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Supplier Responsibilities with A Hazardous Substance Assessment

March 05, 2021

Supplier Responsibilities with A Hazardous Substance Assessment

Suppliers are responsible for producing SDSs that accurately disclose the hazards associated with products regulated under the HPA. Although the information contained in the Hazardous Substance Assessment may be used by suppliers when developing the SDS, the supplier is ultimately responsible for the accuracy and currency of the SDS. Suppliers may use public information, as well as proprietary information, when developing an SDS.

While the classification information included in the Hazardous Substance Assessments can serve as a guide for classifying a product, suppliers must classify their products in accordance with the HPR, based on established scientific principles, and supported by studies and scientific data at their disposal, whether publicly available or proprietary. Hazardous Substance Assessments are based solely on publicly available information and may not be completely up to date.

For this reason, Hazardous Substance Assessments are not used to determine whether an SDS is compliant under the HPA. Health Canada assesses the compliance of SDSs on a case-by-case basis, and in consideration of the information provided by the supplier to support their classifications.

Legal requirements from Regulatory boards:

TDG - Every 3 years or if someone comes into company as Certification is not transferable
WHMIS - Refresher every year (not legally required but should be done)
Air (ICAO) - Every 2 years
Marine (IMDG) - Every 3 years.





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