All products used in the workplace must have an MSDS accessible for employees to understand the proper use and safety measures needed when using a product or in case of an accident. It is the responsibility for the employer to ensure that there is an MSDS sheet for every product being used in their facility, but these MSDSs are typically provided by the supplier of the product.

An MSDS sheet is a go-to document for all persons who may come into contact with a particular chemical or mixture. It explains the relevant physical properties, hazardous information and safety procedures. Every country/jurisdiction has its own regulations that must be followed when preparing an MSDS for a product, specifying what information must be disclosed on the document.

Nexreg Compliance Inc. is a regulatory company that specializes in MSDS preparation. Nexreg offers MSDS authoring for the E.U. (SDS), NAFTA (U.S., Canada and Mexico), OSHA/WHMIS (U.S. and Canada), OSHA (U.S.) and WHMIS (Canada). The type of MSDS you require will depend on where your product will be used. Because of the many different legislations regulating MSDS preparation, choosing a professional service like Nexreg Compliance is a safe way to ensure that your MSDS will be compliant with all necessary documents.

Nexreg offers services for MSDS preparation from 2 weeks standard time to a 24-hour rush depending on your companys needs. Nexreg will determine the hazardous properties and classifications for your product from the formulation and prepare the appropriate MSDS accordingly. We also offer translations if you require your MSDS in another language besides English. Our team also offers services to update or reformat existing MSDSs your company may have that are expired or need to be used in a different jurisdiction.
If you have any questions or are interested in finding out more about Nexreg Compliance Inc.s services, feel free to contact us:

Nexreg Compliance, Inc.
Toll Free: (866) 361-3032
Phone: (519) 488-5126
Fax: (519) 488-5217
Web: www.nexreg.com

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The Workplace Hazardous Materials Information System (WHMIS) requires labels on controlled materials from the supplier and at the workplace. Health and safety officers may check the containers of controlled products in your workplace to ensure they have supplier labels with the special hatched border (illustrated in Appendix II). These labels must have the following information enclosed in the border:

a product identifier

a hazard symbol or symbols to correspond to risk phrases (standard pictograms for WHMIS)

risk phrases describing the nature of the hazard and possible consequences of product misuses (e.g. eye irritant

precautionary measures to be taken to ensure the safe use of the product (e.g. keep away from acids)

first aid measures (e.g. in case of skin contact, flush immediately with plenty of water)

a supplier identifier

a reference to the Material Safety Data Sheet (e.g. see MSDS)

Any containers that have a quantity of 100 mL or less need to only display a product identifier, the hazard symbol(s), the supplier identifier and some reference to the MSDS. All supplier labels must be in English and French.

Workplace labels must contain the following information:

clearly identify the product

identify essential information for safe use and handling of the product

indicate whether a MSDS is available (ex. if a consumer product is being used, a MSDS may not be available)

Contrary to the supplier label, the workplace label is performance oriented and therefore, its appearance, wording and arrangement are not restricted. Regardless, the workplace label must provide enough information to depict the precautions that must be taken to prevent injuries or accidents. Word, symbols, or other modes of communication can be used to convey the possible health and environmental hazards, but it must be combined with worker education to make certain that the worker has all the necessary information for safe handling and storage of the chemical.

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Under the Consumer Chemicals and Containers Regulations (CCCR), five hazard classes are identified. These classes are toxic products, corrosive products, flammable products, quick skin-bonding adhesives, and pressurized containers.

Toxic products are divided into three categories: very toxic, toxic and harmful. If a product contains a substance of special concern, it will automatically be classified under the sub-category assigned to that substance. The category can also be determined by the oral, dermal or inhalation exposure, as well as whether or not the product poses an aspiration hazard. Any product that is classified as very toxic is prohibited from sale, advertising or importation. For each of the other categories, the CCCR sets out specific statements that must be displayed on the product label.

Corrosive products are also divided into three categories: very corrosive, corrosive or irritant. Similarly to toxic products, if a mixture contains a substance of special concern, it will automatically have that classification. Classification is also determined by the pH of the product, human experience or the total concentration of substances causing necrosis or ulceration. Regardless of the classification, all corrosive products can be sold as long as their labels contain the appropriate statements.

