Single Packaging
Change Notice: PK-1GRPC

Dear Valued Customer,

In an effort to continuously improve the quality and performance of our UN packaging, we occasionally must make changes to the specifications and usage instructions. This notice is to inform you that the following changes have been made to PK-1GRPC.

  1. The Box in this kit will be changing from the BX-115 to BX-115N once current stock runs out. This change adds 3/8” depth to the box making the dimensions of the new box 6.3125″ x 6.3125”x 12.375”.
  2. The clear tape required for closure of this packaging has changed from 3M #305 48mm wide clear tape to 3M #375 48mm wide clear tape. This change to a stronger tape caused the box to perform better in drop tests, resulting in a more secure packaging.

Click here to view our packing instruction downloads »

If you have any questions or concerns, please contact our customer relations center in the US at 888‐442‐9628 or in Canada at 888‐977‐4834.

Thank you,
Michael S. Zendano
Packaging Specialist

Safety Data Sheets (SDS)
How to Read a Safety Data Sheet (SDS)

Hockey Goalie

Safety Data Sheets Defend Your Employees

Chemical Safety in the workplace can be a topic most employers would like to avoid. However, not only is it vital to the employee’s and community’s wellbeing, it is a requirement by law. In comes Safety Data Sheets (SDS) to the rescue! If Chemical safety in the workplace was a hockey team, training, storage requirements, purchasing, disposal, and inventory requirements would make up the Center, Forwards, and Defense, leaving the cornerstone of any hockey team, the Goalie to represent Safety Data Sheets (SDS). OSHA Standard 1910.1200 (g)(8) states that The employer shall maintain in the workplace copies of the required safety data sheets for each hazardous chemical, and shall ensure that they are readily accessible during each work shift to employees when they are in their work area(s). However without correct understanding of Safety Data Sheets, it would be like having an injured goalie in your starting lineup. Below are some tips for reading a 16-section format SDS.

Section 1. Identification:

Identifies the chemical on the SDS and displays the recommended uses. This section also provides contact information of the manufacturer as well as an emergency phone number.

Section 2. Hazard Identification:

The purpose of this section is to identify various hazards the chemical presents as well as any warning information. This includes Hazard class, signal words, pictograms and hazard statements.

Section 3. Composition/Information on Ingredients:

Displays the ingredients contained in the product. It gives the concentration of each ingredient that is classified as a health hazard.

Section 4. First Aid Measures:

Describes any first aid that should be given by untrained responders if there is exposure to the chemical. This includes symptoms and recommended immediate medical care.

Section 5: Fire-Fighting Measures:

Gives recommendations of how to handle a fire that is caused by this chemical. This includes extinguishing equipment, protective equipment, and information on other hazards that can arise if the chemical burns.

Section 6: Accidental Release Measures:

Lays out the recommended response to spills, leaks, or releases of the chemical. This includes cleanup practices, emergency procedures for evacuation, protective equipment, and spill volume.

Section 7: Handling and Storage:

Outlines the procedure for safe storage of the chemical. This includes ventilation requirements if applicable.

Section 8: Exposure Controls/Personal Protection:

Recommends the specific types of personal protection such as gloves, respirators, or glasses when using the chemical referenced in the SDS.

Section 9: Physical and Chemical Properties:

This section identifies the appearance, odor, density, flammability or explosive limits, as well as other physical properties of the chemical.

Section 10: Stability and Reactivity:

Breaks down the different reactive hazards of the chemical and stability information. This includes an indication of whether the chemical will react in certain situations such as pressure or temperature change, as well as any safety issues that may arise if the product changes in physical appearance. There is also a description of specific test data for the chemical.

Section 11: Toxicological Information:

Identifies any information about immediate or chronic health effects that may arise from exposure to the chemical. This also includes symptoms of exposure from lowest to most severe.

Section 12: Ecological Information:

This section measures the impact the chemical has on the environment if it were released. This includes test results if available.

Section 13: Disposal Considerations:

Provides information on how to properly dispose of the chemical as well as safe handling practices.

