Keeping WHMIS SDSs up to date for employee health and safety

Managing safety data sheets (SDSs) to ensure WHMIS compliance is critical for employee health and safety at your workplace. But it can be a daunting, frustrating process for any workplace health and safety professional.

Given that the average workplace has 120 chemicals on site, managing SDS is a complex undertaking that requires ongoing attention. Safety leaders face a number of challenges keeping safety data sheets up to date:

New WHMIS 2015 rules

With the adoption of WHMIS (Workplace Hazardous Materials Information System) 2015, a supplier is only required to provide you with an SDS when you make a purchase. Suppliers no longer have to routinely update a product's safety data sheet every three years, as they did in the past with material safety data sheets (MSDSs) under WHMIS 1988.

Instead, under WHMIS 2015, suppliers are required to update the product SDS within 90 days of becoming aware of significant new information. But they are not required to let you know that the SDS for a product in your inventory has changed. And if you re-order a product and you receive an SDS, you’ll need to compare old and new versions to see if there are changes.

That means that the date of the SDS is no longer the only metric to determine its compliance.

SDS sourcing

Another challenge with updating SDSs is that the sheer number of mergers, acquisitions and rebranding in the chemical product industry make it difficult to track which company owns a particular product, resulting in duplicate SDSs and/or obsolete products.

In addition, the majority of suppliers now require their customers to do the work of finding and obtaining SDSs from websites, that may or may not be based in Canada.

These challenges can leave you floundering regarding how and when to update SDSs, the basis for your regulatory compliance and chemical safety practices. 

Before we dive in to how to tackle the problem, let's review some WHMIS compliance basics:

WHMIS SDS requirements: the basics

WHMIS requires employers to ensure that employees have access to up-to-date Safety Data Sheets (SDSs) for all hazardous products in your workplace.

SDSs are an important workplace health and safety tool: they provide a detailed description of a chemical product’s hazards, including possible health effects related to short- and long-term exposures. They also provide additional information on safe use, handling, storage and disposal procedures. This information is essential to protect workers and to reduce the prevalence of occupational disease in Canada.

Ontario Regulation 860 (WHMIS) outlines the requirements for updating safety data sheets as follows:

(1) An employer who receives a hazardous product from a supplier for use, storage or handling at a workplace shall obtain a supplier safety data sheet for the hazardous product from the supplier unless the supplier is exempted under the Hazardous Products Regulations (Canada) from providing a safety data sheet for the hazardous product. O. Reg. 168/16, s. 11.

(2)  An employer shall update a supplier safety data sheet obtained under subsection (1) as soon as practicable after significant new data about the product is provided by the supplier or otherwise becomes available to the employer. O. Reg. 168/16, s. 11.

The Canadian Centre for Occupational Health and Safety further explains that “an SDS must be updated when there is new information that changes how the hazardous product is classified, or when there are changes to the way you will handle or store or protect yourself from the hazards of the product.”

While Canada's Hazardous Products Regulations require suppliers to update their SDSs only if new information becomes available, it is important to note that each provincial/territorial jurisdiction in Canada regulates occupational health and safety.

See our SDS RiskAssist Guide to SDS Management to understand the requirements for the jurisdiction(s) that your business operates in.

Practical tips for keeping your SDS collection up to date

Given WHMIS requirements and the challenges above, how do you go about keeping your SDS collection up to date?

Our strategies at SDS RiskAssist are based on data insights from more than 100,000 safety data sheets in 3000+ workplaces. Our analysis shows that:

• In an unreviewed collection 5% of documents are duplicates
• Another 10 % of sheets are obsolete, discontinued or no longer required
• The average difference in dates between an older and newer version of an SDS is 3.3 years
• Only 17% of reviewed SDSs have newer versions with significant differences in hazards. Only 17% of SDSs actually needed to be replaced
• The percentage of sheets which required replacement varied by supplier from 0-75%

The fact is, it’s virtually impossible to ensure your SDS collection is 100% up to date at all times. However, the data above unlocks important insights for a practical and effective approach, summarized below.

5 steps to update your SDS collection

Based on SDS RiskAssist data, we recommend the following 5-step process to identify and update the safety data sheets in your collection:

1. Check for and eliminate any duplicate SDSs
2. Check if you are still using any MSDSs or any SDSs over 7 years old
3. Update your largest suppliers first
4. Ensure that any information attached to the existing document (i.e., where used) is assigned to the new SDS
5. Remove the replaced sheet from your active collection so as not to create confusion amongst workers

Learn more about when and how to update SDSs.

How SDS RiskAssist technology solves the problem of updating safety data sheets

SDS RiskAssist uses digital technology to automatically extract critical information in your safety data sheets and summarize it in actionable ways:

• Quickly identify potential duplicate SDSs in your collection and merge them into a single entry at the click of a button
• Rapidly sort existing SDS sheets to find potential obsolete documents
• Consolidate all brands, subsidiaries and affiliated companies under the parent supplier’s names
• Know when to update your SDSs: we provide links to supplier webpages (available for 85% of SDSs in a typical collection) with target replacement dates based on historical data
• Automatically replace SDSs using the supplier URLs or pdfs, which also copies attached data over and archives older SDSs