Flammable products are four categories: very flammable, flammable, spontaneously combustible and combustible. Very Flammable products are prohibited for sale, unless they meet the specific conditions laid out in the CCCR, 2001. The flammability of a product is determined by its flashpoint, flame projection, flashback, or whether or not it heats/combusts spontaneously.

The final two classes, quick skin-bonding adhesives and pressurized containers, either do or do not apply to a product; there are no sub-categories. Similar to the other hazard classes, if this classification applies to the product, the CCCR sets out specific statements to display on the consumer label.

A product can have more than one hazard class apply to it, but only one category from each class. For example, a product cannot be an irritant and corrosive. In a case such as this, the class chosen is the one that is the most hazardous option; therefore, the product would be corrosive.

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According to WHMIS classifications, Class D (Poisonous and Infectious Material) has 3 divisions. Two of these divisions also havesubdivisions.

Class D1 represents “Materials Causing Immediate and Serious Toxic Effects at greater than or equal to one percent”. This category is further broken up into Class D1A (Very Toxic Material at greater than or equal to one percent) and Class D1B (Toxic Material at greater than or equal to one percent). If a product fits the criteria for a certain TDG Class, Packing group, or falls into the assigned levels for oral, dermal or inhalation toxicity for one of these two classes, it would fall into that class.

Class D2 represents “Materials Causing Other Toxic Effects”. Class D2A (Very Toxic Material at greater than or equal to 0.1 percent) applies to any substance that contains an ingredient which has demonstrated aspects of carcinogenicity, reproductive toxicity, teratogenicity, embryotoxicity, mutagenicity or respiratory sensitization. Class D2A (Very Toxic Material at greater than or equal to one percent) would also include any substance which has been found to have chronic toxic effects in small doses which threatens life or causes serious impairment of cardiovascular or nervous systems, or bodily organs. Class D2B (Toxic Material at greater than or equal to one percent) would incorporate any chemical that has been found to have chronic toxic effects in larger doses (than D2A), mutagenicity, skin sensitization or skin and/or eye irritation.

Please note that for the classes which have a percentage assigned to them, the chemical in question must be present in the mixture in a concentration falling within the range given in order to be classified.

Finally, Class D3 represents “Biohazardous Infectious Material”. Any organism that has been shown to cause or is reasonably believed to cause disease in persons or animals would be classified under this division. Any organisms classified into Risk Group 2, 3, and 4 as determined by the Medical Research Council of Canada (MRCC) or the World Health Organization (WHO) would also be classified as a Class D3 substance.

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Under the CCCR the “main display panel” means the part of the display surface that is displayed or visible under normal conditions of sale to the consumer. This is taken to imply the front of the label as the product would sit on the shelf in a retail setting.

The CCCR has very specific requirements for the main display panel. Exact hazard text and symbols must be present on the label based on the chemical hazard classification, and there are minimum size requirements for the text and symbols.

The main display panel must contain, as applicable, the associated hazard symbol(s), the signal word, and the primary hazard statement(s), all of which correspond with the classification assigned to the chemical under the CCCR regulations. The Consumer Packaging and Labelling Act also requires that the main display panel state the product identity declaration, and the net quantity declaration. The products identity declaration is essentially the products use. If the products name explains what the product is used for then this can count as the identity declaration. All of this required information has minimum size requirements that must be met, of which the sizes are based on the area of the main display panel.

To determine the area of the main display panel the side of the product container that faces the consumer is usually taken, however sometime this is not as straight forward as it seems. Generally in the case of a rectangular container, the largest side of the display surface is the main display panel. In the case of a cylindrical container, the largest of either the area of the top, or 40% of the area obtained by multiplying the circumference of the container by the height. When the product comes in a bag, the largest side of the bag is used. For any other container, the largest surface of the container that is not less than 40% of the display surface is used as the main display panel.

There are specific location requirements for the main display panel information. The hazard symbol, signal word and primary hazard statement must be below the product name, centered and near the base of the product on the main display panel. Additionally all required information must be stated in both English and French languages.

