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

CPR Section 18 - Labels of Bulk Shipments

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Labels of Bulk Shipments

18. For the purposes of subsection 11(2) of the Act, a label of a bulk shipment is included with or accompanies the bulk shipment when it is included with the shipping documents that accompany the bulk shipment.

Interpretation / Discussion of Section 18

Paragraphs 13(b) and 14(b) of the Hazardous Products Act (HPA) state that a controlled product or a container of a controlled product must have a WHMIS label applied to it as a condition of sale or importation. For the reasons listed in the interpretation of section 15 of the CPR, applying a label to the container of a bulk shipment is unnecessary.

Subsection 11(2) of the HPA states that, in the case of bulk shipments, applied means "is included with or caused to accompany the bulk shipment in the manner prescribed". This section prescribes that manner. This section, in conjunction with section 15, provide a range of labelling options for suppliers of controlled products shipped in bulk.