Need of Canadian Consumer Label Review Service

Canadian Consumer Label Review (CCCR) can be both complicated and time consuming. There are many regulations associated with the CCCR 2001 issued under the Hazardous Products Act. It is best to consult an organization that has the expertise with these rules and regulations to ensure the products are correctly classified and products will not be recalled due to improper classification, packaging and/or labeling.

There are services available to help organizations stay compliant with the ever changing consumer labeling regulations. Consulting services provide companies with expert interpretations, guidance and compliance with the GHS guidelines. Typically companies out pursuit GHS services to save time, save money and increase efficiency.

The person who classifies the product is responsible for the CCCR. So if the CCCR is not outsourced to a company of experts and the importer/distributor or manufacture of a consumer product decides to complete the CCCR in-house they will be obligated to assess and correctly classify, package and label the product (as per Parts 1 to 5 of the CCCR-2001). It is not the retailersresponsibility to ensure the product is packaged correctly. The person responsible for classifying the product is also responsible for providing the necessary information to a government inspector should there be a packaging concern or a product audit.

Why (GHS) Globally Harmonized System is necessary?

Currently, most countries have different label requirements as well as classification systems for chemical products. It is also not uncommon for a country to have several different chemical classification systems. The inconsistencies have become very expensive for companies to comply with due to the numerous standards they are required to me for each system. Many governments are also experiencing the high cost or regulating and enforcing numerous

The Globally Harmonized System of Classification and Labelling of Chemicals (GHS) is an initiative undertaken by the United Nations to create uniform regulatory regimes among all countries for communication and classification of chemicals. The GHS offers guidance for pure chemicals and mixtures classification. The GHS also attempts to standardize globally the information (i.e. phrases and symbols) required on chemical labels and material safety data sheets (MSDS).

The GHS provides uniform definitions and classifications for the hazards of chemical products. The GHS also sets the standard for the safety information required on labels and MSDS also known as Safety Data Sheets (SDS). The GHS objective is have the same rules globally resulting in universal international content labels and MSDS as well as Chemical classification hazards.

The intended audience for the GHS includes consumers, emergency responders and workers. The Globalized system will be less confusing and be more cost effective. Business will no longer need to meet several different requirements to sell their products abroad, they will only need to confirm with one set of regulations that are universally accepted.

If I have an industrial label do I also need an international label?

If you currently have an industrial product label and are planning on exporting the product to other countries/jurisdictions you will need an international label complaint specifically for the laws and regulations for the area of import.

There are several countries around the world which require labels to be applied to industrial products. Canada requires a WHMIS label to be present on all industrial products. The WHMIS regulations contain specific hazard symbols and text along with a hatched label border and language requirements which all must be present on the label. The U.S. industrial labels usually follow ANSI or OSHA requirements. Mexicodoes not have an exact set of regulations for industrial labels, but either the WHMIS or ANSI label is usually acceptable to use as long as it is presented in Spanish. The E.U. requires an industrial label to be compliant with either the Directives 67/548/EEC, 1999/45/EC, or 75/324/EEC. These E.U. regulations state specific hazard symbol and hazard text requirements.

It is usually difficult to combine label requirements on a single product label for multiple countries. Different countries have varying label requirements and can either conflict with another jurisdiction or all the requirements might not fit on the label. As such it is usually best to only provide compliance for one jurisdiction per label.

What MSDS Services are available?

There are many companies that provide services and support to organizations who need to develop or maintain MSDS documentation. These services include but are not limited to: MSDS authoring, label reviews, government liaison and/or submissions, technical translations, software programs, database construction and training. Many of these companies provide an array of regulation consulting services; the trick is to select a company who excels in the domain you require assistance with.

At present, it is common for many companies to outsource MSDS authoring. Many small and medium size companies do not have the volume of MSDSs to require an onsite regulatory specialist. It is much more cost effective for these types of companies to outsource their periodic MSDS needs. An increase in complexity with the rules and regulations surrounding MSDS development also makes it more cost effective to outsource these tasks to professionals who receive continual training on the new regulations. Most companies do not have the financial support to continually train their employees on the current regulations when they author a minimal number of MSDS.

Currently, many MSDS services provide customer support via e-mail or by phone. Results are quickly and easily achieved by e-mailing the necessary documents between the customer and the service provider.

GHS (Globally Harmonized System)

The Globally Harmonized System of Classification and Labelling of Chemicals (GHS) was created with the intention of harmonizing existing systems of labelling hazardous materials. The shaping of the system focused on building a single system to address the classification of chemicals, labels and safety data sheets.

Once completed in 2001, the System was sent to the Sub-Committee of Experts on the Globally Harmonized System of Classification and Labelling of Chemicals (UNSCEGHS). This sub-committee had been previously established and is responsible for maintaining the system updated and for promoting its satisfactory performance both nationally and internationally.

Given the widespread use and trade of chemicals in the world, and the fact that regulations on their use vary from country to country, the Harmonized System is directed not only to governments, but also to national and international institutions responsible for handling chemicals.

Some advantages of carrying out the harmonized system are:

– Protecting human life and the environment
– Providing support and information to countries which lack their own system
– Reducing the need for testing and evaluation of chemicals
– Facilitating international trade

Which ingredients must be disclosed on the WHMIS MSDS and under which sections must they be listed?

Every chemical that is controlled has an assigned disclosure limit. Every ingredient in a product that is controlled and is in a concentration higher than the designated disclosure limit must be disclosed on the WHMIS MSDS. Any ingredient that does not fit these criteria (i.e. is not controlled or is in a lower concentration than its disclosure limit) is not required to be disclosed.