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Many organizations provide services for revising or writing Material Safety Data Sheets (MSDS) ensuring compliance with all necessary regulatory requirements. MSDS authoring to meet the required regulatory standards varies from country to country. The Workplace Hazardous Materials Information System (WHMIS) sets the standards for MSDSs in Canada. WHMIS is regulated by Health Canada through the Controlled Products Regulations (CPR), the Hazardous Products Act (HPA) & Part II. Typically in Canada, a MSDS requires to be reviewed every three years.

A MSDS is a document that contains information about a chemical product. The CPR sets the standard for information that is required on a WHMIS MSDS form. Section 12 of the CPR specifies the categories of information that are required to be disclosed within the MSDS. There are nine categories of information captured on the MSDS form, including: product information, hazardous ingredients, physical data, fire & explosive data, reactivity data, toxicological properties, preventative measures, and first aid measures & preparation information.

Currently, the global requirement is that a MSDS must be completed for all hazardous chemicals. The MSDS should be distributed and available during the production, use, storage, testing, transportation, anddestruction of these chemicals. Currently, there are not many education programs in place to train employees on MSDS authoring unless companies offer this type of training in-house.

At present, it is common for many companies to outsource MSDS authoring. Many small and medium size companies do not have the volume of MSDSs to require a full-time onsite regulatory specialist. It is much more cost effective for these types of companies to outsource their periodic MSDS needs. An increase in complexity with the rules and regulations surrounding MSDS development also makes it more cost effective to outsource these tasks to professionals who receive continual training on new regulations. Most companies do not have the financial support to continually train their employees on the current regulations when they author a minimal number of MSDSs.

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A Drug Identification Number (DIN) is an 8-digit number assigned by Health Canada to a drug product (both over-the-counter and prescription-only) under the Food and Drugs Act (FDA). All drug products that fall under the FDA must be assigned a DIN before market in Canada. The DIN guarantees the drug has been evaluated and authorized for sale in Canada by the Canadian government. The DIN is assigned a random number in order to follow-up on the drug once it gets on the Canadian market. This is particularly important for product recalls, inspections and quality monitoring since it uniquely identifies the product and proves Health Canada approved the drug for sale. A drug product in Canada that does not have an associated DIN is not compliant under Canadian law.

The first thing a manufacturer (supplier) must do to receive a DIN from Health Canada is submit the DIN Application Data, which describes in great detail the drug products complete chemical formulation, consumer label and instructional use to ensure it meets all regulations in Canada. The application must be as detailed and up to date as possible. Once Health Canada receives the application data they begin the Screening phase where completeness and quality is of the essence. This is a good reason why initially filling out the application with as much detail as possible can pay off.

If Health Canada wants clarification in response to the DIN application they can issue a Clarifax (clarification issued to the manufacturer by means of fax mail). The Clarifax can lead to the issue of a Safety, Efficacy, and Quality Review, a Notice of Deficiency (NOD) or Screening Deficiency Notice (SDN), or a Screening Rejection Letter (SRL) or Notice of Deficiency - Withdrawal (NOD/w). The NOD, SDN, SRL and NOD/w are all for additional information because of incorrect or insufficient reporting. If any of these are issued to the manufacturer they must respond with the requested information and the product can re-enter the screening process for the DIN.

A Safety, Efficacy, and Quality Review is the third step in receiving DIN assignment. The review assesses the benefits and risks of the product. A Clarifax can again be issued in response to a NOD or NOD/w, or Notice of Non-compliance (NON) or Notice of Non-compliance-Withdrawal (NON/w). From here the drug application can either be rejected or withdrawn from the DIN application or be accepted for DIN registration.

If the application is completed successfully a DIN is issued for the drug product which authorizes sale in Canada.

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MSDS stands for Material Safety Data Sheets that are essentially documents of a special type. These documents are expected to usher in a new world, a world free from incidents and accidents resulting from chemicals of a hazardous kind. These documents are to be raised for each hazardous chemical that could harm the individual or the environment in any way. Therefore, incendiaries, inflammable chemicals or chemicals that could be sensitive to initiation that could cause an explosion and corrosive chemicals or chemicals that could be toxic or carcinogenic in nature are all covered. The stress is on thorough documentation and total training of personnel who are involved in handling such chemicals in any way whether in production, packing, testing, transporting or in demolition.