Section 14: Transport Information:

Provides guidance on classification information for shipping and transporting by ground, air, or sea. This includes UN number, proper shipping name, and hazard class.

Section 15: Regulatory Information:

Displays the specific regulations for the product not indicated anywhere else on the SDS.

Section 16: Other Information:

Indicates when the SDS was created and the level of revision. This section states where the changes have been made to the previous version.


As always, if you have any questions regarding SDS Services contact ICC Compliance Center at 1.888.442.9628 (USA) or 1.888.977.4834 (Canada).


Source: https://www.osha.gov/Publications/OSHA3514.html

Shipping by Road
TDGR US Import Cross-Docking – All We Want are the FAQs…*

Cross-Docking is Reshipping

On February 8 Transport Canada issued an addition to FAQ regarding the Transportation of Dangerous Goods Regulations (TDGR) Part 9, s. 9.4. This section deals with the re-shipping of dangerous goods (DG) received by road from the US when safety marks differ from those specified in the TDGR. In general, (more on this later**), TDGR 9.1 allows receipt of US shipments to first destination with the safety marks that were legally applied under 49 CFR at the US shipping point.

Cross-Docking

The FAQ defines “cross-docking” as “the process of transferring dangerous goods from one vehicle to another before reaching their final destination”. Changing drivers or tractor units does not trigger the term. When DG are cross-docked, Transport Canada considers this to be “re-shipping” and the provisions of TDGR 9.4 apply (note: although the FAQ refers to “reshipping” in quotes, the term is not specifically defined in the TDGR other than as described by s. 9.4).

Reshipping

Basically, the requirements in s. 9.4 are to remove placards which do not meet TDGR requirements and replace them with TDGR-compliant versions. Examples of these could be US “DANGEROUS” placards; or those with the midline adjusted (e.g. Class 7, 8, 9); or worded and “combustible” placards.
In addition, if means of containment (soon to become “packaging” we hope!) have labels or other safety marks differing from TDGR requirements, then the shipping paper must be annotated accordingly as indicated in s. 9.4 (2).

Part 10 is not referenced in the FAQ, but presumably similar logic will apply to cross-docking rail car shipments (TDG s. 10.4) – or to transfers between rail/road vehicles.

Just the FAQs

Although the author hasn’t seen anything in official consultation documents, statements in casual conversations on two occasions indicate that the current practise of including interpretative guidance as italicised text within the body of the regulations will likely be discontinued. Apparently, this very useful (in my humble opinion) practise is at odds with regulatory convention that expects only the mandatory legal requirements to appear in the regulation. FAQ are the preferred vehicle for the type of information we currently see italicised within the TDGR.

The FAQ referred to in this Blog is available at:
http://www.tc.gc.ca/eng/tdg/awareness-materials-and-faq-1159.html#a99_0

* with apologies to Sgt. Joe Friday/Jack Webb’s often misquoted statement:
http://www.snopes.com/radiotv/tv/dragnet.asp

** Reciprocity has its limits
Although we often hear of “reciprocity” for shipments inbound from the US, we must remember that it has limits. As referenced in the above-mentioned FAQ, the “inhalation hazard” version of Class 2.3 and 6.1 labels or placards are not acceptable even to first destination. The “regular” versions, applied with qualifying marks as required by TDGR SP 23 also need to be present. Similarly things done by US special permit- although potentially to be accepted to first destination under the CG I International Harmonization proposal- will not necessarily be approved for reshipping. Perhaps once the CG II is finalised we’ll have another Blog on this aspect…

Lithium
Lithium Battery Labels as of Feb 1, 2017

Both 49 CFR and TDG are expecting to harmonize lithium battery labels into the regulations; however, both regulations are pending. HM-215N (49 CFR) was recalled, and will not be reissued for at least 60 days.

Transport Canada has not provided an ETA on the harmonization.

Find out the correct labels to use below:

 

Electric Tractor Trailer
Electromobility Becomes a Reality!

The Rise of Electromobility

Not long ago, no one believed in the arrival of electric or hybrid road tractors. No one also believed that a fully electric car offering performance and autonomy would arrive on the market as fast as the Tesla vehicle did. The Tesla, a car which proves that electromobility is progressing in a dazzling way.

