Canada’s HPR Concentration Range Amendment Set to Go Live – With One Change

WHMIS 2015 LogoA few months ago we shared a proposed amendment to Canada’s Hazardous Products Regulations.  Health Canada has announced that the proposed change is set to be officially published in the Gazette, Part II next week. The concentration ranges that were detailed in the earlier post remain the same in the final amendment. One change was made to allowances for combining concentration ranges. The finalized amendment now allows for the combination of two consecutive concentration ranges instead of three as in the proposed amendment. Commentary on this change is provided in the Regulatory Impact Analysis.

The Regulatory Impact Analysis Statement also provides additional commentary that includes further interpretation of the requirement for a statement to be provided “immediately following” the use of a prescribed concentration range.  It details that “immediately following” can be interpreted to mean placing a statement at the end of an ingredients table and including an asterisk or footnote that clearly links the prescribed concentration range in the table to the statement. This additional clarification in the interpretation for the required statement is good news for SDS authors and authoring systems everywhere as many systems already allow the functionality to add a footnote that relates to the ingredients table.