MSDS is important from the point of view of total safety due to awareness. All personnel who are involved with such hazardous chemicals would be aware as to how to handle any incident or accident involving such chemicals. Thus, if such a chemical is being transported and there is a spill the personnel accompanying and the safety operators would be aware of the measures that were required to be taken to combat any risk from fire or explosion that may arise. They would have the necessary safety gear and would be competent to handle such incidents to a safe conclusion.

The documents also lay down some important physical data such as the vapor pressure, the associated odor, the boiling point and the degree to which the chemical reacts with other substances. There are several regulatory bodies for MSDS such as the National Institute for Occupational Safety and Health or NIOSH, the Occupational Safety and Health Administration or OSHA and the Environment Protection Agency or EPA. There are some competent agencies as well that offer services towards MSDS authoring in respect of the data sheets in the United States, Canada and Mexico besides some other countries. With this new form of documentation it is hoped that there would be a global reduction in incidents and accidents involving hazardous chemicals and as a result there would be greater health and security in the new world.

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There are a large number of chemicals that are hazardous in nature. These chemicals could be explosive in nature or inflammable or both. They could also be toxic, carcinogenic or corrosive. Therefore, the need was felt to document such chemicals on standardized Material Safety Data Sheets or MSDS. The idea of such documentation is hardly new. Such an idea existed during the time of Imhotep - the Egyptian physician some 4 thousand years ago. He would place every detail regarding his prescription on record. Such details included materials used, their sources and names and how they were prepared. The method of storage was on record as well as the application. Warnings were detailed concerning incorrect use.

Modern times have made the introduction of MSDS absolutely imperative. Every hazardous chemical will henceforth need to be catalogued in a standard manner. In order to improve the safety and health conditions of personnel engaged in the processing of such chemicals it’s essential that all personnel involved in the production, storage, packing, testing, transportation and destruction of these chemicals are to be fully equipped and trained in the very nature of these chemicals.

The MSDS will need to display complete particulars concerning the hazardous chemicals. The particulars will include the names of the chemicals and the full particulars and address of the supplier as well as the producer. The constituents will have to be detailed together with important physical data such as the boiling point, vapor pressure and the odor besides the degree to which the chemical might react with other substances. The sensitivity to explosion and the degree to which the chemical is inflammable are both most pertinent. The protective and safety gear to be used and the first aid measures that may be required are to be clearly stipulated.

Finally, there are regulatory bodies for MSDS. Some of these bodies are the National Institute for Occupation Safety & Health or NIOSH, the Occupational Safety & Health Administration or OSHA and EPA or the Environment Protection Agency. There are competent agencies in the US, Canada, Mexico and some other countries that offer competent services towards MSDS authoring.

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The United Nations introduced the concept of Globally Harmonized System or GHS as an attempt to classify all hazardous chemicals in a uniform manner for information and consultation. The United Nations Economic and Social Council subsequently endorsed this concept in July 2003. The method classifies the hazardous chemicals based on the hazard types that they are associated with.

Till the introduction of GHS every independent country had its own method of classification of hazardous chemicals, their labeling and symbols defining the nature and class of associated hazard that could be fire, explosion or both besides toxicity. Therefore, when such chemicals were transported through other countries there was an absolute lack of awareness of the manner in which a spillage was to be tackled or a conflagration and/or explosion. There was no common directive to define the precautions that were to be considered, or the manner in which a particular type of incident or accident was to be handled.

With the introduction of GHS, a commonality is being established globally. The intention of establishing such a commonality is ultimately to bring in a global improvement in health and safety standards, especially in a field that is so hazardous. The approach adopted is to establish a relationship between the classification and the associated hazard criteria. Subsequently, the link is to be communicated down the line to all the dealing personnel on the hazards, the protective measures that were necessary and the methodology of labeling that was to be adopted. The labeling could be an SDS (Safety Data Sheet). Companies dealing in such chemicals would need the services of a competent GHS consultant.

The new system is not legally binding though it’s an international agreement. It’s also not a standard nor is it a regulation. There is no deadline stipulated for implementation. However, there are immense benefits to the society in general and the industry in particular from its implementation. It is hoped that with the spread of awareness about the associated hazards there will be a dramatic fall in the rate of accidents globally bringing in an improvement in productivity and cost effectiveness besides ensuring better health conditions.

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