Skip to content | Skip to institutional links

Common menu bar links

Institutional links

Current Subject
- Environmental & Workplace Health
- Reports & Publications
Explore...
Proactive Disclosure

Proactive Disclosure

Environmental and Workplace Health

Print |

Need Larger Text? |

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

Table of Contents

CPR Section 19 - Information to be Disclosed on Labels

Help on accessing alternative formats, such as Portable Document Format (PDF), Microsoft Word and PowerPoint (PPT) files, can be obtained in the alternate format help section.

(PDF Version - 294 K)

Information to be Disclosed on Labels

19. (1) The label applied to a controlled product or the container in which a controlled product is packaged shall disclose, in respect of the controlled product, the following information:

the product identifier;
subject to subsections (3) and (4), the supplier identifier;
a statement to the effect that a material safety data sheet is available;
subject to subsection (5), hazard symbols set out in column II of Schedule II that correspond with the classes in which the controlled product is included and the divisions into which the controlled product falls as set out in column I of that Schedule; and
where the container has a capacity of more than 100 millilitres, the following information:
1. risk phrases that are appropriate to the controlled product or to the classes, divisions or subdivisions into which the controlled product falls,
2. precautionary measures to be followed when handling, using or being exposed to the controlled product, and
3. where appropriate, first aid measures to be taken in case of exposure to the controlled product.

(2) Paragraphs (1)(a) and (b) do not apply in respect of the sale of a controlled product to an employer who has filed a claim for exemption or is exempt under the Hazardous Materials Information Review Act or under the laws of a province from disclosing

the chemical name, common name, generic name, trade name or brand name of a controlled product, if the label discloses the code name or code number specified by the supplier; or
any information that could be used to identify the supplier of the controlled product, if that information is replaced by
1. the information referred to in section 26 or 27, or
2. where the information referred to in section 26 or 27 is not available, the information required to be disclosed under the laws of the province.

(3) Where a controlled product is sold to a distributor for the purpose of sale or resale, the distributor is not required, in the information disclosed on the label under paragraph (1)(b), to disclose the supplier identifier of the distributor if the supplier identifier of the manufacturer or importer is disclosed on the label.

(4) Where a controlled product is packaged for a distributor by a manufacturer, the manufacturer is not required, in the information disclosed on the label under paragraph (1)(b), to disclose the supplier identifier of the manufacturer if the supplier identifier of the distributor is disclosed on the label.

(5) Where a controlled product falls into Divisions 1 and 2 of Class D - Poisonous and Infectious Material, paragraph (1)(d) does not apply in respect of the requirement to disclose on the label applied to the controlled product or the container in which the controlled product is packaged the hazard symbol set out in column II of Schedule II that corresponds to Division 2 of Class D - Poisonous and Infectious Material as set out in column I of that Schedule.

(6) Paragraphs (1)(b) and (e) do not apply to the sale or importation of a controlled products that is a mixture of one or more radioactive nuclides and one or more non-radioactive carrier materials.
[SOR/2001-254; s. 7]

DISCUSSION of SECTION 19

This section of the CPR specifies the information that must be disclosed on a WHMIS supplier label. For information relating to language requirements of this disclosure, please see subsection 24(3) of the CPR.

Only the information specified in this section should be placed within the WHMIS border within the WHMIS "hash" border depicted in Schedule III to these Regulations. Refer to subsection 20(1) and 21(1) of the CPR for additional information on this issue.

Classification: Disclosure of the "WHMIS" classification is not required on the label. However, if it is company policy to voluntarily disclose this information, then all classifications must be disclosed. If it is company policy to disclose Class B and Class D Divisions and, in the case of Class D, the Subdivisions, then all Divisions and Subdivisions must be disclosed. (Please also refer to the discussion of section 43 of the CPR in the Reference Manual for information relating to "Redundancy of multiple classifications within WHMIS Class D".)

Subsection 19(1):

This subsection lists all information that is normally required on a WHMIS label. Small size containers that have a volume of 100 millilitres or less require the information specified in paragraphs (a) to (d); containers with a volume of more than 100 millilitres require the information specified in paragraphs (a) to (e). The 100 millilitre size refers to the volume of the container and not the volume of the product.

Paragraphs 19(1)(a) and 19(1)(b):

"Product identifier" and "supplier identifier" are terms which are defined in section 2 of the CPR. As required by section 28 of the CPR, the product identifier disclosed on the label must be identical to that disclosed on the MSDS. The CPR does not contain an analogous requirement for the supplier identifier. The definition of "supplier identifier" does not include "the city where the principal place of business is located". Therefore, in contrast to the MSDS requirements, only the name and not the address of the supplier need appear on the label of the controlled product; {ref.: PIS No. 54}.

