Written on: March 1, 2026 by Cassandra Taylor
On Nov. 20, 2025, I attended Health Canada’s Workplace Hazardous Products Program (WHPP) stakeholder workshop, which provided updates on regulatory developments affecting hazardous products used in Canadian workplaces and offered insight into Industry concerns related to chemical compliance.
The workshop opened with a discussion from Health Canada on the international context of the Globally Harmonized System of Classification & Labeling of Chemicals (GHS) and how countries collaborate to implement the framework. Alignment between the U.S. and Canada continues to be a priority, with the objective of enabling a single safety data sheet (SDS) and label that are compliant in both countries to facilitate cross-border trade and reduce unnecessary burden on stakeholders.
The discussion then shifted to an industry perspective on barriers to GHS implementation. The speaker emphasized that GHS is widely viewed as the foundation of an effective chemicals management system and noted ongoing efforts to expand implementation across Africa. Key challenges include selecting which GHS revision to adopt, keeping pace with biennial updates, limited Government prioritization, insufficient guidance on technical criteria, and a lack of policy direction for selecting hazard classifications and cut-off values. For example, where multiple cut-off values are permitted, implementation can be delayed if the preferred option is unclear. Additional challenges arise in countries with limited proficiency in United Nations languages, where interpreting differences between GHS revisions can be particularly difficult.
The organizers also highlighted the Red Tape Review launched by the Government of Canada in July 2025 and Health Canada’s Report of Red Tape Reduction, published in September 2025. The objective is to reduce regulatory burden by removing barriers to investment and growth. “Red tape” can include complicated or outdated processes, unnecessary or duplicative requirements, overly burdensome rules or inefficient or unpredictable regulatory administration and service delivery.
With respect to enforcement of the Hazardous Products Act (HPA) and the Hazardous Products Regulations (HPR), Health Canada indicated that its approach will focus on compliance promotion until the July 19, 2027, U.S. implementation deadline for mixtures. This will include awareness-raising and education of regulated parties on their obligations under the HPA and the amended HPR. Beginning July 19 of next year, compliance and enforcement activities will shift to a risk-based approach.
The next presentation came from an HPA inspector, who outlined the inspector’s role, how inspected parties are identified and what to expect during an inspection. Companies may be selected for inspection in several ways, including through Health Canada supplier lists, complaints or concerns submitted to authorities, annual targeted inspection plans or random selection. Inspections may be scheduled or unannounced and can focus on general compliance or a specific area of interest. Inspectors may request to review products on site, as well as copies of SDSs, labels or transaction records. Following an inspection, the inspector prepares a report summarizing findings and observations and may prescribe corrective actions to be completed within specified timelines. Inspection outcomes are typically rated as “Satisfactory,” provided the inspected party cooperates.
The most common area of non-compliance, affecting nearly 50% of reviewed SDSs, relates to the emergency telephone number requirement. The key requirement is that a knowledgeable person must be available to provide additional information about the hazardous product, such as the manufacturer or supplier. The emergency phone number does not need to be staffed 24/7, provided the availability conditions are clearly indicated on the SDS. It is important to note that the Canadian Transport Emergency Centre (CANUTEC), operated by Transport Canada, and 911 are not acceptable emergency numbers for SDS purposes. CANUTEC applies to transportation emergencies only and cannot provide information on the storage, use or handling of hazardous products. Other subscription-based emergency response services, such as the Chemical Transportation Emergency Center (CHEMTREC), may be acceptable provided they meet the requirements set out in the HPR.
There was an opportunity for Q&A, and while Health Canada could not address all inquiries during the session, they followed up with a comprehensive summary responding to all questions posed.
This is also where the discussion becomes aerosol-specific, and a clarification is warranted to a statement made in my September 2025 SPRAY column on the Workplace Hazardous Materials Information System (WHMIS) 2022 transition. In that column, I indicated that removal of the gas cylinder pictogram is optional for aerosol products. During the Q&A session, Health Canada clarified that “the use of a symbol in a pictogram that is not prescribed for a product’s classifications may contravene section 14.2 of the HPA.” Section 14.2 permits additional label information only where it is not false, misleading or likely to create an erroneous impression.
Unlike GHS Revision 7, the HPR does not explicitly exclude aerosols from also being classified as Gases Under Pressure. As a result, where a product meets the criteria for both hazard classes, it is permissible under the HPR to classify the product accordingly and to display both the flame and gas cylinder pictograms on the label. At the same time, products classified as aerosols are not required to also be classified as Gases Under Pressure. In practice, the recommended approach is therefore to remove the gas cylinder pictogram and align the label elements with those specified in GHS Revision 7 for the applicable aerosol category.
Stakeholders raised concerns about inaccurate SDSs and how Health Canada verifies that mixture classifications are correct. It was noted that HPA inspectors do not classify products themselves and generally avoid becoming directly involved in classification determinations; suppliers remain fully responsible for the accuracy of their SDSs. Where classification concerns arise, inspectors may refer products to Health Canada for a formal classification assessment. Concerns about specific products can be submitted directly to Health Canada at [email protected] for review.
Another concern raised by stakeholders related to the evaluation of environmental hazards, particularly with respect to transportation of hazardous goods. Although information in Section 12 of the SDS is not mandatory under the HPR, Industry often relies on it when shipping products internationally. As a result, a gap exists between workplace hazard requirements and transportation needs, leaving shippers uncertain about how to determine environmental hazards. Stakeholders questioned where reliable hazard information should be obtained and whether clearer guidance will be provided to manufacturers for environmental hazard determination. Health Canada reiterated that GHS environmental hazard classifications are not adopted under the HPR, as they are not considered workplace hazards. While Section 12 of the SDS remains optional, information may be included provided it is not false or misleading. Environmental hazards are addressed separately by Environment & Climate Change Canada (ECCC) through the administration of the Canadian Environmental Protection Act (CEPA) and the Toxic Substances List. Although Health Canada did not endorse any specific data source for environmental hazard determination, at Nexreg we typically rely on the European Chemicals Agency ECHA CHEM database when assessing environmental classifications.
Other topics covered included the requirement for a Canadian supplier address on Canadian SDSs and labels, as well as U.S.-Canada trade barriers. Health Canada noted that the only exemption to the Canadian supplier address requirement applies to Canadian companies who import hazardous products solely for use in their own workplaces.
Concerns were also raised about Canada’s requirement to submit an application and pay a fee to protect confidential business information on the SDS—an obligation that does not exist in the U.S. Health Canada remains committed to working with stakeholders to address challenges related to cross-border alignment; however, differences between the U.S. and Canadian regulatory systems complicate the process, particularly given Canada’s requirement to consult with provinces and territories when implementing regulatory changes.
Finally, Health Canada confirmed that consultations on proposed regulatory measures under the Canada Consumer Product Safety Act (CCPSA) to address certain human health hazards of concern (HHHOCs), as well as a proposal to remove the consumer product exclusion from the HPA, are currently paused as the department works through priorities established under the Government’s mandate commitments. While this pause is not unexpected, it suggests that updates to consumer product requirements may be slow to materialize. In the meantime, suppliers should continue prioritizing compliance with the CCCR, 2001 for consumer products and the updated WHMIS requirements for workplace products sold in Canada. SPRAY
