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A Guide to Chemical Safety Compliance

Why do I need a guide to chemical safety compliance?

Employees use chemical products in workplaces every day. Most never think about the potential consequences nor about the possibility that use of the chemical products may harm them or fall under legal regulations. But this is going to change. In Ontario, Canada, the Occupational Cancer Research Centre is now publishing occupational disease statistics, by sector. Before long, all employers will be having a closer look at the chemicals they manage to ensure they reduce the risk to your employees.

A guide to chemical safety compliance will help give you an overview of how to determine if your workplace chemical use is regulated and if so, how to meet the requirements of applicable regulations.

The guide discusses how to: develop and maintain an accurate record of your chemicals and their Workplace Hazardous Materials Information System (WHMIS) or GHS (outside of Canada) safety data sheets (SDSs); understand the harm they can cause to employees and the environment; judge the likelihood of this harm occurring in your organization; spot the gaps in your chemical safety management system that could prevent the harm; close the gaps to protect people and the planet; train employees; review and maintain the process.

Chemical safety compliance has a steep learning curve but by following this guide, you will find that the process becomes intuitive and before long, you and your team will be managing chemical safety in realtime!

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Chemicals can and do hurt people in workplaces every day. In Canada, the cost of this harm to our society is measured in the billions of dollars.

Regulations are passed into law to make employers aware of their need to understand how chemicals can hurt people and the environment. They also provide the necessary enforcement tools, in the form of fines, to “encourage” employers to prevent the harm.

In Canada, the regulations to protect the environment are set by both the Canadian as well as the provincial/territorial governments. Whereas the regulations for occupational health and safety fall solely under the control of provincial/territorial governments, unless you work for a federally regulated industry, which is regulated under the Canada Labour Code.

If you manage large quantities of chemicals that can cross your air, water or soil property lines, you will need to be aware of the environmental laws in addition to the occupational health and safety laws.

The Canadian Centre for Occupational Health and Safety (CCOHS) compiles a list of regulations by province/territory. You can either subscribe to the service or use the search and resulting list to become aware of the regulations that apply for your business and then look them up using a search engine.

This article is written to help employers with compliance mainly to occupational health and safety regulations.

If we look at Ontario’s Occupational Health and Safety Act (OHSA), which is similar to many occupational health and safety laws around the world, the general duty clause, Section 25 (2) (h), states:

an employer shall, …

take every precaution reasonable in the circumstances for the protection of a worker …

While there are many chemical-related regulations under OHSA, essentially if you can show that you have taken reasonable precautions to protect workers and the environment from harm, you have achieved chemical safety compliance.

This guide to chemical safety compliance discusses how you can break down the requirements for chemical safety compliance into 3 groups. Next it gives you tested strategies on how to successfully complete each of the requirements.

The 3 major requirements to meet chemical safety compliance are:

  • Assess the potential risks that hazardous chemicals pose within your organizations.
  • Control risk of harm to people and the environment.
  • Train employees.
3 Steps to Chemical Safety Compliance

Figure 1: A guide to chemical safety compliance - 3 steps - A.C.T.

An important part of chemical safety compliance is the ability to review your procedures and control measures to ensure they are working as you intended – an audit. So, to achieve compliance, you will need a sustainable system.

Achieving chemical safety compliance can take anywhere from months to years, depending on the number of chemicals you manage, the tools you use and the resources you apply to the problem. If you are starting from scratch, it is best to take the time to think about your "system" in advance and develop it as you go.

Once your system is in place, you will have peace of mind that you are compliant and have done what you can to improve workplace health and safety.

1.0 How do I assess my chemical hazards?

In order to properly assess your chemical hazards, there are 4 steps to follow. They are:

1.   Start with an accurate inventory of your chemicals.

2.   Obtain up-to-date Workplace Hazardous Materials information System (WHMIS) safety data sheet (SDS) for each chemical. These will identify the chemical hazards for you.

3.   Prioritize your hazards for review.

4.   Identify gaps in safe chemicals handling.

RilleaTech's 4 steps to assessing chemical risk

Figure 2: A guide to chemical safety compliance - 4 steps to assess chemical hazards

1.1 How do I develop an accurate inventory of my chemicals?

Getting an accurate account or inventory of your chemicals can be a grind. It depends on how your people purchase chemicals. We typically see one of 3 ways that people buy chemicals:

  • All purchases are made through the purchasing department.
  • Chemicals are bought by individuals with company credit cards.
  • A mixture of 1 and 2.

