Monday, September 16, 2013

Understanding the Training Requirements Under WHMIS Regulation

Understanding the Training Requirements Under WHMIS Regulation

By law, every employer is solely responsible for ensuring their employees are adequately trained in WHMIS. This includes identifying if the workplace requires WHMIS training or not. Under Regulation 860 of the Occupational Health and Safety Act, WHMIS training is required for all employees who are exposed to or likely to be exposed to a hazardous material or controlled product found at the workplace. This definition includes employees who do not use any controlled products, but who have physical access to them.

The definition of controlled products can be confusing to many employers especially as the distinction of a product can change based on the quantity purchased or the distribution methods used. Regulation 860 outlines that an employer shall assess all biological and chemical agents found at the workplace to determine if they are in fact hazardous. This can be particularly difficult when dealing with the example of bleach: when purchased in bulk, bleach is a controlled product; when purchased at the grocery store marketed for home use, bleach does not require WHMIS labelling. This holds true as well when transferring products: some products do not require WHMIS labelling when left in the container they were purchased in, but by transferring them into new/smaller containers WHMIS labelling is required and therefore WHMIS training is necessary.  Employers can save their workplaces from having to comply with WHMIS by eliminating unnecessary controlled products. This can be as easy as purchasing many cleaning products directly from the grocery store instead of in bulk from suppliers. While this may cost more money upfront, employers will save time and money in the long run by not having to comply with WHMIS regulation.

If employers find that they cannot eliminate their controlled products, training must be reviewed at least annually or more often if there is a change in product. The Canadian Department of Human Resources and Skills Development (HRSDC) provides employers with six training requirements to comply with the mandatory aspects of the WHMIS Regulation 860.  HRSDC states that employers must ensure that:

1.    The workplace education program is developed together with the health and safety representative/joint health and safety committee;

2.    Workers can recognize and describe the meaning of the WHMIS symbols and other symbols used in the workplace; 

3.     Workers understand the concept of WHMIS and the legislative requirements of labelling, MSDS and training; 

4.    The training program is workplace specific and is presented at a level that may be understood by all workers at the workplace; 

5.    A program is developed and implemented to train new workers and to retrain experienced workers regarding new information; and 

6.    The entire program is reviewed at least annually.

By ensuring that your training program has met all of the above requirements, your workplace will be fully compliant with the Occupational Health and Safety Act’s WHMIS Regulation.


Lynne Bard, BA (Honours), C.H.R.P., CES
Human Resources, Safety & Risk Management Experts
Taking the Complexity out of Compliance
Beyond Rewards Inc.
Phone: 519-821-7440
Cell: 519-830-7480

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