One of the services ICC Compliance Center offers is reviewing Safety Data Sheets (SDS) for compliance within Canada and the United States.
We review your SDS against the criteria outlined in the WHMIS (Workplace Hazardous Materials Information System), which is Canada’s federal requirements for hazard classification, labeling, safety data sheets, and worker education program. This requirement is based on the Hazardous Products Act (HPA) and Hazardous Products Regulations (HPR). For the US requirements, we review the SDS against the criteria outlined in the OSHA (Occupational Safety and Health Administration) Hazard Communication Standard (HCS) Part 1900.1200.
Our checklist allows us to thoroughly review each section of the SDS against what the regulatory content says should be there. We also review Section 2 for accuracy based on the classification and label statements used.
What are some of the common errors?
Section 1
Many SDS that we see do not disclose a product use statement and restrictions on use. BOTH are required. The section heading is often wrong.
Section 2
Many SDS that we see do not include ALL of the hazard and precautionary statements. According to both the US and Canada requirements, all statements must be shown. In addition, oftentimes, the statements are not “finished.” When the regulations use “…” or “/,” you need to complete the sentence.
Section 4
Often “Most important symptoms and effects, both acute and delayed,” is missing from this section.
Section 9
All physical and chemical property headings must be shown, even if you have no data. In place of data, “not available” or “not applicable” should be indicated.
Section 11
Section 11 is very important as it indicates all of the acute and chronic health concerns as it relates to your product. Often, we see information in this section to be very limited. This section should include: routes of exposure, description of the delayed and immediate short AND long term effects, description of symptoms, and the lethal dose values for all THREE routes of exposure.
Need to know if your SDS is compliant with the US or Canadian regulations? Ask our training and services coordinator for a quote. We can help.
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