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If I Have Multiple Products With The Same Chemical Composition Do I Need A New Whmis Msds For Each A
The short answer is No. There does not need to be a different WHMIS MSDS for each product of similar chemical composition.
Section 6 of the Controlled Products Regulations (CPR) explains controlled products with same product identifier:
(1) The sale or importation of a controlled product is exempt from the application of paragraph 13(a) or 14(a) of the Hazardous Products Act (HPA) in respect of the requirement to transmit, obtain or prepare a WHMIS MSDS for the controlled product if:
a) the controlled product is part of a shipment of controlled products that have the same product identifier and a WHMIS MSDS is transmitted with the shipment or is obtained or prepared for one of the controlled products
b) the supplier has transmitted to the person to whom the controlled product is sold or the supplier who imports the controlled product has in his possession a WHMIS MSDS for a controlled product that has the same product identifier and the WHMIS MSDS:
(i) discloses information that is current at the time of the sale or importation
(ii) was prepared and dated not more than three years ...
... before the date of the sale or importation
Section 7 of the CPR explains the generic WHMIS MSDS:
(1) The sale or importation of a controlled product whose chemical composition is similar to the chemical composition of other controlled products in its group is exempt from the application of paragraph 13(a) or 14(a) of the HPA in respect of the requirement to transmit, obtain or prepare a WHMIS MSDS for the controlled product if a generic WHMIS MSDS for the group of controlled products is transmitted, obtained or prepared
(2) The generic WHMIS MSDS shall disclose:
a) where the range of concentration of an ingredient of the controlled product is different from the range of concentration of the ingredient in the other controlled products in the group; beside the name of the controlled product and the ingredient, the range of concentration of the ingredient in the controlled product
b) where the hazard information in respect of the controlled product is different from the hazard information in respect of the other controlled products in the group; beside the name of the controlled product, the hazard information for the controlled product
About Author:
Jeff Burns writes for Nexreg Compliance Inc., a company that provides WHMIS MSDS authoring and MSDS services.
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