Last December, Nikola Motors realized what was unthinkable just three years ago, by unveiling a class 8 road tractor with an all-electric 320-kilowatt powertrain powered by high-density lithium batteries. (https://nikolamotor.com/).

It’s an all-electric class 8 road tractor with a sleeping compartment, capable of traveling up to 1,900 kilometers with a single filling of the hydrogen fuel cell system. It has no conventional transmission: each of the six wheel positions has its own electric traction motor which are controlled independently.

Will we soon see electric trucks on the roads to transport our freight?

More broadly, Navigant Research forecasts suggest that sales of electric trucks could reach 332,000 units globally by 2026. Sales were 31,000 in 2016. These are sales of trucks Medium and Heavy hybrid, hybrid rechargeable, electric battery and hydrogen fuel cells.

Electromobility seems to be a solution when National and regional governments keep imposing increasingly stringent emissions standards on commercial vehicles but are also looking for ways to encourage fleets to invest in energy-efficient technologies and cleaner fuels.

Deer Crossing Sign
Are Highway Warning Signs Effective?

How Well Do Driving Safety Signs Work?

A few years ago, someone wrote an irate letter to his local newspaper about the deer warning signs put up on a local highway. He couldn’t understand why they were always on busy highways. Wouldn’t it reduce accidents if the deer were told to cross smaller roads instead?

We may laugh, but the story does bring up an interesting point. Just how effective are traffic warning signs? They can be found wherever we travel, from the common “sharp curve ahead” to the more esoteric, such as the “moose warning” signs in Newfoundland. Highway safety departments consider them an important part of improving driving safety. But how well do they work?

Apparently, the answer is somewhere between “not great” and “we’re not sure.” There’s little research on the effectiveness of highway traffic signs and what there is shows that a surprising lack of effectiveness. For example, the Minnesota Department of Transportation has admitted:

“Signs that alert drivers to infrequent encounters or possible situations–such as deer crossing or children playing—do not have a consistent impact on driver behavior. Widespread use or misuse of warning signs reduces their overall effectiveness.”

Traffic and Why We Drive The Way We Drive

Tom Vanderbilt, author of Traffic: Why We Drive the Way We Do (and What It Says About Us), says:

“[D]rivers routinely see signs warning of deer crossings (in the United States) or elephant crossings (in Sri Lanka) or camel signs (in Tunisia). It is difficult to say what is going on in the mind of a driver whenever he or she sees a deer or elephant or camel crossing sign, but studies have shown that most drivers do not change their speed at all.”

Surprisingly little work has been put into studying the effectiveness of traffic signs, considering how they can be seen on every highway or busy city street. What studies have been done have not shown signage has a strong effect on reducing accidents in dangerous areas. In fact, many experts believe that the main purpose of traffic warning signs is not to reduce accidents but to provide liability protection for the government that posts them.

Why Aren’t They Successful?

So, why don’t traffic signs work like they should? Many reasons are likely at play. Marc Green, in his article The Psychology of Warnings says compliance with warning signs involves the driver making a cost-benefit analysis, where he or she balances the following factors:

  1. Cost of compliance – most traffic signs, in their most basic message, say “slow down, because something ahead is dangerous.” The driver will (consciously or not) factor in the inconvenience of being late, or their dislike of being slow, as part of the cost of compliance. Green notes this is a similar problem with product warning labels. “Increased time reading” can be seen as a “cost of compliance”. Who’s going to read an entire product label when there’s a rush job to be done?
  2. Danger perception – this is the old risk versus hazard issue. Most drivers will stop at stop signs, because they understand that if they don’t, they significantly increase their risk of getting hit. But if you drive a road for years and never see a deer, you may come to feel that even if the consequences of hitting a deer are high, the risk of that ever happening is low. Paradoxically, people who feel confident in their driving skills more likely to ignore such signs. Green points out “[o]ne of the ironies of warnings is that the more experienced and skilled the viewer, the stronger the familiarization effect and the more likely that the warning will be ignored. For example, diving team members are the most likely people to ignore “no diving” signs.” Further, herd behavior can be a factor; if everyone speeds, it appears to be safer than if everyone slows down.