There are sixteen sections on a WHMIS MSDS. The first section under which the ingredients must be disclosed is Section 3 (Composition/Information on Ingredients). Under this heading, each ingredient is listed, along with its Chemical Abstracts Service (CAS) registry number and concentration in the product (using WHMIS ranges).

The ingredient list is also shown under Section 8 (Exposure Controls/Personal Protection). Each ingredient must have its exposure limits listed under ACGIH-TLV (American Conference of Governmental Industrial Hygienists).

Section 11 (Toxicology Information) also requires a listing of each ingredient to be disclosed. This section states the LD50 and LC50, including species and route of exposure, for each chemical. Each ingredient must also be listed a second time under this section, stating any chemical in that ingredient that is listed as a carcinogen or potential carcinogen.

In addition, Section 15 (Regulatory Information) also lists the disclosed ingredients. This section states if the ingredient is in the Domestic Substances List (DSL) or not (NDSL).

In any section where the data is unknown/not available for a specific chemical, Not Available, Not Applicable, or Not Listed can be used in its place.

Do MSDS sheets expire?

Every country has their own regulations on MSDS sheets and possible expiration dates.

Canadian WHMIS MSDS sheets expire every 3 years. The MSDS sheet must be updated to provide any new information that has become available since the date it was first prepared. This may include a change in the formulation or information that has demonstrated a hazard that was not previously stated.

United States OSHA MSDS sheets have no specific requirements concerning expiration dates. However, as required by OSHA, a new MSDS sheet must be issued if any of these conditions are met:

There has been a significant change to the chemical makeup

A health or physical hazard that is different from previously stated is discovered

If the product has been listed as carcinogenic

If any of these changes occur, a new MSDS must be released with the new date that it was prepared on.

In the European Union, under the old CLP regulations SDS sheets also do not have a specific expiration dates. However, if any information has been added, deleted or revised, this must clearly be shown on the revised sheet.

Each of these three countries does require the date of preparation or date of revision to be listed on the current MSDS sheet in place. Even if your country does not have an expiration date in place, it is best to review your MSDS sheets regularly to ensure proper compliance.

MSDS: documenting Hazardous Chemicals and ensuring a safe work environment

Material Safety Data Sheets or MSDS and hazardous chemicals share a bond. Today, every chemical of a hazardous nature must be documented. This concept of documentation goes back thousands of years to an Egyptian physician Inhotep who would document each aspect of his prescription. Thus, not only the materials used and their concentrations but also their sources and the method of preparation, the manner in which it was to be administered and the precautions that were to be observed were documented.

We have now reached a stage when our very survival depends on the faithful documentation, the MSDS way. Now every one involved in the manufacture, storage, testing, packaging, transporting and demolition of these hazardous chemicals must be aware of not only the dangers that these chemicals construe but also how such dangers are to be handled. There is now a unified global thrust towards improving the safety, health and security of our environment.

Each of these data sheets must display full particulars that include the name of the chemical and its constituents and the full particulars of both the producer and the supplier. These particulars should be complete so as to serve as postal addresses including telephone numbers. The important physical data are to be included such as the boiling point, vapor pressure, odor and the nature and intensity of its reactivity with other substances. Its inflammability and sensitivity to explosion, the safety gear to be used and to what extent the chemical is carcinogenic or toxic are all to be detailed.

MSDS – for a Risk Free Society

With the proliferation of hazardous chemicals a necessity was felt to document these chemicals in a systematic manner in order to exercise total control over them. This was to be a global effort in order to ensure uniformity and standardization. The new method of documentation was known as Material Safety Data Sheets or MSDS.

MSDS was to dictate the manner of documentation in a way that all the personnel involved in the production, packaging, testing, transporting, demolition or handling of hazardous chemicals was to be made fully aware of the hazards; the first aid to be used; the protective gear that was recommended; how to handle a fire; spillage, or an explosion. This was to be a global thrust aimed at achieving total security and improved health in the working area. The new documentation was to contain the complete particulars regarding the chemical, those of the producer and the supplier. It was to indicate the toxicity and the extent to which the chemical was carcinogenic. The various constituents of the chemical were to be detailed along with physical data such as odor, the vapor pressure and the boiling point besides the extent to which the chemical was reactive with other substances. Its flammability and sensitivity to explosion were to be mentioned as well.

There are regulatory bodies for MSDS such as the National Institute for Occupational Safety & Health besides certain competent agencies that offer services for MSDS authoring for the data sheets in US, Canada, Mexico and other countries.

MSDS Can Bring in Stability and sustenance to an industrial process

There is an international understanding that all chemicals that are hazardous in nature must be documented in order to bring in a stable global order not available so far. Hereafter, all chemicals that are hazardous are to be documented in Material Safety Data Sheet or MSDS. This in itself is not new since Egyptian physicians while preparing their prescriptions more than 4000 years ago practiced similar method of documentation. However, this is a significant move that will usher in an era of health and safety in the working environment in particular. Hereafter all personnel dealing with the manufacture, packing, testing, transporting or handling in any manner and the demolition of these chemicals would need to be fully aware of the risks involved, the safety precautions to be observed and the manner of handling any untoward accident or incident.

MSDS demands that all such hazardous chemicals would need to be documented. The sheets must contain the name of the chemical, and the full particulars of the producer as well as the supplier. The constituents must be specified along with the important physical data such as vapor pressure, boiling point, odor and its reactivity with other substances. The degree of inflammability as well as its sensitivity to spontaneous explosion is to be mentioned as well as the protective gear and first aid measures that would be required while combating any accident or incident. There are regulatory bodies such as the National Institute for Occupational Safety & Health Administration (NIOSH) and competent agencies offering services concerning MSDS authoring.