Labour & Regulatory Services - Workplace, Safety & Health - Legislation

WHMIS 2015


Guidance for employers during transition to WHMIS 2015

**Updated to June 30, 2017

Updates on WHMIS 2015 for Hazardous Products Suppliers, Manufacturers, Importers and Distributers:   

The Government of Canada has deferred transition timelines for manufacturers, importers and distributors to meet requirements introduced under WHMIS 2015. The Orders in Council and a Regulatory Impact Analysis Statement (RIAS) are published in the Canada Gazette Part II (Phase One and Phase Two). 

The revised timelines provide an extension for manufacturers, importers, and distributors of hazardous products. The target deadline set for employers by federal, provincial and territorial agencies responsible for occupational safety and health in the workplace remains unchanged at December 1, 2018.

Updates on WHMIS 2015 for Employers:   

From October 1, 2017 to December 31, 2017 federal Hazardous Products Act (HPA) Officers from the Workplace Safety and Health Branch will be inspecting Manitoba workplaces to promote compliance with WHMIS 2015 requirements, and to assist Health Canada with building a list of suppliers in each jurisdiction. You may be asked to provide a copy of your “specific purchasing information” and/or your “specific sales information,” and up to five Safety Data Sheets (SDSs) and corresponding labels for your hazardous products.  

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Amendments to the federal Hazardous Products Act (HPA) and the new Hazardous Products Regulations (HPR) came into effect February 11, 2015 under the authority of Health Canada. The changes to Workplace Hazardous Materials Information Systems (WHMIS) reflect the Globally Harmonized System of Classification and Labelling of Chemicals (GHS). To ensure consistency across Canada, federal, provincial and territorial jurisdictions responsible for occupational health and safety legislation have been working to implement the necessary changes to their respective WHMIS legislation.

The transition from former WHMIS requirements (WHMIS 1988) to the new requirements (WHMIS 2015) will occur over a three year period, ending December 1, 2018. Timeframes for compliance with new requirements will be staggered to allow manufacturers, suppliers and employers to phase out products labelled in accordance with WHMIS 1988, and to bring in newer products that align with WHMIS 2015.

During the transition, hazardous products classified and labelled in accordance with WHMIS 1988 will be subject to former provisions for labels and Material Safety Data Sheets (MSDS) under Manitoba’s Workplace Safety and Health Regulation Part 35: WHMIS. Effective immediately, new provisions under Part 35 apply to any hazardous product classified and labelled under WHMIS 2015. Employers must ensure that hazardous products received at the workplace have the corresponding WHMIS label and M/SDS information (1988 or 2015), and that workers are trained for the version(s) of WHMIS they are using in their workplaces (1988 and/or 2015).

Federal, provincial and territorial jurisdictions continue to reflect the following principles in order to ensure worker health and safety during the transition period to WHMIS 2015:

  • Primacy of occupational health and safety - protecting workers from the potential adverse effects from exposure to hazardous products.
  • Collaboration - federal, provincial and territorial jurisdictions and Health Canada will work collaboratively during the transition period.
  • Consistency - jurisdictions will make every effort to ensure consistency across Canada, both in the wording of amended legislation and its implementation during the transition period.
  • Clarity - Health Canada will provide jurisdictions with clear and timely information on new federal requirements, and WHMIS jurisdictions will clearly communicate the common transition approach to stakeholders.
  • Flexibility - the transition will allow suppliers and employers a broader timeframe to phase out any WHMIS 1988 compliant hazardous product and meet the new WHMIS 2015 requirements.

The WHMIS 2015 transition will take effect in three phases (timelines current as of June 2017):

  • Phase One – February 11th , 2015 to June 1st, 2018: Manufacturers, importers, distributors and employers will be able to comply with either WHMIS 1988 or WHMIS 2015 requirements for classification, labelling, MSDS and laboratory chemical labels during this period. At the end of this period manufacturers and importers must have reached full compliance with WHMIS 2015.  
  • Phases Two – June 1st, 2018 to September 1st, 2018: Distributors and employers will be able to comply with either WHMIS 1988 or WHMIS 2015 requirements during this period. This period allows distributors to phase out their supplies of WHMIS 1988 compliant products to reach full compliance with WHMIS 2015.  
  • Phase Three – September 1st, 2018 to December 1st, 2018: Employers will be able to comply with either WHMIS 1988 or WHMIS 2015 requirements during this period. This period allows employers phase out their supplies WHMIS 1988 compliant products to reach full compliance with WHMIS 2015.

For more information on the transition to WHMIS 2015, see Health Canada’s WHMIS Transition page. 

Manitoba Requirements

Following the February 2015 amendments to the HPA and HPR, accompanying amendments to Manitoba’s Workplace Safety and Health Regulation have been undertaken and completed. Manitoba workplaces may already be receiving hazardous products with labels and SDSs that align with the new WHMIS 2015 provisions. Government, employers and workers must work together to maintain the central intent of WHMIS, which is to ensure workers receive adequate information on the hazardous products used, handled and stored in their workplace.

Worker Education and Training Requirements

Employers are permitted to use both WHMIS 2015 and WHMIS 1988 classified and labelled hazardous products in Manitoba workplaces during the transition period, as long as current requirements respecting training and education are observed (See: Workplace Safety and Health Regulation, Part 35: WHMIS, sections 35.3 and 35.4), and the label information on the hazardous product matches the M/SDS.

  • When an employer receives a product with both WHMIS 1988 and WHMIS 2015 labels and M/SDSs, workers may use the product if they have received education in the WHMIS 1988 provisions at minimum and product-specific training instructions for the hazardous product they use or may be exposed to.  
  • When an employer receives a product with only WHMIS 2015 labels and SDSs, workers may use the product as long as they have received education in WHMIS 2015 and product-specific training instructions for the hazardous product they work with or may be exposed to.
  • Through the transition period, all products that meet the definition of controlled products under the former regulation are considered hazardous products for the purposes of compliance with Part 35.

Manitoba recognizes that employers may need assistance delivering education to workers when both WHMIS 1988 and WHMIS 2015 programs may be required.  SAFE Work Manitoba has partnered with the Canadian Centre for Occupational Health and Safety (CCOHS), to offer free e-learning resources for Manitobans for both WHMIS 1988 and WHMIS 2015. You can access the free resources online at: www.safemanitoba.com/training.

Additional information to help with the transition from WHMIS 1988 to WHIMS 2015 is available for suppliers, distributors, employers and employees through WHMIS.org, SAFE Work Manitoba and CCOHS.

Information regarding compliance will be updated on this page throughout the transition period.

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