Canada is in the midst of a major transition in chemical safety regulation, as it updates its Safety Data Sheet (SDS) requirements to align with the latest revisions of the Globally Harmonized System (GHS). These changes, implemented through amendments to the Hazardous Products Regulations (HPR), are set to significantly impact manufacturers, importers, and workplaces across the country by the end of 2025.
Transition to GHS Revision 7 and 8
On January 4, 2023, Health Canada published amendments to the HPR to align with the seventh edition of the GHS and incorporate select elements from the eighth edition. These amendments came into force on December 15, 2022, and introduced a three-year transition period, ending December 14, 2025. During this period, suppliers can comply with either the former or the amended HPR-but not a mix of both. After December 14, 2025, full compliance with the amended HPR will be mandatory for all hazardous products. [See here & here]
Key Changes Affecting SDS Requirements
- New and Revised Hazard Classes: The amendments introduce a new physical hazard class (Chemicals Under Pressure), a new hazard category for non-flammable aerosols, and new subcategories for flammable gases. These updates require suppliers to review and potentially reclassify their products and update SDSs accordingly. [See here]
- Expanded SDS Content: Additional information elements are now required on SDSs, especially in Section 9 (Physical and Chemical Properties). This ensures more comprehensive disclosure of a product’s characteristics, supporting safer handling and risk assessment.
- Bilingual Requirement: All SDSs must be provided in both of Canada’s official languages-English and French. Suppliers may issue a single bilingual SDS or two separate documents, but both must be given to the purchaser at the same time.
- Mandatory 16-Section Format: The structure and content of SDSs are strictly regulated. Each SDS must follow the 16-section format detailed in Schedule 1 of the HPR, covering everything from identification and hazard classification to ecological information and regulatory details. [See here]
- Timely Updates: SDSs must be updated when significant new information becomes available. In some jurisdictions, updates are required within 90 days of new data, while in others, employers must seek updated SDSs every three years.
- Trade Secret Provisions: The amendments clarify how prescribed concentration ranges can be used on SDSs when the actual concentration of a hazardous ingredient is withheld as a trade secret.
Practical Implications for Canadian Businesses
Immediate Action Required: Businesses must review their product classifications, SDSs, and labels to ensure they meet the new requirements before the December 14, 2025 deadline. This includes updating hazard statements, precautionary measures, and physical/chemical data.
Training and Communication: Employers need to update worker training programs to reflect the new hazard classes, categories, and SDS formats introduced by the GHS 7/8 alignment.
Documentation and Proof of Compliance: During the transition, suppliers must be ready to demonstrate which version of the HPR their products comply with, upon request by regulators.
The 2025 deadline for compliance with the amended Hazardous Products Regulations marks a pivotal moment for chemical safety in Canada. By adopting the latest GHS revisions, Canada is enhancing the clarity, consistency, and utility of SDSs, ultimately improving workplace safety and facilitating international trade. Businesses should act now to review and update their SDSs, labels, and training programs to ensure full compliance with the new standards.
How SDS Manager Can Help
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