Canada's Hazard Communication Standard Substance-Specific Issues

• Substance-specific issues - overview
• Substance -specific regulatory issues
• Substance-specific issues
• Substance-specific issues - OSHA

Substance-Specific Issues - Overview

This page provides information / direction on a number of substance-specific issues relating primarily to the "WHMIS" supplier requirements of the Hazardous Products Act (HPA) and associated Controlled Products Regulations (CPR).

Some information is also being provided on this page in relation to chemicals subject to provisions of the HPA other than the [WHMIS] CPR. However, users of this site are alerted to the following:

Prohibited products - Subsection 4(1) of the HPA provides the authority to prohibit certain products from sale, importation and advertisement in Canada. These are defined as "prohibited products" in Section 2 of the Act. Prohibited products are listed in Part I of Schedule I to the HPA. Although this section of the HPA has been primarily used to prohibit products for which consumers may have limited facility to implement the necessary precautions, it has also been invoked to ban, for example nitrites in certain cutting oils.

Restricted products - Subsection 4(2) of the HPA provides the authority to prohibit the advertisement, sale or importation of a product except as authorized by the applicable regulations established under the HPA. These are defined as "restricted products". Restricted products are listed in Part II of Schedule I to the HPA.

Controlled products - Section 15 of the HPA provides the authority to establish regulations for [WHMIS] "controlled products" intended for use in a workplace in Canada.

Substance-Specific Regulatory Issues

There are a number of information sources from which the "WHMIS" classification of a given substance can be ascertained and which can also be used to determine appropriate label and MSDS information. In cases where there has not been complete agreement, this has been referred to the organization ultimately responsible for the administration of the HPA/CPR, i.e., the National WHMIS Office, Health Canada, for resolution to ensure the uniform application of the HPA/CPR throughout Canada.

Chlorine, for example, is sold as a compressed gas and its corrosive properties are well documented. The fact that chlorine is a relatively strong oxidizing agent is not in dispute. However, there has been confusion as to whether chlorine falls within the criteria specified in the CPR for Class C - Oxidizing Material.

Substance-Specific Issues

• ammonia; acute toxicity, classification
• asbestos, crocidolite; restriction
• asbestos, pure; prohibition as consumer product
• asbestos, sprayed; prohibition
• bromine and chlorine; oxidizers, classification as
• carbon black, non-respirable; carcinogenicity, classification
• carbon dioxide, solid; corrosiveness
• cellulose fibre, as thermal insulation; restriction
• charcoal; restriction
• chlorine; oxidizer, classification as [see under bromine]
• coal / coal dust; classification of
• cobalt, organometallic compounds; carcinogenicity, classification of
• concrete; corrosiveness, classification
• diatomaceous earth, calcined; carcinogenicity
• diethylene glycol; acute toxicity, classification
• ethylene glycol; acute toxicity, classification
• hydroflouric acid; first aid
• hydrogen peroxide; acute toxicity, classification
• isopropanol; skin sensitization
• mercury; skin sensitization
• methyl methacrylate; respiratory tract sensitization
• nitrites (in cutting fluids); prohibition
• nitrogen, liquid; corrosiveness
• PCBs (in microscopy oils); prohibition
• silica, crystalline, encapsulated; carcinogenicity, classification
• sodium chlorate; acute toxicity, classification
• sulphuric acid; carcinogenicity, classification
• titanium dioxide, mixture containing, carcinogenicity
• wood by-products; application of HPA
• xylene, isomers; embryotoxicity, classification
• xylene, "mixed"; embryotoxicity, classification

Substance-Specific Issues - OSHA

A number of substance-specific issues that may be of relevance to classification under the CPR and/or WHMIS hazard communication can be found on the web site of the United States Occupational Health and Safety Administration. The following examples, which indicate the date of OSHA's response, can be accessed by entering the keywords shown in red on OSHA's  Standard Interpretations search page:

• ammonia: should it be classified as a toxic, flammable, reactive or explosive chemical? (1994-06-02)
• carbon black: what is the regulatory classification of commercial carbon black? (1989-02-21)
• chromium, hexavalent: do manufacturers of acid gas respirator cartridges containing hexavalent chromium have to warn of the (cancer) hazard of exposure to the hexavalent chromium [Cr(VI)] present in these types of cartridges? (1992-02-06)
• coal dust: what is the regulatory classification of coke oven emmisions (1990-09-06)
• cobalt phthalocyanine sulfonate: what is the hazard determination for carcinogenic compounds? (1994-02-02)
• diatomaceous earth, uncalcined: what information must be disclosed on an MSDS? (1999-04-05)
• diesel fuel: what are the requirements for including the hazards of diesel fuel exhaust on an MSDS? (1990-04-04)
• fiberglass: what are the labelling and MSDS requirements regarding potential carcinogenicity for fiberglass products? (1991-11-19)
• inert gases: in the non-compressed state, do they represent a hazardous chemical? (1995-01-25)
• iron oxides: is FDA approval of iron oxides as a colourant evidence that iron oxide dust is not hazardous? (1993-03-12)
• naphthenic oils: are they considered to be carcinogenic? (1986-05-06)
• orlon: do the potential cancer hazards of dimethylformamide (DMF) and acrylonitrile (AN) have to be addressed on the labels and MSDS for orlon and orlon blend yarns? (1989-08-31)
• polyvinyl chloride resin: what are the labelling requirements? (1986-04-30)
• rubber dust byproduct: when sold by a tire recapping company, should it be accompanied by a label and an MSDS? (1991-08-15)
• titanium dioxide: is it a carcinogen? (1997-11-19)
• wood by-products: is it classified as a carcinogen? (1995-10-11)