Or: “When I use a word,” Humpty Dumpty said, … “it means just what I choose it to mean …”
Lewis Carrol “Through the Looking Glass” in Bartleby’s “A Dictionary of Quotations”:
Health Canada provided an FAQ presentation at a recent CIC (Current Issues Committee) meeting that may provide a useful lead in to the more detailed Guidance document published in December 2016.
The latter, “Technical Guidance on the Requirements of the Hazardous Products Act & Hazardous Products Regulations – WHMIS 2015 Supplier Requirements”, provides (at 540 pages) a detailed review of the content of the law and various aspects of guidance/interpretation. This document is available for download at:
The length of the document may be daunting to the casual user, so the FAQ presentation attempts to present Health Canada’s position on items that are of current concern.
The CIC is a multi-representative committee that meets several times a year to review, as it’s name implies, issues that can be improved to increase the effectiveness of WHMIS in helping to protect workers. Currently there are representatives from various government levels (Federal/Provincial/Territorial), Health & Safety organizations (e.g. CCOHS), industry organizations (e.g. RDC, CIAC, etc.) and Labour (CLC, Unifor, etc.).
One of the current issues being addressed is Continue Reading…
If you ever navigate our packaging section on our website, you will notice a section for U.S. Special Permit Kits.
You may ask yourself, what is a special permit and how does it apply to packaging? Well, basically special permits allow a shipper to perform a function that is not currently authorized by the regulations, or not perform a function currently required under the PHMSA regulations. Below are answers to questions regarding special permits.
Q. Why would someone need a special permit?
A. Special permits can provide relief from specific regulations when shipping dangerous goods. For example, it can allow a shipper to transport their dangerous goods in a specific UN-rated package without having to use hazard labels, as long as they adhere to the required provisions stated within the Special Permit.
Q. How do you apply for a special permit?
A. An application has to be completed and submitted to the US DOT along with specific documentation including written descriptions, drawings, flow charts, plans and other supporting documents.
Q. Do special permits expire?
A. Yes. Special permits expire after a period of time and the manufacturer must re-apply with the Department of Transportation.
Q. Does the Department of Transportation reject applications for a special permit?
A. The application must Continue Reading…
Frequently Asked SDS Symbols Questions
How many times have you thought you understood a requirement, only to second guess yourself about whether you got that right or not? It could be something relatively straight forward, or something a bit more complicated. Everyone has these moments occasionally, especially with the implementation of GHS around the world. At ICC, two of the questions that seem to pop up from time to time, revolve around symbols on SDSs.
Do GHS pictograms have to appear on an SDS?
The answer: No. The ‘pictogram,’ specifically, doesn’t have to appear. This answer, in part, boils down to terminology.
In both Canada, under WHMIS 2015 Hazardous Products Regulations (HPR) requirements, and in the United States, under Hazcom 2012 requirements, Section 2 of an SDS is required to list the label ‘information elements’ that are applicable to the product. Hazard ‘symbols’ being one of the required ‘information elements’.
In both the United States and in Canada, ‘pictogram’ is defined as a “symbol” along with other “elements, such as a border or background color”. So a complete GHS ‘pictogram’ is actually two part; a graphic symbol on the inside, and a frame surrounding it. Both countries include an allowance only to show a ‘symbol’ Continue Reading…
Oprah Winfrey once said, “I’ve talked to nearly 30,000 people on this show, and all 30,000 had one thing in common. They all wanted validation.” Validation is receiving feedback from others that what you do and say matters. It is an acknowledgment of your actions, deeds and accomplishments. To be a healthy person we need to receive positive validation and be able to give it to ourselves. So is it possible for a company to receive validation? I believe so and here’s why.
In one of OSHA’s recent Frequently Asked Questions (FAQ’s) postings a question regarding the use of ranges on Safety Data Sheets was added. To see the full FAQ and the answer, please click here. The specific question asked is: When may chemical manufactures/importers use concentration ranges rather than an exact percentage composition in Section 3 of the SDS, and how does this apply to trade secrets? Let’s take a closer look at OSHA’s answer. There are several parts to it and each deserves some attention.
Part 1 – Exact Percentage versus Concentration Range Clarification
The answer starts by clarifying the language used in Appendix D under Section 3. In the actual Appendix it states, “The chemical name and concentration (exact percentage) or concentration ranges of Continue Reading…