The Controlled Products Regulations, Section I contains the nine sections that are required on a compliant WHMIS MSDS. The suggested headings are as follows:
1. Hazardous Ingredients
2. Preparation Information
3. Product Information
4. Physical Data
5. Fire or Explosion Hazard
6. Reactivity Data
7. Toxicological Properties
8. Preventative Measures
9. First Aid Measures
Each one of these headings has a list of information that is required in that section.
Note that only 9 sections are given on this list. This does not imply, however, that WHMIS MSDSs must only be 9 sections long. Subsection 12.1 of Canada's controlled products regulations states that "a material safety data sheet shall disclose the nine categories of information set out in Column I of an item of Schedule I and each category shall be identified by a heading that is the same as or similar to the suggested heading set out for that category in Column II of that item." Health Canada's reference manual, however, states that this is only to be taken as a minimum number of headings:
"As an administrative policy, MSDSs for WHMIS controlled products which use the ILO, ISO or EC, ANSI or GHS 16 heading format are accepted as meeting compliance requirements of CPR Section 12, provided that all 16 headings are disclosed (in the sequence recommended by these other standards) and that the required content specified under Schedule I, Column III of the CPR is addressed. Under the ILO heading "Regulatory Information", the following statement should appear: "This product has been classified in accordance with the hazard criteria of the Controlled Products Regulations and the MSDS contains all the information required by the Controlled Products Regulations." All headings and subheadings which appear on the MSDS must be addressed by disclosing the relevant information or by declaring that the information is not available or not applicable, as appropriate."
Having 16-section WHMIS MSDSs that are compliant with the ANSI Z400.1- 2004 have become industry standard in Canada. They not only provide far clearer and more detailed information than a 9-section MSDS, they will also provide for a much easier transition to GHS, which also uses a 16-section format.
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