Labelling requirements for hazardous products in laboratories - 985-1-IPG-027 (WHIMS 2015)

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Effective date: September 2017

1. Subject

To clarify the requirements for hazardous products in work places that are laboratories, [Paragraph 125.1(d) of Part II of the Canada Labour Code and section 10.39 of the Canada Occupational Health and Safety Regulations (COHSR)].

2. Issue

Some of the labelling exemptions for laboratories that existed under the Workplace Hazardous Materials Information System (WHMIS) 1988 have changed as a result of WHMIS 2015 and amendments to COHSR Part X.

3. Questions and answers

Question 1. What are the new requirements for labelling hazardous products in laboratories under WHMIS 2015 and amended COHSR?

Answer 1. In general, hazardous products in laboratories are subject to the same WHMIS labelling requirements as in all other work places. Hazardous products must have a label provided by the supplier (supplier label) affixed to the container received in the work place. This label must provide:

  • the product identifier, [Hazardous Products Regulations (HPR), paragraph 3(1)(a)];
  • the initial supplier identifier, [HPR, paragraph 3(1)(b)];
  • the information elements, namely, the symbol, signal word, hazard statement and precautionary statement, [HPR, paragraph 3(1)(c)];
  • additional information elements specified and any applicable precautionary statements [HPR, paragraph 3(1)(d)]; and
  • other requirements depending on the classification of the hazardous product [HPR, paragraphs 3(1)(e) and (f)].

The hazardous product may be decanted into another container (or containers); however a compliant supplier label must always be affixed to the container in which the hazardous product is stored.

Question 2. What are the new requirements for labelling laboratory samples of hazardous products in laboratories under WHMIS 2015 and amended COHSR?

Answer 2. Unless exempt, Laboratory samples must have a label provided by the supplier as indicated in Answer 1 above.

“Laboratory sample” means a:

  • (a) sample of a hazardous product that is packaged in a container that contains less than 10 kg of the hazardous product; and
  • (b) that is intended solely to be tested in a laboratory but does not include a sample that is to be used:

“Laboratory sample “does not include:

  • (a) a sample that is intended for testing other products, mixtures or substances; or
  • (b) for education or demonstration purposes.

Examples of laboratory samples include: diagnostic specimens (infectious blood, mucosa or tissue samples), soil or water samples contaminated with hazardous substances or mixtures, chemical mixtures of hazardous products that are in the process of being developed, and quality control samples of hazardous products (developed products being tested for quality).

There are two types of laboratory samples for which labelling exemptions continue to exist:

  1. Those classified only as “biohazardous infectious materials” (any microorganism, nucleic acid or protein that causes or is a probable cause of infection, with or without toxicity, in humans or animals) – Category 1; and
  2. Those where the possession of the hazardous product is transferred for a specific purpose such as being sent by a supplier to a laboratory for testing without:
    • the chemical name and concentration of the hazardous product or its ingredients are not known; or
    • the supplier has not offered or exposed the hazardous product for transfer of ownership (in other words not being sold).

Biohazardous infectious materials

A laboratory sample of a hazardous product being imported or sold and only classified as biohazardous infectious materials – Category 1, if exempt under subsection 5(5) of the HPR is exempt from the information normally required on a supplier label by paragraph 3(1)(d) of the HPR and in place of that information, the following must be provided:

  • the chemical name or generic chemical name of any material in the hazardous product classified as a biohazardous infectious material; and
  • the statement “Hazardous Laboratory Sample. For hazard information or in an emergency, call...” followed by an emergency phone number that enables the caller to obtain the information that must be provided on the safety data sheet (SDS) of a hazardous product.

Sample being transferred for a specific purpose

A laboratory sample of a hazardous product that has been transferred for a specific purpose without transferring ownership and where the chemical name and concentration of the hazardous product or its ingredients are not known, is exempt from the information normally required on a supplier label by paragraphs 3(1)(c) or 3(1)(d) of the HPR. In place of that information, the employer must provide the following:

  • if known by the supplier, the chemical name or generic chemical name of any material in the hazardous product classified as a biohazardous infectious material; and
  • the statement “Hazardous Laboratory Sample. For hazard information or in an emergency, call...” followed by an emergency phone number that enables the caller to obtain the information that must be provided on the safety data sheet (SDS) of a hazardous product.

Product transferred from original container

If a hazardous product in the work place has been transferred from the container in which it was received from a supplier or is produced in the work place, the employer is exempt from the conventional labelling requirements of supplier labels, work place labels or those of portable containers if:

  • employee education and training is provided as required by regulation;
  • the hazardous product is a laboratory sample;
  • the hazardous product is intended solely for analysis, testing or evaluation in a laboratory; and
  • the hazardous product is clearly identified by a mode of identification visible to employees that enable them to readily identify and obtain information with respect to the hazardous product or laboratory sample. [COHSR section 10.36 and subparagraph 10.37(b)(iii)].

4. Conclusion

Unless exempt as described above, hazardous products that are received in the work place, including laboratory samples, must have a label that provides all required information and was provided by the supplier, affixed to the container.

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