WHMIS 1988 - Transportation of Controlled Products - Workplace Hazardous Materials Information System (WHMIS)
The WHMIS and the Transportation of Dangerous Goods (TDG) programs, although complementary and compatible, satisfy different purposes and have significant and essential differences.
The TDG program, which is administered by Transport Canada controls the shipment of dangerous goods and provides the information needed by emergency response personnel to deal with transportation accidents and spills. The objective of WHMIS is to ensure the protection of Canadian workers from the adverse effects of hazardous materials through the provision of relevant information.
If an outer container has a TDG label, the outer container will not require a WHMIS label; inner containers, however, must have WHMIS labels. If a product does not have any inner containers (e.g., a drum of solvent), then this exemption is not applicable, i.e., a WHMIS supplier label must be applied to the container. (Not all controlled products will require TDG labelling since the criteria for WHMIS controlled products are broader than the criteria for products subject to the TDG Regulations.)
As set out in section 15 of the Controlled Products Regulations (CPR), the sale or importation of a bulk shipment of a WHMIS controlled product is exempt from the requirement to apply a WHMIS supplier label to the controlled product if a label, MSDS or other written statement disclosing the required information is transmitted to the person receiving the bulk shipment by the time they receive the shipment. The person receiving the bulk shipment (e.g. the buyer or importer) may also already have a label, MSDS or statement with the required information for the bulk shipment. Provided this information is current at the time of the sale/importation, this would meet the labelling requirements set out in the CPR.
Note: To facilitate the application of the appropriate label to the controlled product, should a supplier/importer of bulk shipments choose to provide supplier label information on the MSDS as opposed to providing a separate label (or by disclosing the label information on a separate sheet), the label information should be set apart and readily discernible from the other information disclosed on the MSDS.
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