Keeping Safety Data Sheets (SDSs) up to date can take a huge amount of time. Time that most organizations do not have. But not having current information puts workers at risk for both acute and chronic health issues.

What The Regulations Say

In Canada, the Hazardous Product Act (federal legislation) and the provinces WHMIS legislation outline supplier and employer responsibilities with respect to keeping SDSs up to date:

• Suppliers must ensure that the SDS for a hazardous product is current every time the product is sold
• Suppliers are not required to provide employers an updated SDS for prior purchases
• Employers must obtain a current SDS for all hazardous products present in the workplace
• Employers must update the SDS in the workplace after significant new data about a product becomes available
• Most provinces have eliminated the 3-year rule that required sheets to be replaced based on their age

Safety vs Compliance

To most people, keeping SDSs up to date is a question of compliance – “Am I meeting the Regulations?”

For those who are committed to the principles of worker health and safety however, they might take a different approach to keeping SDSs updated.

Case Study

On September 26, 2019 an employer went to the supplier’s website to get an SDS for a chemical they were using. The SDS had been revised on April 13, 2018 and said the product is “not a hazardous substance or mixture”.  Clearly the employer is in compliance to the regulations – arguably exceeding the requirements as they have a current SDS for a non-hazardous product.

However, when this sheet (and 1,000’s of others) were loaded into SDS RiskAssist the employer got a different perspective.  SDS RiskAssist identified the product, as well as many others, as containing a Designated Substance (as defined by Ontario Regulation 490). In checking Section 3 of the SDS, the designated substance made up a significant portion of the product composition so how could the product be classified as “not a hazardous substance or mixture” ?

This led the employer to check for an updated SDS. The supplier had posted a new sheet to their website on October 24, 2019.

The new SDS had the following hazard statements (bold indicates signal word DANGER).

• Causes skin irritation
• May cause an allergic skin reaction
• Causes serious eye irritation
• Fatal if inhaled
• May cause allergy or asthma symptoms or breathing difficulties if inhaled
• May cause respiratory irritation
• Suspected of causing cancer
• Harmful to aquatic life with long lasting effects

A significantly different document than the original SDS. And one the employer updated not because they were out of compliance, but because they could quickly assess 1,000’s of SDSs and evaluate hazard statements and ingredients against provincial regulations. Knowing the product contained a designated substance was a flag to look for better information.

Digital Technology Saves Time

Flagging SDSs with hazardous ingredients using digital technology and then checking those for updates or accuracy can save you time and focus your efforts on the critical safety and health hazards your workers are exposed to.

Safety Data Sheets are often viewed as a burden that must be managed periodically by some unfortunate person in the organization. In fact, they are essential for good worker health and safety. Contact us to understand your chemical hazards.