Each driver will evaluate these two factors and make a (perhaps unconscious) decision to obey the sign or to ignore it and risk something nasty happening down the road.

Complying & Understanding

There are many ways safety experts are now working to determine what psychological factors make people decide to obey traffic signs. For example, the effectiveness of signs can be diluted if they appear everywhere, so signs may be posted only where significant hazards truly exist. Green mentions

“People have unconsciously learned the general rule that signs and signals grow in size and vividness with their importance, presumably so that they will be more readily seen. Viewers will then likely interpret warnings that are small, faint, or located peripherally as signaling lower risk.”

These factors apply to all drivers, but they also are an important issue for workplace and consumer safety labels. Designers of OSHA or WHMIS labels must, of course, comply with the regulations, but understanding the psychology of safety warnings is also important when trying to create an effective label design. The label must be able to persuade the reader that compliance is really the most cost-beneficial response. By studying what we’ve learned about highway signs, we can learn what psychological nuances improve the likelihood that users will comply with the label.

Fortunately, OSHA and WHMIS labels include precautionary phrases that specifically instruct the user in what to do to ensure safety, a feature sometimes lacking in traffic signs. For example, when confronted by a “falling rocks” sign, what should a driver do? Avoid the area? Wear a hard hat when going through the zone? And I was always perplexed on how drivers transversing a typical single-lane Scottish highway were expected to respond to the ominous warning on blind curves – “Oncoming traffic may be in centre of road” – that gave drivers no suggestion for how to negotiate the curve safely.

Have you seen any particularly effective or ineffective traffic signs? If so, let us know in the comment section. And if you have questions about labelling for workplace or transportation safety, contact ICC Compliance Center at 1.888.442.9628 (USA) or 1.888.977.4834 (Canada).

PHMSA Update
U.S. Final Rule HM-215N on International Harmonization Delayed

Regulatory Freeze Delays Final Rule HM-215N

The Pipelines and Hazardous Materials Safety Administration (PHMSA) of the Department of Transportation (DOT) has withdrawn a Final Rule that was intended to be published in the Federal Register on January 26.

The Final Rule, HM-215N, would have updated the U.S. “Hazardous Materials Regulations” to reflect international standards, improving U.S. abilities to import and export hazardous materials as well as reflecting improved safety standards. However, due to the new administration’s Regulatory Freeze executive memorandum, regulatory changes that had been sent to the Federal Register but not already approved must be immediately withdrawn for “review and approval” before being reissued. While the text of the Final Rule had already been published on PHMSA’s website on January 18th, it had not yet appeared in the Federal Register. The Regulatory Freeze took effect as of January 20.

Since this update is relatively non-controversial for stakeholders in the transportation industry, and will improve the ability of the United States to compete internationally, it is hoped that the review and approval time will be short. However, until the Final Rule can be published, the hazmat community must wait for the anticipated harmonization of U.S. regulations with international standards. These include proposed changes such as:

  • the adoption of the latest versions of the UN Recommendations on the Transport of Dangerous Goods, the ICAO Technical Instruction’s on the Safe Transport of Dangerous Goods, the International Maritime Dangerous Goods Code and Canadian “Transportation of Dangerous Goods Regulations”;
  • the extension of Transport Canada equivalency certificates to the U.S. portions of transborder shipments;
  • a set of new shipping descriptions for products such as polymerizable substances;
  • a new special provision for substances that require stabilization during transport, enabling the use of temperature controls when chemical stabilization becomes ineffective;
  • change in the classification and hazard communication for uranium hexafluoride; and
  • the harmonization of lithium battery transport provisions, including the new Class 9 label and Lithium Battery Handling Mark. Fortunately, these new marks have a transition period in the ICAO Technical Instructions until 2019.

Right now PHMSA is unable to confirm when they can resubmit the Final Rule. It will, it’s hoped, be soon, so U.S. companies can establish a unified set of procedures for national and international shipments.

