What Is Considered A Controlled Product When Making A Whmis Msds?

By Author: Jeff Burns
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Under WHMIS a controlled product is a chemical product used in the Canadian workplace which meets the hazard criteria under the Controlled Products Regulations (CPR) in sections 33 to 66. To be a controlled product a chemical cannot be excluded as a hazard under the Hazardous Products Act (HPA) in section 12.

Under the CPR a WHMIS controlled product is any substance which belongs to one or more of the following WHMIS classes:

- Compressed gas
- Flammable and combustible material
- Oxidizing material
- Poisonous or infectious material
- Corrosive material
- Dangerously reactive material

As stated in section 12 of the HPA, the following chemical products are all exempt from being WHMIS controlled products:

- Explosives under the Explosives Act

- Cosmetics, devices, drugs, and food under the Food and Drug Act

- Pest control products defined in subsection 2(1) under the Pest Control Products Act

- Nuclear radioactive substances under the Nuclear Safety and Control Act

- Hazardous waste

- Products, materials or substances included in Part ...
... II of Schedule I and packaged as a Consumer Product

- Wood and wood products

- Tobacco and tobacco products defined in section 2 under the Tobacco Act

- Manufactured articles

So if the chemical product falls under the CPR and is not exempt under the HPA then it must be classified as a WHMIS controlled product. The controlled product must have an associated hazard label and WHMIS MSDS if it is being sold or imported for use in the Canadian workplace.

Section 13 of the HPA states when and what type of information, in regards to the controlled product, must be disclosed on the WHMIS MSDS:

(i) where the controlled product is a pure substance, the chemical identity of the controlled product and; where the controlled product is not a pure substance, the chemical identity of any ingredient thereof that is a controlled product and the concentration of that ingredient

(ii) where the controlled product contains an ingredient that is included in the Ingredient Disclosure List (IDL) and the ingredient is in a concentration that is equal to or greater than the concentration specified in the IDL for that ingredient, the chemical identity and concentration of that ingredient
About Author:
Jeff Burns writes for Nexreg Compliance Inc., a company that provides WHMIS MSDS authoring and MSDS services.