A common question Chemscape is asked regarding the transition to GHS and WHMIS 2015 is whether only one SDS is now required. Does one SDS work now for all countries since it is a Globally Harmonized System(GHS).
Although the GHS has introduced standardized communication for Labels and Safety Data Sheets, countries have adopted these standards into their own legislation, and SDSs still vary significantly by country. A variance can result in a different classification, labelling, SDS or other information requirements for a hazardous product in Canada versus another like the USA. An experienced SDS author can help you navigate the constantly changing classification and regulatory landscape.
- Although we have common GHS standards there is no harmonization between countries. The Globally Harmonized System was created by the United Nations. It is currently in Revision 7. It is up to individual countries to adopt what revision they want. There are differences in GHS requirements by country. The GHS was created with a building block approach and this allows countries to adopt the standards into their jurisdictions as best suits them. Every country decides what revision to implement. For example, currently the USA uses revision 3 and Canada uses revision 5. These leads to a lack of harmonization between countries.
- Every country has unique regulations for transportation and the environment. On top of GHS standards every country has local regulations like transportation or environmental regulations that are unique and need to be integrated into Safety Data Sheet authoring.
- Local regulations and classifications keep changing. If you pay attention to TDG in Canada particularly since the Lac Megantic tragedy you will be aware of how these standards are not static and require someone to keep up-to-date with regulatory changes.
- Classification of substances vary between countries. As there are different revisions of the GHS being adopted by different countries we see substances classified differently between jurisdictions.
- Toxicity data is ever changing. Research is constantly evolving with new data being published daily on the effects of toxicity of certain substances on humans, animals, and the environment.
- Exposure scenarios can be difficult to predict. The SDS author often needs to work with the client to predict possible exposure scenarios. Data can often be absent.
- Exposure cut-offs can vary between countries. What may be considered acceptable in one country may have greater restrictions in another.
- Ingredients can be allowed for commerce in one country and not in another. In Canada the Domestic Substance List contains approximately 23, 000 substances approved for commercial use, import and manufacture.
- Concentration ranges for ingredients can be used differently in different countries.
- Confidential Business information is withheld in the client’s best interest and there are different methods to do this according to country location.
For all the above reasons, SDSs still differ significantly between countries. SDSs should still be updated on a routine basis to ensure current data is available. In BC, Saskatchewan and the Territories their provincial WHMIS 2015 laws require the employer to check every 3-years if any significant data have changed. For suppliers, the SDSs must be accurate at the time of sale or import, for each sale or import. It is a requirement to update the SDS when significant new information becomes available.