If you have questions about these proposed changes and how they can affect your operations, please contact ICC Compliance Center at 1.888.442.9628 (USA) or 1.888.977.44834 (Canada).

Single Packaging
Benefits and Rules of Variation Packaging

Standard 4G UN combination packaging is tested in a specific configuration with specific inner packaging and components. When using standard 4G UN combination packaging, you must use very similar components that match the configuration of the way the package was tested in the lab. This can make it rather difficult at times to find a packaging solution to meet your specific needs. In comes variation packaging to save the day! Variation packaging allows you to use various types of inner packaging, such as bottles, cans, jars, and smaller plastic containers while using a fiberboard box that meets the UN specifications and the ISTA requirements.

This packaging is ideal when a combination of different inner components is needed, or when the party responsible for shipping has a variety of products to ship. This type of packaging carries labeling marks designated 4GV. Below is a list of some rules and regulations per 49 CFR 178.601 (g) (2) if you decide to utilize variation packaging:

  1. Articles of any type, liquid or solid, may be assembled and transported using variation packaging if the following conditions are met below:
  2. The same cushioning material must be used as what the package was tested with. If the package was tested with an absorbent pouch and 2 pillows, the same must be used during the shipping process. The same goes for any fiberboard insert associated with the packaging.
  3. The thickness of the absorbent must not be reduced below what the original testing report indicates. For example, if the packing instructions call for 2″ of vermiculite on the top, bottom, and sides of the inner container and to fill the remaining void space, that would be the minimum cushioning you are allowed to use when shipping the variation package.
  4. If inner packaging is used that contains liquid, there must be enough absorbent material to absorb the entire contents of the bottle. If the hazardous liquid in the bottle leaks, the absorbent material must have the ability to soak it up to prevent leakage from getting beyond the outer packaging.
  5. When an inner packaging contains a liquid and is not leak-proof or a solid and is not sift-proof, it must also contain a leak-proof liner, plastic bag, or any equally effective means of containment.

And as always if you have any questions or would like to purchase variation packaging, contact ICC Compliance Center at 1.888.442.9628 (USA) or 1.888.977.44834 (Canada).

Lithium
Lithium Battery Worlds Collide

One of my favorite episodes of the show Seinfeld is the one where worlds collide. In the episode Elaine asks George’s girlfriend Susan to a show. On the surface this seems harmless. According to Kramer, this is a bad thing because when George’s “sanctuary world” and his “girlfriend world” collide there will be an explosion.

I had a case of my worlds colliding over the holidays. Let’s see what the results were. The attached pictures are from a leaf blower my husband received as a Christmas gift. It is a nice gift that will help us with yard work in the future. The description on the box says it comes with a charger for the included 40 volt, 2.0 ampere-hour rechargeable lithium-ion battery. On the back was the Lithium battery handling information. I didn’t pay much attention to it due to being in a cookie coma from the holidays.

Lithium battery label on box

Upon arrival home and while unloading the car, my husband noticed the information on the box and pointed it out to me. He then asks, “Should this be on here?” Needless to say, once we were fully unpacked I grabbed my regulations just to see.

Using the information on the box let’s review some points for shipping Lithium-ion batteries. Bear in mind this was purchased at a store where it was on the shelf. I have no way of knowing if it was shipped in this box.

  • Step 1: Is this lithium-ion battery is “contained in equipment” or “packed with equipment”?
    • Answer: The battery was not inserted into the blower but in a separate box beside it. This means it would have been “packed with equipment”.
  • Step 2: What is the watt-hour rating?
    • Answer: This was easy enough since the box said the battery had a 2 ampere-hour capacity and a voltage of 40 volts.  Using the following formula:

Watt-hours = Ah (ampere-hours) x V (voltage)
Watt-hours = 2 Ah.  X 40 volts
Watt=hours = 80 watt-hours

