Availability of Safety Data Sheets (SDS) - 985-1-IPG-037 (WHIMS 2015) 

1. Purpose

To provide information about changes to requirements regarding the availability of safety data sheets (SDS). [Section 10.34 of the Canada Occupational Health and Safety Regulations (COHSR)].

Prior to its revision, employers were allowed to make electronic versions of safety data sheets provided by the supplier available to employees and the work place committee or health and safety representative by means of a computer, if the employer took steps to keep the computer working, instructed employees on how to use it and kept the original SDS available.

2. Issue

Employers are required to keep readily available for examination in any work place in which an employee is likely to handle or be exposed to a hazardous product, a copy of the work place SDS if the employer produces the hazardous product or replaces the supplier SDS. In any other case the supplier SDS must be readily available. [Subsection 10.34(1) of the COHSR].

3. Questions and answers

Question 1. If an employer prepares electronic versions of supplier SDS and makes them available to employees, the policy committee, the work place committee and/or health and safety representative, must that employer also keep a hard copy of the SDS readily available at the work place at all times?

Answer 1. No, hard copies are no longer explicitly required to be kept available. The amended definition of “readily available” in Part X of the COHS Regulations recognizes the importance of having information readily available without specifying the need for paper copies. Although, employers are not required to keep paper copies of the SDS at each work place, they must ensure SDS can be viewed in the work place and are accessible at all times (in other words: electronically) This could include, but is not limited to, maintaining physical hard copies, using battery backup power supplies, having multiple working terminals (redundancy).

Work place and supplier SDS must be made available in any form, as determined in consultation with the policy committee, the work place committee and/or health and safety representative (HSR). [COHSR subsection 10.34(2)].

Additionally, at least one printer should be available at the work place in order to provide a hard copy of the digital SDS at the request of an employee, the policy committee, work place committee and/or the health and safety representative, first aid attendant or emergency medical services.

Question 2. What happens to the original supplier safety data sheet?

Answer 2. The employer must keep a copy of the supplier SDS present and accessible for examination upon request by an employee, the work place committee and/or the health and safety representative at all times. Where the employer’s work place is limited to one building, the supplier SDS must be available for examination at that location. For the employer who has branches in different locations throughout Canada, they may keep the original of the supplier data sheets at a central location in Canada.

Question 3. Do all SDS need to be in both English and in French?

Answer 3. Yes, the SDS must be readily available in English and in French in any work place in which an employee is likely to handle or be exposed to a hazardous product. [COHSR subsection 10.34(1)].

The Hazardous Products Regulations require that the information elements provided on an SDS and on a label for hazardous products be in both official languages of Canada.

The information elements may appear either on a single bilingual document or as two unilingual parts that constitute one bilingual SDS.

It is the same for a label; information elements may appear either on a single bilingual label or in a group of information elements in two unilingual parts that constitute one bilingual label.