MYTH #1:
All consumer products are exempt from WHMIS. Wrong on two counts. The exemption only applies to the WHMIS labeling and MSDS provisions: you still have to train your staff in the safe use of a hazardous consumer product And if you buy it in bulk or transfer it to another container, you’ll still need a WHMISstyle label.

MYTH #2:
Very small containers don’t have to be labeled. Wrong. There is no exemption for small quantities of a controlled substance, although the label of a container holding less than 100 miIlilitres must only display the name of the supplier, hazard symbols and a statement that an MSDS is available. If a bottle is too small for a label, then attach a tagwith the required information.

MYTH #3:
As long as I’m trying to get a missing label from my supplier, I can use their controlled product until it arrives. Wrong. You can’t use a controlled product without a label under any circumstances. You either have to wait for your supplier to come through or make one yourself. However, you can store the unlabeled shipment on-site in the meantime.

MYTH #4:
There is a list of controlled products that WHMIS applies to. Wrong. There is no such list. If a substance meets the WHMIS criteria, and if it is not specifically covered by any other regulatory regime, it’s a WHMIS controlled product. True, most substances have been classified, and if they’ve been considered controlled products in the past, they probably still are. But there’s no master list you can look them up on.

MYTH #5:
The Ingredient Disclosure List contains the names of all the controlled products subject to WHMIS. Wrong. The IDL is a list of chemicals that, if present above a specified minimum concentration, must be identified on a product’s MSDS. And it’s not exhaustive.

MYTH #6:
At least I don’t have to worry about the maintenance company I’ve hired to clean the building. Wrong. Employers are responsible for the proper labeling of controlled products brought to the workplace by a contractor. You must ensure any contractor you hire understands, and complies with, WHMIS.

MYTH #7:
If the MSDS says so, it must be true. Wrong, wrong, wrong. Studies have shown that MSDSs are frequently out-date, missing important information, tainted with misleading information and sometimes just plain wrong. If possible, it is a good idea to get copies of MSDSs for common or generic chemicals from a number of sources and compare the contents.

MYTH #8:
All MSDSs are created equal. Wrong. The Controlled Products Regulations (CPR) are very specific about the information MSDSs must contain. Canada currently accepts MSDSs which use the no, ISO or EC headings, but whenever you get an MSDS from a foreign supplier, look for the following statement: "This product has been classified in accordance with the hazard criteria of the CPR and the MSDS contains all the information required by the CPR".

MYTH #9:
My shipper says the TDC label doubles as a WHMIS label. Not entirely wrong, but misleading. The WHMIS label is very similar to the safety markings a shipment requires under the Transportation of Dangerous Goods Act. But not every "controlled product" is a "dangerous good" and may not be labeled. And each inner container in a shipment will still need an individual WHMIS label.

MYTH #10:
Bulk shipments need a WHMIS label. Wrong. Bulk containers, tank cars, freight containers and the like don’t need a WHMIS label. However, if you decant or transfer a controlled product into a smaller container, you will need a workplace label.

WHMIS, who are you canna call?

Copies of the federal WHMIS legislation and regulations are available, for a small fee, through the Canadian Government Publishing Centre (phone: 819.956.4802) or the nearest government bookstore. However, if you have computer access to the Internet, you can download an unofficial version of all other relevant WHMIS statutes, off the Access to Justice Network (http://legis.acjnet.org). Be aware, however, that the elctronic version of the text has no official sanction because it isn't guaranteed to contain the most recent amendments. But as the feds haven't amended the relevent WHMIS-related sections since 1989, the on-line version is still current.
WHMIS is a national program and the basic requirements are uniform across the country. However, individual provinces and territories may have introduced some minor refinements in intregrating the WHMIS program with their occupational health and safety regulatory regime. Contact your local agency for details on any special WHMIS requiremnts.

Federally regulated workplaces laws and regs:
The Hazardous Products Act, the Controlled Products Regulations, and the Ingredient Disclosure List, contact Human Resources Development Canada, (819.953.0215).
Alberta regs:
Designation of Hazardous Materials Regulations, contact Alberta Labour (403.276.3137).



First published September 1999