Safety data sheets and labels for workplace hazardous products: Administrative non-compliances
If we prioritize a product with an exemption for an in-depth compliance review, we assess the safety data sheet (SDS) (and label, if applicable) to determine compliance. During our review, we note all non-compliances that we find, including those that are administrative in nature.
In the context of compliance review, "administrative non-compliances" refers to editorial errors and the incorrect placement of information on the SDS (and label, if applicable), including:
- typographical errors
- minor formatting errors
- phrasing and expression of words
The table below presents the most common administrative non-compliances that we have observed in past compliance reviews, and the associated corrective measures required to fix them.
| Description | Corrective measures |
|---|---|
| No link between confidential business information and claim | Disclose the registry number and add a statement indicating that an exemption has been granted, with validity decision date |
Actual concentration or concentration range not included on SDS |
If it is determined that the actual concentration or actual concentration range is confidential: Disclose a reference to the registry number in lieu of the actual concentration/concentration range of the ingredient(s) |
| If the concentration is not confidential: Disclose the actual concentration or concentration range of the ingredient(s) |
|
| Unit of concentration is insufficient or missing | Disclose an acceptable unit of concentration |
| Description of product's physical state/colour is insufficient or missing | Disclose an accurate product colour/physical state |
| Not all confidential ingredients linked to the registry number | Disclose a clear link between all of the applicable confidential business information and the registry number |
| Generic chemical name inconsistent between claim and SDS | Disclose a generic chemical name that is consistent with what you provided in your claim for the confidential ingredient(s) that is/are subject to the exemption |
| Concentration range on the SDS does not encompass actual confidential concentration (or concentration range) as provided in the claim | Disclose an acceptable concentration range for the specific confidential concentration (or concentration range) |
| SDS headings – incorrect format | Disclose the correct heading(s) as set out in Schedule 1 to the Hazardous Products Regulations (HPR) |
| SDS headings – wrong order | Disclose the appropriate heading(s) in the correct order as set out in Schedule 1 to the HPR |
| SDS headings – item number missing | Disclose the relevant item number directly before each heading |
| Unnecessary information – non-hazardous ingredients claimed as confidential business information | Remove the link between the non-hazardous confidential ingredient and the registry number |
| Precautionary statements on the SDS retain their forward slashes or diagonal marks | Correct the precautionary statements to select the appropriate phrase(s) when a slash is present |