If you fall in category #1, this is the easiest. You can simply gain a list of chemicals purchased in the last year or two from your purchasing department. The records should have product numbers, which will make it easy for you to find the WHMIS SDSs for the products. While this approach is a great start, it won’t help you identify older products that are still in use. To do this, you will need to do a “field check”.

If you fall into category #2, building your chemical list is going to take some time. You could try to contact your suppliers and ask them to send up-to-date WHMIS SDSs for all the chemicals purchased in the last year. This will get both your list and WHMIS SDS collection started but won’t help with products purchased from department stores or older products that are still in use. For a complete inventory, you will need to build your list with a “field check”.

If you fall in category #3, you can build your list using the suggestions above, but you also will need to check your list through a “field check”.

1.1.1 How to organize a “field check” for my chemicals?

Completing a field check for chemical products is time-consuming, and you will want to be organized to make it as efficient as possible.

Here are a few options you may want to consider:

  • Assemble a team of people – one from each department.
  • Hire students to do the work for all departments.
  • Hire a company like SDS RiskAssist to conduct your field check for you.

Once you have decided on who will conduct your field check, you will want clear communication about what you are looking for.

Communication is key to efficient chemical inventory

Figure 4: A guide to chemical safety compliance - clear communication is key to efficiency

Keep in mind that you will also need the WHMIS SDSs for these chemical products. Recording information from the chemical product labels, while you are doing your field check, will make sourcing the WHMIS SDSs easier.

Here are a few tips to get you started quickly:

  • If your team does not have central SDS Management software like SDS RiskAssist, provide them with access to an Excel or similar spreadsheet to ensure you are clear about the information you want them to collect.
  • Organize sub-sheets within your spreadsheet by department.
  • Ask your team to spend 1 - 2 hours per day taking and uploading the 3 photos per product recommended in the Google spreadsheet, until you have a list of all chemical products. The task can be boring so try to break it up with other work so that you get reasonable attention to detail for collecting the right information.
  • Remember to include cosmetics, drugs, pesticides and consumer products if employees are required to handle these products in your workplace.
  • Note that some suppliers include URL links to the WHMIS SDS as a QR code on the label. Add this URL to Google spreadsheet for easy reference later.

1.2 I have a list of chemicals. What is the easiest way to find the WHMIS SDSs?

Once you have an accurate list of chemical products with the information suggested in the RilleaTech’s Chemical List & SDS Tracking Spreadsheet, you will have several choices about how to build and maintain your WHMIS SDS collection. You can:

1.   Source the SDSs on your own using a search engine like Google and store the sheets as pdfs or in paper. If you follow this approach keep these thoughts in mind:

By law, employees are required to have easy access to WHMIS SDSs.

You will want a system that is easy for employees to search.

Since SDSs can frequently be updated, you will want a system that is easy to maintain.

2. Hire a subscription services like SDS RiskAssist to source and manage your WHMIS SDSs and make them accessible to employees on mobile and desktop devices. Note that if you use a subscription service you need to view them as a partner in your chemical safety efforts. No outside service can ensure all your sheets represent the chemical products you use and are up-to-date, without your help.

Before you decided to hire a subscription service, it is important for you to know that there is a variety of offerings. The range varies from organizations who simply host your SDS collection on the internet, to those who offer platforms that use software to read SDSs for you and enable you to interact with the software to help you meet your chemical safety and training goals. If you have fewer and lower hazard chemical products, a system to host your SDSs may be all you need. If your operation is complex with hundreds or thousands of chemicals, you will want a more robust system that does lots of the work for you.

Video 1: A guide to chemical safety compliance - How RilleaTech’s SDS RiskAssist™ works

If you’ve decided to hire a subscription service, simply give them the chemical list that you’ve created and look forward to obtaining access to your collection within a week or two, depending on the size of your collection.

If you’ve decided to manage the work yourself, then you can proceed as follows:

  • Sort your list by supplier and either;

-  Visit the supplier’s website and download the SDSs required,

-  Or send the supplier your list and ask them to provide up-to-date SDSs.     

