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

CPR Section 7 - Generic Material Safety Data Sheet

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Generic Material Safety Data Sheet

Interpretation / Discussion of Section 7

A generic MSDS may be used for a group of controlled products with similar chemical composition. However, if the concentration range for an ingredient of a particular controlled product in the group is different from the range declared for the rest of the group, this must be indicated on the MSDS beside the name of that product and beside that ingredient. The permissible concentration ranges are set out in section 11. If the hazard information for a particular controlled product in the group differs from that of the other products in the group, the hazard information relevant to that product must be disclosed on the MSDS beside the name of the product.

An example where a supplier might choose to use a generic MSDS is if the supplier is supplying a series of coloured paints where the only difference from product to product is the pigment used. In such a case, the supplier would be required to list all of the products to which the MSDS applies under the product identifier. If, for example, the yellow-coloured paint is more toxic because of the pigment used, a note on the generic MSDS would be required disclosing the additional toxicological hazards associated with the yellow paint.

Where a supplier sells a line of similar (base) products to distributors or users who blend the bases in various proportions to obtain the final usable product (e.g., automotive paints), a supplier's generic MSDS is acceptable for such a line of products.

The supplier's generic MSDS and the blender's generic MSDS must disclose, under the appropriate heading, all special hazard information related to particular ingredients. For example, special first aid measures concerning a particular ingredient must be disclosed under the "First Aid Measures" section of the MSDS.

An acceptable alternative to providing a MSDS for every blend which discloses the concentration of the ingredients for the blends is to provide the supplier's generic MSDS which discloses the concentrations of hazardous ingredients in the bases; either the blender's generic MSDS or the label must disclose the concentrations of the bases in the final product.

A series of MSDSs could also be prepared for a group of products within a line which have the same base ingredients but which vary with respect to the concentrations of other ingredients, {ref.: PIS No. 48}. The intent of WHMIS is to provide complete hazard information to workers. Therefore, the words "may contain" and other phrases which leave some ambiguity as to the composition and, consequently, the health hazard of the product in question, are discouraged.

Crude petroleum oil: In the case of crude petroleum oil, which falls within the definition of a complex mixture, because the hazardous nature of crude oil is such that it varies within a wide range from field to field, and even within the same field, a generic MSDS is acceptable only if it addresses all of the potential hazards of the group of controlled products to which it applies.

For example, crude oil that contains H2 S falls within the D1A classification criteria. However, when the supplier knows that the crude oil does not contain H2 S, the supplier must remove the hazard information and classification associated with H2 S. The dividing line between sweet and sour crude is not a definite one. Even sweet crude may contain sufficient H2 S, either in solution or in the headspace of a storage or transport container which may be harmful to workers upon unprotected exposure. Crude oil that is spiked with butane, subject to the appropriate concentration cut-off, must be identified and its hazard indicated.

It is understood that workers handling crude oil should have received a considerable amount of training (as is required by provincial OSH regulations) specific to the work site. The generic MSDS for crude oil will act as an additional source of hazard information warning of the potential hazards; {ref.: PIS No. 55}.