHMIS program review is required. This review does not necessarily mean that re-training is required.

The legislation does not prescribe a specific course to be taken. Employers can provide the education and training in-house or hire a consultant. There have been instances of aggressive WHMIS marketing. Warnings about this issue are posted on F/P/T websites and the national WHMIS portal.

4. What else do I need to do for WHMIS 2015?

During the transition from WHMIS 1988 to WHMIS 2015, you may receive hazardous products that comply with WHMIS 1988 or WHMIS 2015. Suppliers have the option of converting their products to WHMIS 2015 at the product level (i.e., one product at a time). Suppliers who are manufacturers or importers have until May 31, 2017 to convert to WHMIS 2015. Distributors have until May 31, 2018.

For a smooth transition:

• Update your inventory of hazardous products and safely dispose of those you no longer need.
• Keep track of those products complying with WHMIS 1988 and those converted to WHMIS 2015.
• Review the new WHMIS 2015 SDSs to see if any different hazard and/or control information is listed. If there are changes, then
  • educate and train your employees on the new hazards
  • review your hazard control and emergency response procedures and update if required
• Be aware that most employers have until November 30, 2018 to use up or phase out products that comply with WHMIS 1988. Note: there are some variations on this end of transition date (e.g., in federal OH&S jurisdictions).

How WSPS can help

• Ask us about WHMIS 1988 & WHMIS 2015 for Workers, a new onsite training course.
• Check out WSPS' online WHMIS resource page, where you'll find WHMIS training courses, self-paced training and e-courses, complimentary downloads and recent articles. More self-paced solutions coming soon!

Jessie Callaghan is Senior Technical Specialist Chemical, Canadian Centre for Occupational Health and Safety. CCOHS, Canada's national resource for the advancement of workplace health and safety, promotes the total well-being - physical, psychosocial and mental health - of workers in Canada by providing information, training, education and management systems and solutions that support health and safety programs and the prevention of injury and illness.