  • Organize your SDSs by department within your sharing medium. (Keep in mind that people will search for information in different ways. For example, for Krylon Yellow Spray Paint, people may start their search on yellow, paint, krylon or spray. If your system does not have robust search capability, ensure that how the SDSs are filed is part of your training to employees.)
  • Delegate a team member from each department to maintain their SDS collection, once you have completed the work to compile it.
  • Communicate to employees how they can access the collection.

1.2.1 I have all my WHMIS SDSs. How do I identify chemical hazards?

Congratulations! You now have a relevant collection of WHMIS SDSs, as required by Ontario Regulation 860, a regulation under Ontario’s OHSA. Similar regulations for other provinces can be found at

This is a great start to chemical safety compliance!

If you’ve chosen to subscribe to a digitalized SDS Management platform like SDS RiskAssist, your WHMIS as well as other regulatory hazards will instantly be available and organized on the platform. You will receive training about how to interact with the platform so that you can decide how best to prioritize which hazards to assess first.

If you have chosen to manage your SDSs in-house, you will now need to read the material to identify the types of hazards in the chemicals your organization purchases.

WHMIS 2015, states hazards in plain English; “Causes serious eye damage”, “Fatal if inhaled”, “Causes severe skin burns”, “Highly flammable liquid and vapour”. Most of us can easily understand what these phrases mean and you do not need to be an expert.

1.3 How should I prioritize the chemical hazards?

Prioritizing chemical hazards is subjective to your company. Only you can decide which hazards may carry the highest risk, based on your risk tolerance and existing safety programs.

However, chemical safety is new and foreign to most people. To help our clients, we give them a starting point by classifying hazards into 4 groups.

  • Urgent
  • Occupational disease
  • Common
  • Not classified

Urgent are WHMIS hazards with the skull, oxidizer or exploding bomb symbol plus some high hazard flammables such as products that may ignite if spontaneously exposed to air and pyrophorics. These hazards are immediately dangerous to your people AND the type of hazard and form of control is not very common. We also consider documents that do not meet the Canadian Hazardous Products Regulations, which we classify as “not identified” and MSDSs urgent because these documents do not accurately define the hazards to your people.

Figure 5: A guide to chemical safety compliance - SRA™ urgent chemical hazards

Occupational disease are those chemicals that pose an immediate or long-term risk of disease to people and/or the unborn. WHMIS hazards with the Health symbol (aside from aspiration hazards) fall into this category, as well as hazards that can cause allergic skin reactions or harm to breast-fed children.

RilleaTech classified

Figure 6: A guide to chemical safety compliance - SRA™ occupational disease hazards

Common are WHMIS hazards whose risk of harm is usually lowered by typical safety programs. For example, fire hazards or hazards that can cause harm to eyes and skin, can be controlled with standard safety glasses, gloves, ventilation and fire safety programs.

Not classified are chemical products that suppliers have evaluated against the Canadian Hazardous Product Regulations and found that they do not have applicable hazards. No further work is required with these chemical products.

Based on our data, Figure 7 represents the general distribution of these groups of hazards that we see across our client organizations.

SDS RiskAssist Software data

Figure 7: A guide to chemical safety compliance - Distribution of hazards in a typical organization

If you are using an interactive subscription system such as SDS RiskAssist, we recommend that you start with your urgent hazards and progress to your occupational disease hazards. You will easily be able to group these hazards by location/department and start planning you risk assessment activities.

If you are using an in-house system, we recommend that you build an Excel spreadsheet to summarize the hazards of all your chemicals so that you can group them according to your priorities. Toronto Metropolitan University has developed what they call CHAP (Chemicals Hazard Assessment and Prioritization) Tools that may be helpful to get you started.

If you manage less than 50 chemicals, this task is doable with a spreadsheet but time consuming. Expect this task to take you about 1/2 hour per chemical. More if you are also recording chemicals that have ingredients listed as designated substances on Ontario Regulations 490 and 833. Add still more time if you are also noting ingredients on the Environment Canada’s Toxic Substances List and you are investigating recommended PPE. You will also have to revise the spreadsheet each time chemicals change.

If you are managing between 50 and 100 chemicals, this task borders on impossible to sustain over time. Think hard about spending this time compiling versus investing in a service that will compile the information for you in a fraction of the time. Wouldn't it be preferable to get to your risk assessment faster?

If you are managing more than 100 chemical products, a subscription to a smart and interactive SDS Management platform is a must! You will save time, money, accelerate progress towards your occupational health and safety goals and avoid unnecessary risk.

