Updated Dec. 14, 2022
Update safety data sheets every time there’s significant new data
Workplace safety pros know that they must keep safety data sheets (SDSs) up to date to comply with WHMIS regulations.
But since the introduction of WHMIS 2015, how do you know when to update your sheets?
Under the old WHMIS 1988 regulations, time was the key – safety data sheets had to be updated every three years. That requirement changed with the introduction of WHMIS 2015.
WHMIS 2015 requirements for SDS updates
Occupational health and safety is regulated at the federal and provincial/territorial levels in Canada; therefore, requirements for updating or replacing SDSs may also vary by jurisdiction.
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.
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.
How to tackle SDS updates
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 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.
But you don’t have the time to sit down and tackle all of your SDSs at once. So how would you eat this elephant? One bite at a time!
Here are 3 strategies to get started:
Strategy #1: Check for duplicate safety data sheets
The easiest way to reduce the work of updating SDSs is to examine 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 sheets. Within hours of the onboarding the number of sheets was reduced to 1,736 by merging duplicates – a 26% reduction. Now that’s a time saver!
Eliminating duplicate sheets allows you to focus your attention on the remaining active sheets in your collection.
Strategy #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 and it was 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 sheet
- Notification that they had an old sheet that maybe wasn’t required
- Insight into the hazards, ingredients or control measures on protecting employees
What’s worse is we discovered they had 350 sheets that were more than 10 years old. They had paid $21,000 for nothing!
Strategy #3: Update sheets by target dates
With SDS RiskAssist we set a target date for when each sheet should be checked for an update. We can do this because we are the only SDS management software that maintains data on how frequently suppliers update their sheets and whether the SDS has significant new data. That data gives you the ability to prioritize what products you should check first for updates.
One supplier we see in the marketplace has SDSs for their products on their website dated 2015-2017. Why would you bother routinely checking these after three years and then every year thereafter when the 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. They require 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 sheet to the new one and then archiving the old sheets (again with date stamps).
Archiving safety data sheets
We recommend archiving SDSs that you don’t need. System administrators can still 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 sheets 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.
SDS RiskAssist makes chemical safety a snap
SDS RiskAssist makes it easy to tackle the huge job of keeping SDSs up to date by allowing you to sort your collection by hazard, date, format, supplier, last update and other criteria. That way you can prioritize your work to ensure you are in compliance with WHMIS regulations.
Also see our complete Guide to SDS Management.
Please contact us if you have any more questions about the requirements to update your safety data sheets.