September 2015 Spray 27 that, where one or more backslashes or diagonal marks ( / ) appear in the text of a precautionary statement listed in section three of Annex Three of the GHS (5th revised edition) or in Appendix C of the HCS 2012, this means that the supplier must select all the appropriate choice(s) from the words that are separated by the backslashes. “For example, in the case of precautionary statement P261, ‘Avoid breathing dust/fume/gas/mist/vapors/spray’, if a worker could be exposed to the hazardous product through inhalation of dust, fume, gas or vapors, then this precautionary statement should read as follows: ‘Avoid breathing dust, fume, gas and vapors’, or ‘Avoid breathing dust, fume, gas or vapors’ or ‘Avoid breathing dust/fume/ gas/vapors’, as long as the precautionary statement includes all the applicable words. “The Health Canada web page on ‘Information Elements Required on a WHMIS 2015 Label’ has been modified to indicate that backslashes may appear in a precautionary statement on a WHMIS 2015 label, as long as the precautionary statement includes all the words that are applicable to the hazardous product.” With these issues clarified, we are now confident that jointly compliant documents are possible. If you would like a copy of Health Canada’s full letter, please e-mail me at mmoffatt@nexreg.com. Health Canada ramps up consumer chemical recalls After a heavy period of recalls for flammable aerosols and reed diffusers, we went through an extended period of peace and quiet when it came to consumer chemical recalls in Canada. Since March, however, recalls have picked up substantially. Particularly worrying is that, unlike the previous set of recalls, there does not appear to be one type of product that the agency is targeting. The recent recalls include the following: • Automotive touch-up paint, antifreeze/coolant, urethane catalyst, radiator flush, citrus all-purpose cleaner and vehicle wash products: Lacked Canadian labeling altogether. • Aerosol hair care products: Lacked pressured container and flammability information required by Canadian law. • Household cleaners and boat cleaner chemicals: Did not meet Canada’s child-resistant packaging requirements. With this heightened enforcement of Canadian labeling regulations, it is more important than ever to ensure products are compliant with the applicable legislation. Note that WHMIS 2015 does not alter the regulations governing consumer chemicals, which still fall under the existing Consumer Chemicals & Containers Regulations, 2001 (CCCR, 2001) regulations. Canada has a federal election on Oct. 19 of this year. In my next piece, I will discuss how the outcome of the election will affect companies importing into Canada, as well as touch on any new regulatory developments between now and then. Spray
Spray September 2015
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