Additional issues raised by labor representatives
There has been a consensus among stakeholders that the use of
prescribed concentration ranges might be acceptable. So why is a
full year needed to implement such a change? Labor representatives
have raised additional concerns relating to the disclosure of
ingredients that are carcinogens, mutagens, reproductive toxins
and respiratory sensitizers (CMRs), as well as the protection of
product sectors excluded from WHMIS such as consumer products.
Concessions on these additional points may be a condition
for support.
How these changes could influence consumer
products and more
As mentioned previously, Health Canada has committed to
provide support for employers as they make their way through the
transition from WHMIS 1988 to WHMIS 2015. We can expect
guidance to be released prior to the first extended deadline of
June 1, 2018.
So, you might ask, what are some of the other changes we
can expect? It is possible that the new prescribed ranges will
differ from WHMIS 1988. We may see narrower ranges than
before or there could be some new restrictions that limit the
protection of CBI in this way. For example, full disclosure
may still be a requirement in cases of particularly dangerous
ingredients such as CMRs.
Perhaps we will also see updates to the Consumer Chemicals
& Containers Regulations (CCCR). There could be new
requirements for Canadian consumer labeling comparable
to California’s recently amended Proposition 65. Prop 65
requires clear and reasonable warnings on products that
contain chemicals known to cause cancer or reproductive
harm. Given the interest of Canadian labor representatives
in CMRs, new labeling requirements for these chemicals are
a possibility. These could take the form of custom warnings,
requirements to disclose certain chemicals on the label or
new pictograms.
This is all speculation, of course. We will be sure to keep you in
the loop as new information becomes available. SPRAY
September 2017 SPRAY 23