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:
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The movement of all Dangerous Goods in Canada is regulated by Transport Canada for all modes of Transportation and is governed by the Transportation of Dangerous Goods Regulations (TDGR), the International Civil Aviation Organization Technical Instructions (ICAO TI) as well as the International Marine Dangerous Goods Code (IMDG). Each of these outlines’ specific instructions for the shipping/handling/receiving and consumer purchasing of each Dangerous Goods product or those products contained within e.g., Lithium Batteries. Having a visible safety mark on the outside of a means of containment to identify the potential hazards is part of these instructions and works to keep all individuals safe and secure from possible illness/injury caused by unmarked packaging.