Information Elements Required on a WHMIS 2015 Label

The label on a hazardous product is the worker’s first source of information about the hazards of the product. It provides workers with information on safe handling, storage and use of the hazardous product and how to protect them from adverse effects related to exposures to the product. In the Workplace Hazardous Materials Information System (WHMIS) 2015, all hazardous products must be labelled with the specified information elements listed below.

Disclaimer
 
Information contained in this section is of a general nature only and is not intended to constitute advice for any specific fact situation. For particular questions, users should contact their legal advisor and/or the occupational health and safety authority having jurisdiction for their workplace.

WHMIS 2015 sets out requirements for labels in Part 3 of the Hazardous Products Regulations (HPR).  In addition, exemptions related to labels and additional requirements that apply to labels can be found in Parts 5 and 6, respectively of the HPR.

Supplier labels must be both English and French, durable and legible without the aid of any devices other than corrective lenses. If the label of a hazardous product is lost, damaged, or no longer readable, the product must be relabelled before it is sold or upon its importation into Canada.

The hazard pictogram(s), signal word and the hazard statement(s) must be grouped together on a label. The hatched border previously used by WHMIS (1988) is no longer required.

Any hazard pictogram required to be provided on a label must, except with respect to size, be an exact reproduction of that pictogram as set out in column 3 of Schedule 3 of the HPR.  For each hazard class adopted from the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) in which the hazardous product is classified, the corresponding pictogram, signal word, hazard statement and precautionary statements set out in Section 3 of Annex 3 of the GHS (5th revised edition) are required to appear on the label.  For all other hazard classes in which the hazardous product is classified, those information elements as set out in Schedule 5 of the HPR for the hazard class are required to appear on the label. It is to be noted that, as opposed to the Controlled Products Regulations, nearly all hazard and precautionary statements are now prescribed, this means that the exact same statements an in Section 3 of Annex 3 of the GHS or as in Schedule 5 of the HPR should appear on labels.  The only non-prescribed hazard and precautionary statements appear in Schedule 5 of the HPR.

Labels must be updated to include significant new data - data which changes the classification of the product or ways to protect against the hazards presented by the hazardous product - within 180 days of becoming available.  In the interim 180-day period, (a) upon sale of the product, this data must be communicated, in writing, to any purchaser of the product; and (b) upon importation of the product, the importer must obtain or prepare a document that provides this data.

Section 3 of Annex 3 of the GHS and Schedule 5 of the HPR contain instructions in italics, which are not to be included in the content of a label.

The alphanumeric codes set out in section 3 of Annex 3 of the GHS need not appear on a label and must not, under any circumstances, replace the hazard statement or precautionary statement to which they relate.

In the case of a hazardous product that is a mixture, each ingredient that, individually, presents a health hazard must be listed on the safety data sheet (SDS). A supplier may also choose to disclose the hazardous ingredients on a label, even though it is not mandatory.

Label requirements
Label Element HPR Requirements Example Content
Product Identifier Requirements consist of:
  • Product identifier is how the hazardous product can be identified, which means the brand name, chemical name, common name, generic name or trade name of the hazardous product.
  • The same product identifier must be both on the label and in section 1 of the SDS.
Product K1
Hazard pictograms Requirements include:
  • Hazard pictogram must have a black symbol on a white background with a red border in the shape of a square set on one its points, except for the pictogram for "Biohazardous Infectious Materials".
  • In the case of "Biohazardous Infectious Materials" the pictogram must have a black symbol on a white background with a black border in the shape of a circle.
  • The environmental pictogram is not mandatory but may be used to provide additional information.
  • Hazard pictogram(s) are determined by the hazard classification of the hazardous product.
  • Some hazard categories in a hazard class do not require a pictogram. For example, Combustible Dusts- Category 1 and Simple Asphyxiants- Category 1.
Hazard Pictogram - Poison

