Substance-Specific Issues

Wood by-products, application of Hazardous Products Act

Substance:

Wood by-products

Issue:

Are wood by-products such as wood dust and wood flour subject to the WHMIS requirements of the Hazardous Products Act (HPA)?

Considerations:

By virtue of paragraph 12(g) of the HPA, "wood or product made of wood" are exempt from the WHMIS requirements of the HPA.

As stated in the Health Canada Reference Manual, the HPA 12(g) exemption is meant to refer to wood itself or wood structures. This exemption, therefore, does not encompass wood by-products that are derived from wood.

Amongst other hazards, certain wood dusts fall within the criteria for carcinogenicity, (ACGIH "A1"and IARC "Group 1"), specified in the Controlled Products Regulations.

Conclusion:

Wood by-products such as wood dust, wood flour, turpentine, wood pulp and other products derived from wood are subject to the WHMIS supplier label and MSDS requirements of the HPA.

References:

Health Canada; Reference Manual for the WHMIS Requirements of the Hazardous Products Act and Controlled Products Regulations.