Is the Ingredient Disclosure List (IDL) a list of WHMIS controlled products?

                                                                                         

No. The Ingredient Disclosure List (IDL) is a list of chemical substances which are listed in alphabetical order by their universal name together with their corresponding Chemical Abstracts Service (CAS) registry number. However, if the specific substance is present in a WHMIS controlled product, in that case its identity and concentration must be disclosed on an MSDS if present at or above the specific “cut-off” concentration. Each chemical has its own corresponding concentration “cut-off” value of either 0.1% or 1.0%. The criteria for ingredient disclosure is set out in subparagraphs 13(a)(i) to (iv) of the Hazardous Products Act (HPA).

The standard that was set to determine whether to include a certain substance in the IDL was the following. Chemicals which were not treated as harmful enough to be controlled products in themselves but were considered health hazards have been placed on the IDL as well as substances which met the standard of the Controlled Products Regulations (CPR) act. In cases if a chemical was included in the IDL which was not itself a controlled product it was not subject to the HPA label or MSDS requirements, however when incorporated in a controlled product above its cut-off concentration, no matter what the MSDS author must disclose that certain substance identity and concentration on the MSDS document.

A compound might be found on the IDL but it does not fall within any of the prescribed hazard criteria of the CPR. It is also to note that the IDL is not a complete listing of ingredients that fall within he prescribed hazard criteria of the CPR. The main reason to be pointed out is that the IDL is not intended to be used as a basis to determine if a product is a controlled product. The main purpose of the IDL is to establish whether an ingredient found in a controlled product needs to be disclose in an MSDS document.

To conclude, an MSDS author must know, if an ingredient is not appearing in the IDL, disclosure of information relating to a certain chemical compound may still be required under subparagraphs 13(a)(i), (iii) or (iv) of the Hazardous Products Act (HPA).

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