Module 4 - WHMIS labels

4.1 - Learning outcomes

• Distinguish between the different types of product labels
• List the contents of a supplier label
• Describe when a workplace label is required
• Assess what you know about product labels

You’ve likely noticed that each hazardous product is identified with a label. Would you be able to distinguish between different types of labels? Would you know whether it’s a supplier label or a workplace label?

Once you’ve discovered the type of label attached to a specific hazardous product, how can you decode the information? What information should be on a supplier label? What information should be on a workplace label?

There are implications of improperly labelled containers or containers with missing labels. For example, in 2017 at the University of Ottawa, a lab manager was following up on a lab safety inspection that had identified inappropriately stored bottles of chemicals in a cabinet under a sink. While doing so, he found some empty bottles that appeared to be for methanol and collected them for recycling. He tilted each of the bottles to confirm they were empty.

Unfortunately, one of them was not and some of the contents—an orange liquid—spilled out onto the floor, splashing onto the manager’s feet. It was clear that the liquid was not methanol because of the orange colour but it did not have any other identifying characteristics. Fortunately, the manager was not injured, but the outcome could have been serious.

Proper labelling of these containers—whether original or waste containers—would have ensured the necessary information was available in order to respond safely and appropriately.

4.2 - General label requirements

WHMIS 2015 defines label as “a group of written, printed or graphic information elements that relate to a hazardous product. The label is to be affixed to, printed on or attached to the hazardous product or the container in which the hazardous product is packaged.”

1. Every hazardous product container must be labeled. This includes each container in a shipment.
2. Supplier labels must remain on the container while any of the product remains in the container. If a label becomes illegible or is removed, the label must be replaced with a workplace label.
3. A container received without a proper label must have a workplace label affixed to it.

When a hazardous product enters a uOttawa workplace, it is usually already labelled by the supplier. In this case, no additional labels are required.

Transferring a product into a different container is sometimes necessary for practicality. In this case, the product user needs to create a new label, known as a workplace label. When all laboratory users have received proper training, fewer workplace labelling requirements apply to analytical standard solutions, solutions prepared for teaching laboratories, products that result from synthesis and products created in the laboratory for research and development (simplified labels can be used).

See section 4.7 for the requirements for a workplace label.

Labels produced in the workplace may include additional information (symbols of required personal protective equipment, hazard pictograms, etc.). Refer to table 1 for an overview of label requirements.

4.3 - Supplier labels

The product label serves as one of the primary sources of information about the contents of a container. It is vital that the information depicted is properly understood by end users. The label must be bilingual (French/English) and legible. If the supplier label becomes damaged or unreadable for any reason, the label must be replaced with a workplace label. The following label example identifies the components of a WHMIS supplier label.

Recall the conditions for updating an SDS that were described in module 2: if there is significant new data, the supplier of the hazardous product is required to update labels within 180 days of becoming aware of the significant new data. Like the SDS, if a product is sold during this 180 day grace period without an updated supplier label, the supplier must provide the buyer (i.e., the employer) with the significant new data in writing and the date on which the data became available. Suppliers are not required to inform past buyers of a hazardous product that significant new data is available. If users at uOttawa become aware of such new information, they should advise their supervisor.

4.4 - Interactive supplier label

The following supplier label exercise will allow you to analyze a typical WHMIS supplier label.

Accessible learning experience.

4.5 - Products received without labels

Let’s assume that a user has received a hazardous product and the label was missing or damaged beyond recognition. Since all hazardous products require some form of identification, what should the user do?

In a case like this, it is acceptable to store (i.e., not use) an unlabelled hazardous product received from a supplier while actively seeking a supplier label and a supplier SDS for the hazardous product. If, despite reasonable efforts, a supplier SDS or label is not available, advise the Office of the Chief Risk Officer and, if possible, affix a workplace label to the container before releasing the product for use.

4.6 - Labels created by uOttawa personnel

Workers may be required to label a hazardous product for a multitude of reasons. The most common reason is decanting a hazardous product to another container. However, another reason could be that the label has become illegible, damaged, etc.

Workplace labelling requirements can be quite simple. uOttawa has a variety of hazardous products in varying sizes of containers—each with specific labelling needs. Table 1 provides a brief example of some workplace labelling requirements.

4.7 - Workplace labels

Workplace labels are created by the users of hazardous products being used in an area other than a laboratory. These labels are applied to the container of a hazardous product that was:

• created in the workplace,
• received without a supplier label or
• transferred into a container that had no labelling.

Workplace labels do not require a border or specific wording; they do, however, require the following information:

1. Product identifier (product name matching that on the SDS),
2. Information for the safe handling of the product, and
3. A statement that the SDS is available

Information for the safe handling of the product refers to precautions that a person must take to minimize potential adverse health effects or injury. These precautions can be conveyed through pictures, words, symbols or equivalent means and are usually available on the SDS.

Workplace labels can be automatically produced using Chemwatch, available on the Office of the Chief Risk Officer website.

4.8 - Portable containers

If a hazardous product is transferred from the supplier container into a second, portable container, the portable container generally must have a workplace label.

The second container does not require a workplace label if:

1. the portable container was filled directly from a container with a supplier or workplace label,
2. all of the hazardous product in the portable container is required for immediate use or
3. all of the following conditions are met:
   • the hazardous product is used only by the worker who filled the portable container,
   • the hazardous product is used only during the shift in which the portable container was filled and
   • the contents of the portable container are clearly identified (product name, common name, generic name, trade name, brand name, etc.).