Regulatory International Influences December 2015 Spray 25 “Claim for Exemption Form” and payment to Health Canada. The forms are not available online, but can be obtained from Health Canada by e-mailing WHMIS-SIMDUT.conf@hc-sc. gc.ca. Health Canada’s decision is far from automatic; you will need to prove on the form that the information is truly confidential and has legitimate privacy value for your company. There is also the issue of submission costs, which can add up quickly. The first 15 original claims filed in a single submission cost $1,800 (Canadian) each, with declining fees for claims 16-25 and 25+. There are reduced fees for refiling of claims, along with a 50% reduction in fees for companies that are eligible for the small business exemption. The combination of financial cost and the time it takes to fill out the necessary paperwork means that companies will need to think long and hard about their Canadian strategy when it comes to confidential business information. On the one hand, very few companies wish to put exact percentages in the composition section of their SDS. On the other hand, filing for an HMIRA# is expensive and time consuming and there is a high chance of rejection if the case for trade-secret status is not strong. Our recommendation would be that if you are going to file for a HMIRA#, do so earlier rather than later. Health Canada’s listing of Active Claims for Exemption shows that the number of applications have been steadily climbing, from 45 in the fourth quarter of 2014 to 64, 85 and 91 in the first, second and third quarters respectively.* If this trend continues, a backlog could form, causing delays. We will continue watching the unfolding WHMIS 2015 situation in Canada closely, as we expect more roadblocks and hurdles to emerge in the coming months. Spray *Source: http://www.hc-sc.gc.ca/ewh-semt/occup-travail/whmis-simdut/hmiralcrmd/ exemption-derogation/active_claims-actives_avis/list-liste-eng.php
Spray December 2015
To see the actual publication please follow the link above