  • Step 3: What would be the proper identification number, shipping name, hazard class, and packing group (ISHP) if this had been shipped?
    • Answer: Since the manufacturer is within the US, I looked at the US ground regulations, 49 CFR. It is a Lithium-ion battery that was packed with equipment. Using the Hazardous Materials Table (HMT) that tells me the proper ISHP would be UN3481 // Lithium-ion batteries packed with equipment // Class 9 // no packing group.
  • Step 4: What sort of packaging requirements are there?
    • Answer: Again the HMT gave me that information in column 8. Luckily for UN3481 the packaging information is all found in Section 173.185. The only Special Provisions listed in the table are for air shipments. Much of this section didn’t apply to my query because I wasn’t shipping this. However, this section is also where all of the marking, labelling, exceptions/exemptions and hazard communication information is found.
  • Step 5: Where does the leaf blower fit and why was that particular safety information used?
    • Answer: This goes back to the information from Step 2. The watt-hour rating of 80 put me into Section 173.185(c) for exceptions. In that section is where the hazard communication information is found. In that was the proof I needed to say, “It is ok for this information to be on this box.” The box only has 1 lithium battery and the box is using the “handling marking” shown in paragraph (c)(3)(ii). The regulation says the following:

(3) Hazard communication. Except for a package containing button cell batteries installed in equipment (including circuit boards), or no more than four lithium cells or two lithium batteries installed in the equipment:

(i) For transportation by highway, rail and vessel, the outer package must be marked with the information in the following paragraphs (c)(3)(i)(A) to (D), or the handling marking in paragraph (c)(3)(ii) of this section:

(A) An indication that the package contains “Lithium metal” and/or “Lithium ion” cells or batteries, as appropriate, or alternatively, the word “batteries” may be used for packages containing cells;

(B) An indication that the package is to be handled with care and that a flammable hazard exists if the package is damaged;

(C) An indication that special procedures must be followed in the event the package is damaged, to include inspection and repacking if necessary;

(D) A telephone number for additional information.

(ii) For transportation by air, the outer package must be marked with the following handling marking, which is durable, legible, and displayed on a background of contrasting color:

Old lithium battery label

So there it is the results of my worlds colliding. There were no explosions, tidal waves, or earthquakes. There were no deaths from licking cheap envelopes, which is a reference to Susan’s fate. It was just an exercise of taking ICC Compliance Center’s “7 Steps to Compliance” idea and making them work for me. Of course, my head may explode when HM215-N is finalized and the information in this section of 49 CFR changes.

As always, ICC Compliance Center is here for all of your hazard communication and lithium battery needs. Call us today for lithium battery training, new class 9 labels or new handling marks, and new lithium battery shipping materials. We have it all.

GHS
GHS in North America and Europe – Where Are We Now?

Isn’t everyone using GHS for SDS’s and labels?

The answer to that is yes, and also no.

The European Union (EU)

In the EU, REACH [Regulation (EC) No. 1907/2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals] and GHS regulations [Regulation (EC) No. 1272/2008 on classification, labelling and packaging of substances and mixtures, or the ‘CLP’] have already been implemented for many years. Most phases of the EU’s implementation plan have already been completed. There is one last remaining date that has not yet passed, however, with respect to SDS’s and labels.

SDS’s and labels for pure substances are required to fully compliant with REACH and the CLP. The last transition date for pure substance SDS’s was completed on December 1, 2012. Any SDS and label for a pure substance after that date, had to be fully compliant with REACH and CLP regulations, and display only GHS information.

SDS’s and labels for mixtures, for products placed on the market in the EU for the first time after June 1, 2015, are also required to be fully compliant with REACH and the CLP, and display only GHS information.

Mixture SDS’s and labels, only for products already placed on the market in the EU for the first time before June 1, 2015, however, may still show old system EU information. These SDS’s and labels for mixtures, may still display the EU’s old system of regulations [Directive 1999/45/EC], which made use of Risk (R) and Safety (S) phrases, as well as square shaped, orange and black symbols. These SDS’s and Labels, have the last remaining compliance date, which is coming up fast, of June 1, 2017. Any SDS and label after that date, will have to be fully compliant with REACH and CLP regulations.

