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Reference Manual for the WHMIS Requirements of the Hazardous Products Act and Controlled Products Regulations

CPR Section 13 - Information to be Disclosed on Material Safety Data Sheet[conflicting toxicological information]

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13. (1) Where information respecting the toxicological properties of a controlled product disclosed on a material safety data sheet may be interpreted in such a way as to qualify or contradict other toxicological information disclosed on the material safety data sheet, the material safety data sheet shall include sufficient information concerning the toxicological studies so as not to mislead a person as to the nature or extent of the hazard posed by the controlled product.

(2) For the purposes of determining whether information may mislead a person as to the nature or extent of a hazard, the general impression that the information conveys shall be taken into account.

Interpretation / Discussion of Section 13

Also see discussion under section 25 of the CPR.

Subsection 13(1):

Results derived from toxicity testing of a product can be inconclusive or conflicting. However, it is important that when such information is disclosed on the MSDS, it be done in a way that does not imply that there are no hazards posed by the product (assuming that the product meets the criteria). This can be done by including enough information about the conflicting study so that a proper judgement about the validity of the study can be made.

Subsection 13(2):

This subsection places the onus on suppliers to communicate the hazards associated with a controlled product in a clear, unambiguous manner that does not contradict other information disclosed on the MSDS.

For example, many individuals believe that an exposure limit, in the absence of a qualification to the contrary, is the time weighted average (TWA) exposure limit. It is misleading to disclose a short term exposure limit (STEL) or a ceiling (C) value without qualifying it as such. Therefore, it is considered unacceptable to disclose an exposure limit without specifying which type, ie., without distinguishing between TWA vs STEL vs C.