Results at a Glance-Evaluation of the Workplace Hazardous Products Program 2014–15 to 2018–19
Health Canada’s Workplace Hazardous Products Program (WHPP) is responsible for the Hazardous Products Act (HPA), the Hazardous Materials Information Review Act (HMIRA) and their associated regulations. WHPP regulates Canadian industry, including importers, manufacturers, and suppliers, and requires them to communicate hazards associated with products through the provision of supplier labels and safety data sheets via the standardized Workplace Hazardous Materials Information System (WHMIS).
Implementation of WHMIS relies on a complex system of interactions between partners, including provinces and territories, and other stakeholder groups, such as suppliers of workplace chemicals, employers, and workers.
The annual budget is approximately $3M, with 32 Full-time Equivalents (FTEs); an additional 10 FTEs are being paid by the Directorate outside of Program allocations.
This evaluation examined the results, efficiency, and sustainability of WHPP for the period of 2014-15 to 2018-19.
- Document and File Review
- Literature Review
- Survey of P/T partners (Inspectors)
- Data Analysis
- Key Informant Interviews
- International Comparison
- Financial Data Review
- Case Study
What the Evaluation Found
Within a complex and interlocking multijurisdictional system such as WHMIS, engagement and coordination with various partners and stakeholders is essential. WHPP’s engagement with stakeholders is viewed as one of its strengths. Strong engagement with partners also helped WHPP increase the number of HPA inspections being conducted since 2017 by provincial and territorial (P/T) inspectors, and Employment and Social Development Canada (ESDC), as the occupational health and safety authority in federally regulated workplaces, at no additional cost to the Program.
WHPP successfully led the modernization of the HMIRA, which enabled it to streamline the process for confidential business information (CBI) claims review. This work allowed WHPP to make significant progress in addressing its CBI backlog, and enabled it to take a calibrated risk approach to reviewing future CBI claims.
However, supplier compliance with HPA requirements is low (e.g., compliance with safety data sheet and label requirements), and more could be done to inform and promote the safe use of hazardous products in the workplace. The current level of compliance and enforcement activities does not appear to be sufficient given the rates of non-compliance observed. WHPP’s inspection capacity remains limited, as it relies extensively on P/T capacity and ESDC. While this arrangement is cost-effective, it presents challenges in terms of capacity for inspection activities and consistency in implementation. Compliance enforcement tools currently available also limit WHPP’s ability to address compliance issues in a timely manner.
Consumer chemical products excluded from the HPA were found to be a growing concern for worker safety. In particular, the evaluation found that these products are being increasingly used in the workplace, but without adequate hazard information to allow workers to protect themselves from extended and repeated use.
Additional communication and engagement with suppliers on HPA requirements appear to be needed, considering the poor compliance results to date. Data identified that small suppliers faced more barriers to awareness and understanding, and that currently, engagement of small suppliers by WHPP is limited and could be expanded.
The evaluation also found that there is a lack of baseline data on workplace hazardous products for assessing Program impact.
Given WHPP’s limited capacity and resources, the Program will not be in a position to address the challenges it faces unless there are fundamental changes.
- Consider means to increase compliance and enforcement activities, and explore an expanded range of enforcement tools.
- Enhance communication and guidance material on excluded products for all WHPP stakeholders and partners.
- Expand communication and engagement with suppliers, in particular with small suppliers.
- Explore means to improve measurement of Program impact.
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