Hazard Pictogram - Warning

Signal word Requirements include:
  • Signal word alerts the user of the hazardous product to a potential hazard on the label.
  • It also indicates the severity of the hazard.
  • "Danger" and "Warning" are the two signal words used to emphasize hazards.
  • The appropriate signal word, "Warning" or "Danger", is determined based on the hazard classification of the product.
  • If the signal words "Danger" and "Warning" are both assigned based on the hazard classification of the product, the signal word "Warning" may be omitted.
Danger
Hazard statements Requirements include:
  • Hazard statements describe the nature of the hazard presented by a hazardous product.
  • They are brief statements that describe the hazards based on the hazard classification of the product.
  • Hazard statements may be combined where appropriate, if the combination conveys the same information as would have been conveyed by each of the individual statements. For example, "Fatal if swallowed" and "Fatal if inhaled" can be combined to read "Fatal if swallowed or if inhaled".
  • All applicable hazard statements must be present.
  • The standardized hazard statements are found in Sections 1 and 3 of Annex 3 of the GHS for the hazard classes adopted from the GHS and, for some other hazard classes, they are found in Schedule 5 of the HPR.
  • There are no standardized hazard statements for the following hazard classes, but hazard statements that describe the nature of the hazards are required (wording is at the discretion of the supplier):
    • Physical Hazard not Otherwise Classified;
    • Health Hazard not Otherwise Classified; and
    • Biohazardous Infectious Materials.
Fatal if swallowed.
Causes skin irritation.
Precautionary statements Requirements include:
  • Precautionary statements describe recommended measures to minimize or prevent adverse effects resulting from exposure, or improper storage or handling of a hazardous product, including protective equipment and emergency measures. First aid is included in precautionary information.
  • These statements are found in Section 3 of Annex 3 of the GHS and consist of 4 types of statements (prevention, response (accidental spillage or exposure), storage and disposal).
  • For hazard classes not specified by the GHS, the supplier must provide any precautionary statements that are applicable to the hazardous product in terms of general, prevention, response, storage and disposal. There is no standardized wording for these statements for these hazard classes.
  • Statements may be combined if the combination provides the same information as would have been conveyed by each of the individual precautionary statements.  For example, "Store in a well-ventilated place," and "Keep cool" may be combined to read "Store in a cool, well-ventilated place."
  • Inapplicable precautionary statements can be omitted.
  • When a backslash or diagonal mark [/] appears in a precautionary statement specified in Section 3 of Annex 3 of the GHS, it indicates that  the most appropriate words or phrases must be selected and included in the precautionary statement. For example, "Wear protective gloves/protective clothing/eye protection/face protection" could read "Wear protective gloves and eye protection".
  • When three full stops [...] appear in a precautionary statement specified in Section 3 of Annex 3 of the GHS, they indicate that all applicable conditions are not listed.  For example, "Use explosion-proof [electrical/ventilating/lighting/...] equipment", the use of ... indicates that other equipment may be specified.
  • Three full stops must not appear on the label.
Wear protective gloves. Wash hands thoroughly after handling. Do not eat, drink or smoke when using this product. Store locked up. Dispose of contents/containers in accordance with local regulations. IF ON SKIN: Wash with plenty of water. If skin irritation occurs: Get medical advice or attention. Take off contaminated clothing and wash before reuse. IF SWALLOWED: Immediately call a POISON CENTRE or doctor. Rinse mouth.
Initial supplier identifier Requirements include:
  • Initial supplier identifier means the name, address and telephone number of the Canadian manufacturer or importer of a hazardous product who operates in Canada.
  • However, a distributor could provide its contact information (name, address and telephone number) in lieu of the initial supplier.
  • An importer could retain the name of the foreign supplier if the hazardous product is imported for the importer's use in its own workplace in Canada.
  • The supplier identifier on the label must match the supplier identifier provided on the SDS.
ABC Chemical Co.
123 Anywhere St.
Mytown, ON
N0N 0N0
(123) 456-7890
Supplemental Information This information may be used to provide further detail as long as that information does not contradict the validity of the standardized hazard information.

Requirements include:

  • There are two situations where supplemental information must be provided:
  • if on contact with water, the hazardous product releases a gaseous substance that meets the classification criteria for Acute Toxicity; the statement "In contact with water, releases gases which are fatal/toxic/harmful if inhaled" must be provided (Note: only one of the three words (i.e., either "fatal" or "toxic" or "harmful") is required in the supplemental statement, and it depends on the LC50 value of the emitted gas); and
  • if a mixture is classified in the Acute Toxicity hazard class, and it contains ingredients of unknown acute toxicity; the statement "__% of the mixture consists of an ingredient or ingredients of unknown acute toxicity" must be provided.
 
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