How does a supplier know if a product is a WHMIS “controlled product”?
A. A product, material or substance which falls within any of the hazard criteria set out in sections 33 to 65 of the CPR is a “controlled product” and, unless excluded under section 12 of the HPA, is subject to the supplier MSDS and label requirements of the HPA if the controlled product is sold or imported for use in a Canadian workplace. It is the responsibility of the party marketing the product in Canada or the Canadian importer to assess the product against the classification criteria of the CPR. Section 12 of the HPA excludes certain product categories from the federal WHMIS requirement to apply a supplier label and to transmit a MSDS. These categories are : food; drugs; cosmetics; medical devices; pesticides; explosives; radioactive materials (except controlled product carrier materials in radionuclide mixtures); consumer “restricted” products; wood and products made of wood; tobacco and products made of tobacco; manufactured articles; and hazardous waste.
