December 2014 Spray 39 Regulatory International Influences Renewal of Labels and SDS: The current requirement to update a Material Safety Data Sheet every three years will not be retained. However, companies must ensure that their SDS and labels remain accurate and must update these if new information becomes available about the composition of the mixture or the substances comprising it. Exact Concentrations: Under the 2014 proposed rule, companies will not be able to use “WHMIS ranges” for the concentrations of components in their mixture. Rather, exact percentages must be used, unless there is a known variance in the raw material or manufacturing process. Trade Secrets: In Canada, companies cannot selfdeclare that chemicals in a mixture—or their concentrations— are a trade-secret. Rather, they must apply to the Federal government to make such claims. Given the requirement for exact concentrations on SDS, we expect many companies will want to make trade secret claims. In order to do so, a company must register the chemical in question with Health Canada and obtain a Hazardous Materials Information Review Act (HMIRA) number. Small Volume Containers: The 2014 draft rules have special provisions for reduced labeling requirements on containers of 100mL or smaller. These do not exist under the U.S. Hazcom 2012 regulation. Products with Multiple Containers: Kits and other products with multiple containers (two-part epoxies are a classic example) require both the inner containers and the outer container (such as a box) and must have workplace labeling under the 2014 draft rules. This is not the case under Hazcom 2012. We will keep watching the progress of GHS around the world. Do not be surprised to see jurisdictions that have already implemented the system update their laws to be closer to GHS Revision Five, including the U.S. When that happens, we will be sure to inform SPRAY readers. SPRAY
Spray Dec 2014
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