Paragraph 19(1)(d):

Hazard symbols are depicted in Schedule II of the CPR. If a product meets the criteria for more than one Class or Division, all of the applicable symbols, with the exception stated in subsection 19(5), must be displayed on the WHMIS label.

Hazard symbols should be large enough to provide a clear warning to workers. In contrast to the Consumer Chemicals and Containers Regulations, 2001 (CCCR-2001), the size of the hazard symbols has not been prescribed in the CPR. Suppliers, however, may wish to use the CCCR-2001 as a guideline for symbol size. (The CCCR apply to chemical products sold to consumers. These products are included as items 1 and 2 of Part II of Schedule I to the HPA).

The CCCR-2001 requirement for minimum symbol size is based on the "main display panel". In the CCCR-2001, the requirement for minimum symbol size is based on the "the main display panel". The CCCR-2001 require that the hazard symbol must be at least such a size that it covers 3% of the "main display panel", but must be no smaller than 6 mm (¼ inch) in diameter. In the case of large containers, the symbol need not exceed 50 mm (2 inches). The "the main display panel" is the area of the largest side of a box or, for a cylinder, it is either the area of the top or 40% of the side surface area, whichever is larger.

Paragraph 19(1)(e):

Specifically worded risk phrases, precautionary measures and first aid statements have not been prescribed by the CPR. The term"risk phrases" is defined in section 2 of the CPR. Examples of acceptable risk phrases and precautionary measures in English and French are found in Council Directives of the European Economic Community posted on the "LABEL" page of the national WHMIS Web site.

For information regarding the "qualifying" of risk phrases, refer to the interpretation of section 25 of the CPR.

First aid measures should be limited to immediate measures to be taken by the victim or coworkers that are specific to the product and not measures to be taken by a medical professional. The first aid measures are not meant to include, for example, the treatment to be taken if a person receives burns in a fire resulting from a flammable controlled product. First aid measures must provide information necessary for the immediate on-site treatment of a person who has experienced adverse acute effects resulting from an accident with or overexposure to the controlled product. If applicable, the first aid measures disclosed must be specific to the route of entry, i.e., inhalation versus skin or eye contact, etc.. The label must disclose first aid measures if they are applicable to the product. If the product's toxicity is negligible, first aid measures would not be applicable.

Subsection 19(2):

An employer, who is a purchaser of a controlled product, may consider the product identifier or the name of his/her supplier as confidenti al business information because it might allow a competitor to determine the ingredients used to create his/her product. Under WHMIS, the employer may file a claim for exemption from having that information revealed on labels in his/her workplace. Depending on the province, the employer will claim an exemption under the Hazardous Materials Information Review Act (HMIRA) or under laws particular to that province. If an employer is exempt under the HMIRA or laws particular to a province, allowance is made in this subsection for the supplier to accommodate the employer's exemption. If the employer's exemption is allowed under HMIRA, the supplier may replace the exempt information with the information contained in section 26 or 27, such as the registry number. If the employer's exemption is allowed under laws particular to a province, the supplier may replace the exempt information with any information specified by those laws.

Subsections 19(3) and (4):

There are two situations where a supplier of a controlled product may use another person's name as the "supplier identifier".

Under subsection 19(3), any distributor of the product, whether the distributor is selling the product to another distributor or to an industrial consumer, may use the manufacturer's or importer's name as the "supplier identifier".

Under subsection 19(4), where the supplier is a manufacturer who is custom packaging the controlled product for a distributor, the distributor's name may be used as the "supplier identifier".

Subsection 19(5):

Under paragraph 19(1)(d), a label of a controlled product must display hazard symbols relevant to all of the classes and divisions into which the product falls. This subsection states the only exception to this rule. In the case of a product that meets the criteria in both Division 1 and Division 2 of Class D, the Division 2 (stylized "T") symbol is not required. For example, if a product meets the criteria in all three Divisions of Class D and the criteria in Class E, the label of the product would require the skull and crossbones symbol, the biohazard symbol and the corrosive symbol.

Subsection 19(6):

Materials which are mixtures of radioactive nuclide(s) and controlled product carrier material(s) are exempt from the inclusion of a supplier identifier, risk phrase(s), precautionary measure(s) and first aid information on the WHMIS supplier label which is distinct and separate from any labelling required under the Nuclear Safety and Control Act and Regulations.