Updated Sept. 19, 2023
WHMIS rules for SDS updates: when and how to keep on top of it
WHMIS regulations require all employers to keep safety data sheets (SDSs) up to date for all chemical products in their workplace. That's because each SDS provides important information about a chemical product in a standardized format. This information includes the chemical product's ingredients, hazards, storage and transport instructions, safety precautions, and more. The rules around when to update SDSs changed with the introduction of WHMIS 2015. Now SDSs must be updated when significant new data about the product is provided by the supplier or otherwise becomes available to the employer. So what does that mean in practical terms to ensure WHMIS compliance? Let's jump in:
WHMIS 2015 requirements for SDS updates
Occupational health and safety is regulated at the federal and provincial/territorial levels in Canada. As a result, requirements for updating or replacing SDSs may also vary by jurisdiction.
The old WHMIS 1988 regulations required safety data sheets to be updated every three years – time was the key. That is no longer the case. WHMIS 2015 legislation typically states that employers are required to update the most recent supplier SDS at the workplace as soon as practicable every time significant new data about a product is provided by the supplier, or becomes available to the employer in some other way.
For example, the Province of Ontario’s guide to WHMIS legislation cites the following about updating SDSs:
- Under federal law, it is the supplier’s responsibility to ensure that the SDS for a hazardous product is current and complies with all applicable requirements every time the product is sold.
- Suppliers are not required to inform past buyers of a hazardous product that significant new data is available.
- “Significant new data” means information about a product that would change its classification … or change the ways to handle the product safely.
Tackling SDS updates: 4 practical strategies to get the job done
The three-year rule under WHMIS 1988 made it clear when a material safety data sheet (MSDS) update was required. While it was easy to understand, the time and effort to update the MSDSs every three years was more than most organizations could handle.
With WHMIS 2015, SDSs do not expire, which can save you the time and the expense of updating SDSs that have no significant changes. However, if a supplier does not inform you of a change, you likely will not know when an SDS should be updated.
This can be a huge but necessary challenge for workplaces with hundreds – or even thousands – of SDSs. If a worker has an urgent need to find an SDS, a well-organized, up-to-date collection can mean the difference between life and death.
The reality is that very few health and safety professionals have the time to sit down and tackle all SDSs for their chemical collection at once. So what's the best approach to comply with WHMIS regulations for keeping SDSs up to date?
Here are 4 practical strategies to make it easier to keep your SDSs up to date:
#1: Check for duplicate safety data sheets
The easiest way to reduce the work of updating SDSs is to get the number of sheets down by examining your SDS collection for duplicate sheets. Often a workplace will have multiple copies of SDSs for the same product with the same product code from the same supplier. Get rid of the extras. It’s easy to merge two, three, four or more SDSs into one using SDS RiskAssist. Plus you can also combine your data on location and inventory into that one SDS.
We recently onboarded a client who had 2,731 SDSs. Within hours of the onboarding the number of SDSs was reduced to 1,736 by merging duplicates - a 26% reduction. Now that’s a time saver!
Eliminating duplicate SDSs allows you to focus your attention on the remaining active sheets in your collection.
#2: Look for old safety data sheets, including any MSDSs, to update or eliminate
To stay on top of safety data sheet updates, it’s important to track your sheets by date and format. Look for any MSDSs in your collection. The term MSDS was updated to SDS when WHMIS 2015 was introduced.
MSDSs were required to be replaced by 2018. If you still have them in your collection you need to see if the product is still in use. The same is true in general for older sheets. Under Section 14.3(2) of the Hazardous Products Act, suppliers in Canada are only required to provide SDSs for six years after they stop providing the product. Therefore, we also suggest looking at sheets that are more than seven years old to ensure the product is still in use. Archive obsolete SDSs and replace MSDSs and older SDSs as soon as possible.
A cautionary tale: the case of the 35-year-old MSDS
When onboarding a new client, we found their oldest MSDS was for sodium hypochlorite, dated January 30, 1987. That sheet was 35 years old!
It started out as a paper sheet in a binder. At some point it was converted to a pdf and for the last 10 years it was hosted by a series of online SDS management providers. Over those 10 years our new client paid their previous SDS providers $60 to have quick access to an obsolete document. What they didn’t get was:
- An updated version of the SDS
- Notification that they had an old MSDS/SDS that maybe wasn’t required
- Insight into the hazards, ingredients or control measures to protect employees
What’s worse is we discovered they had 350 safety data sheets that were more than 10 years old. They had paid $21,000 for nothing!
#3: Update SDSs by target dates
SDS RiskAssist is the only SDS management software that helps you to prioritize SDS updates by setting target dates for each SDS. Target dates are set based on our data showing how frequently suppliers update their sheets and whether the SDS has significant new data. It allows you to prioritize what products you should check first for updates, and how often, to see if an updated sheet is available.
For example, one supplier we see in the marketplace has SDSs for their products on their website dated 2015-2017. There's no point checking these sheets after three years and then every year thereafter if those dates haven’t changed. Our data also show that a different supplier regularly updates their sheets every three years and half the time has significant differences. This supplier requires a different level of attention.
You can also link to supplier websites directly from our dashboard to speed up the process of replacing your SDSs using the supplier’s URLs or pdfs, while copying any of data you have added to the old SDS to the new one and then archiving the old SDS (again with date stamps).
Archiving safety data sheets
We recommend archiving any SDSs that you don’t need. This allows system administrators to continue to access them if required but they are not visible to other users. As a side note, you should not have to pay your SDS management provider to store documents that people don’t access and that are not being actively managed. SDS RiskAssist doesn’t charge you for archived sheets. Archived SDSs are like a safety net – the SDSs are there if you need them (with date stamps as to when they were archived), but they are not your main focus.
#4 Outsource your SDS updates to SDS RiskAssist
Make chemical safety a snap
SDS RiskAssist makes it easy for you to tackle the huge job of keeping SDSs up to date. We can take care of the entire process for you, or you can manage it yourself using our software tools to prioritize your work by sorting your chemical product collection by hazard, date, format, supplier, last update and other criteria to ensure you are in complete compliance with WHMIS regulations for SDS updates.
Please contact us if you have any more questions about safety data sheet updates or other chemical safety issues.