Are there any other forms of labels allowed?
In specific cases, yes. A WHMIS label can also be a mark, sign, stamp, sticker, seal, ticket, tag, or wrapper. It can be attached, imprinted, stencilled or embossed on the hazardous product or its container. Workers must be trained to be able to identify these alternate systems if they are used in the workplace.
Variations on the supplier label apply to specific situations such as:
- Bulk shipments - A labelling exemption exists for products sold without packaging.
- 100 mL or less - Exempt only from requirement to have precautionary or hazard statements on the label.
- 3mL or less - Where the label will interfere with normal use of the product, the product would be required to have a label that is durable and legible for transport and storage, but may be removed during use.
How does WHMIS 2015 apply to consumer products (e.g. cleaners)?
Consumer products are those products that can be purchased in a store and are generally intended to be used in the home. They often include cleaning products, adhesives, or lubricants. These products are labelled according to other legislation.
If consumer products are used in the ‘workplace’ i.e. at the University, then WHMIS 2015 requirements apply. The University’s chemical safety program includes both hazardous products regulated by WHMIS and any other products that a worker may be exposed to (which includes consumer products). Workers must still receive education and training for safe use of these products.
Why do some products (e.g. cleaners, disinfectants) have a safety data sheet but don’t have WHMIS 2015 labels on the container?
If the product is not regulated WHMIS legislation, then WHMIS 2015 labels are not required. The product may be regulated under different legislation (e.g. radioactive materials, consumer products).
SDSs provide more detailed hazard information about the product than the label. They are an important resource for workplaces and workers to provide information about the product(s) used and are commonly included from the supplier as a best practice, even if it’s not a regulatory requirement.
How does WHMIS 2015 apply to laboratory samples?
If a hazardous product is produced in a laboratory, the employer is exempt from the requirements of workplace labels if the hazardous product:
a) is intended by the employer solely for the use, analysis, testing or evaluation for research and development;
b) is not removed from the laboratory; and
c) is clearly identified with a form of identification visible to workers at the workplace and worker education and training is provided.
This combination of identification and education must enable laboratory workers to identify the product and obtain information for the safe use, storage and handling of the product. This is accomplished through WHMIS training and the use of consistent identification for products used in a laboratory. Laboratory supervisors will inform employees of the identification standards in their work areas.
Nonetheless, once such hazardous products are ready to be disposed of, they require appropriate hazardous waste labels.
Do Safety Data Sheets (SDS) expire?
No. However, suppliers must update SDS whenever new information is available. It is recommended that each time a product is ordered the supplier website be checked to determine if the SDS on hand is the most up-to-date version available.