1.3.1 Where do I start to assess my risks posed by chemicals hazards?

Before you begin your risk assessment, think about what you want to achieve with this exercise. Ideally, you will want at least the following 2 outcomes:

1.   A clear framework of your organization’s risk tolerance.

2.   An understanding of the risks that chemical products pose to your organization. Defining Your Risk Tolerance

It is important to understand that risk tolerance is closely associated with an organization’s values and therefore will vary from organization to organization.

Figure 8 shows an example of a simple risk matrix that you can use to think about your risk in any key part of your organization. Red typically represents intolerable risk and requires action to reduce. Yellow means that action is suggested but not mandatory and green requires no action.

Figure 8: A guide to chemical safety compliance - Example risk matrix

An organization’s risk tolerance is ultimately set by the employer and/or the board of directors. From financial risk to operational risk to chemical risk, whether you realize it or not, employees are making decisions on behalf of your organization. The best way to ensure they are making decisions that are in line with your organization’s values is to educate them about the what risks are acceptable.

An organization with a risk tolerance that is high may use only 1 red square in the risk matrix. The advantage is that the cost associated with proactive measures to control risk is lower and the organization can be very agile to respond to market changes. The disadvantage is that the risk of harm to people and/or the environment can be higher, which can result in fines, legal action and loss of reputation.

An organization with a risk tolerance that is low may have 5 or 6 red squares in the risk matrix. The advantage here is that there is lower risk of harm to people and/or the environment with less chance of fines and loss of reputation. The disadvantage is the higher cost of the proactive measures to prevent harm.

Formalizing your risk tolerance gives you a basis for discussions with your team and enables you to adjust and improve over time. Understanding Your Risk

Risk of harm from chemical products depends on the kind of harm that a chemical product can cause and the likelihood that the harm will occur.

Figure 9: A guide to chemical safety compliance - The risk equation

WHMIS already determines the kind of harm that a product can cause, so now that you have your WHMIS hazards organized, you are halfway there.

Like risk tolerance, only people within an organization can determine the likelihood of the harm occurring due to handling, storage and use of chemical products. In order to determine the likelihood, consider how the chemical product is being used with following points:

a. Why is it being used?

b. How much is needed?

c. For how long?

d. Under what conditions?

e. How often?

f.     How is it stored?

g. How is it disposed of?

The easiest way to think about likelihood of the harm occurring is to first assume that you have nothing in place to prevent the harm.

Next you would use your risk matrix to determine the risk that your employee could experience the harm defined by WHMIS, if they used the chemical product in the typical way, during their years of employment in your organization.

Let’s walk through a simple example with eye hazards.

Figure 10: A Guide to chemical safety compliance - WHMIS eye hazards with example products

Figure 10 shows the 3 levels of WHMIS eye hazards with examples of the types of chemical products that fall into each category. The hazard statement defines the severity of harm that the products can cause, if you get it in your eye.

We all know what getting soap or shampoo in our eyes feels like. This “harm” is considered eye irritation and it typically recovers in less than 7 days.

Getting paint or cleaner in your eye hurts more and for products that have the WHMIS Exclamation symbol, “harm” is referred to as serious eye irritation. This time, it may take up to 21 days to recover.

If you get splashed with a product that has a WHMIS Corrosive symbol like liquid bleach, the “harm” you can experience is serious damage to the eye tissue and is irreversible.

To evaluate the likelihood of an employee experiencing irreversible eye damage with the use of bleach, consider that the employee is working with the product without safety glasses and then consider how the product is being used by the employee:

  • How the bleach is applied; spray, liquid or wipe?
  • Is it ready-to-use or must it be diluted?
  • What is it being used on; below, at or above eye level?
  • How long does the job take; seconds, minutes, or hours?
  • How often is the job performed; hourly, daily, weekly, monthly, yearly?

Once you have answered these questions, you will be able to determine the risk of an employee getting bleach in their eye and suffering irreversible eye damage. Now you can begin to think about ways to reduce the risk, if necessary, based on your organization's risk tolerance.

1.4 How do I identify the gaps in my chemical safety management program?

Once you have a good understanding of your hazards and risk of harm due to your chemical products, you will need to consider two types of gaps:

1.   Regulatory

2.   Organization-specific safeguards

1.4.1 Regulatory Gaps