The United States

In the United States, GHS regulations have also already been implemented for a few years as well. All effective completion dates have passed in the United States. All SDS’s, labels, written Hazard Communication programs, and training must be fully compliant with the Occupational Safety and Health Administration’s (OSHA) Hazcom 2012 GHS standard. The last transition date, for Employer workplace systems, was completed on June 1, 2016.

Canada

In Canada, the implementation of GHS into existing regulations is currently in only its first transition phase. Health Canada’s Hazardous Products Regulations (HPR) (ie. the ‘Workplace Hazardous Materials Information System 2015’, or ‘WHMIS 2015’), were only fairly recently published in February of 2015.

In its first transition phase, Manufacturers, Importers and Distributors, may comply with either the existing WHMIS regulation (‘WHMIS 1988’ or the ‘Controlled Products Regulations / CPR’), or the new WHMIS 2015 GHS regulation. SDS’s in this phase, may still be called ‘Material Safety Data Sheets (MSDS’s)’, and labels may still show the characteristic WHMIS 1988 hatched border and circular symbols. Phase 1 comes to an end on May 31, 2017, after which, Manufacturers and Importers must comply fully with the WHMIS 2015 regulation. SDS’s and labels then after that date, which are produced by Manufacturers and Importers, must display GHS information.

In its second transition phase, which begins on June 1, 2017, Distributors may still comply with either the existing WHMIS 1988 regulation, or the new WHMIS 2015 GHS regulation. Employers now will also comply with either regulation. Phase 2 comes to an end on May 31, 2018, after which, Distributors must comply fully with the WHMIS 2015 regulation. Any SDS’s and labels in a distribution warehouse, then, after that date, must display GHS information.

In its third and final transition phase, which begins on June 1, 2018, Employers may still comply with either the existing WHMIS 1988 regulation, or the new WHMIS 2015 GHS regulation. Phase 3 comes to an end on November 30, 2018, after which, Employers must comply fully with the WHMIS 2015 regulation. With this third and final phase, individual Provinces may slightly extend certain aspects of employer WHMIS 1988 requirements, so the rules in place for each individual Province must be reviewed. For example, the Province of Ontario, will allow Federally-regulated Employers to use WHMIS 1988 for products already present in the workplace on December 1, 2018, until May 31, 2019.

Mexico

In Mexico, GHS was adopted even before it was adopted in the United States into OSHA regulations. In June of 2011, Mexico’s Ministry of Labor and Social Welfare published a new Mexican standard, NMX-R-019-SCFI-2011. The standard adopted all building blocks of the UN’s Purple Book, revision 3, including all Environmentally Hazardous categories. The standard, however, was completely optional. Mexico presented the new standard as an ‘alternative’ to its existing standard, NOM-018-STPS-2000.

Then, fairly recently, in October of 2015, the Ministry of Labor and Social Welfare announced the adoption of a new GHS standard, which will eventually become mandatory. This is Mexican standard NOM-018-STPS-2015. This newer GHS standard adopted all building blocks of the UN’s Purple Book, revision 5, again, including all Environmentally Hazardous categories.

Similarly to Canada, Mexico is now also in a transition phase. Employers in Mexico may comply with the existing standard, NOM-018-STPS-2000, or standard NOM-018-STPS-2014 (this was a ‘proposed’ NOM that was officially adopted as NOM-018-STPS-2015), until October 8, 2018. SDS’s and labels then after that date, must display GHS information.

North America and Europe Reminders

Canada, the United States, Mexico, and Europe, will not be completely transitioned to GHS, across the board, until November 30, 2018, when Canada’s final transition phase for employers come to an end. In the meantime, keep in mind these differing transition and completion dates. And as always, remember that each country or region may throw in side-bar country specific requirements that veer away from the UN’s Purple Book. Review each regulation fully, and individually.

For further information and updates on European and North American regulations, please consult the following website links:

Europe:
ECHA

United States:
OSHA

Canada:
WHMIS

Mexico:
Diario Oficial de la Federación


If you have any questions regarding the GHS, please contact ICC Compliance Center Inc at 1-888-442-9628 (USA) or 1-888-977-4834 (Canada).