Reprinted from the ACJ - October, 1995
I am often asked if I am from Canada. It may be because I sometimes say "Hey Der" instead of "Hello There." Or ask "Aboot how far is it to Dullut?" instead of "About how far is..." I guess growing up in Wisconsin is close enough to the Great White North to absorb some of the syntax. Either that or I've watched the movie "Strange Brew" with Bob and Doug McKenzie once too often.
NAFTA has changed the "our side/your side" mentality into one of mutual cooperation while trying to make heads or tails out of the increased paperwork and mountains of forms. There is no time for animosity.
But there are differences; some are slight, others more pronounced. Canada has moose, the U.S. has moose lodges (same goes for elk). The U.S. has Budweiser, Canada has Labatts. The U.S. has bacon, Canada has Canadian bacon (I believe it has to do with the nationality of the pig). Americans have baseball caps, Canadians have toques. Americans have football, Canadians have hockey. Americans have baseball, Canadians have hockey. Americans have basketball, Canadians have hockey.
And most important for our discussion, the U.S. has OSHA's Worker Right to Know (RTK) laws, and Canada has the Controlled Product Regulations including the Workplace Hazardous Materials Information System (WHMIS).
Both systems are designed to provide employees exposed to hazardous materials with information concerning how to assess the hazards present and the proper work and handling methods to avoid detrimental exposure to the nasties. Each also requires hazard assessment by both the supplier and employer/purchaser of hazardous materials.
A difference exists in how this is done. In Canada, an actual list of chemicals considered hazardous has been compiled. This is called the Ingredient Disclosure List. If a chemical or component of a product is on this list, safety precautions, training and an MSDS must be prepared. Canada also adds that any non-listed chemical showing corrosivity, flammability, oxidation potential, explosivity, reactivity or that presents a physical hazard must be similarly addressed.
OSHA, on the other hand, does not provide a list but requires the manufacturer to asses the dangers based on the categories above. As a result, you'd better have done your shop hazards homework before the OSHA inspector comes in.
MSDS programs are very similar in the two countries. Suppliers must forward a copy of the MSDS with each hazardous product. Any distributor of the products also has an obligation to make sure his customers have a copy of the current MSDS. The end user must keep a MSDS for each hazardous product in his shop available to his employees.
The categories on the MSDS are identical: who made it, emergency contact, hazardous ingredients, physical characteristics, flammability and reactivity information, health hazards, first aid, and handling and personnel protective equipment information.
One difference in Canada is that the MSDS has to be in both English and French. Canada also requires that MSDS be updated once every three years or sooner if the hazards change. OSHA requires updates only as the hazards change. Both countries require hazardous ingredients above one percent to be disclosed, and carcinogens above 0.1 percent to be listed.
Labeling requirements exist in both systems. In the U.S., the label must be legible and include, as a minimum, manufacturer and product identification, cautionary statements including the names of dangerous chemicals in the product, and first aid procedures. The same is true in Canada. In addition, the label must be available in French, if requested, and reference the availability of a MSDS for the product.
Canada also requires inclusion of standardized hazard symbols if they apply, and provides size and border requirements for the labels. Employers in both countries must ensure products they receive are properly labeled or re-label them if they are not. It is recommended in both the U.S. and Canada that purchasers not remove any labels affixed by the manufacturer.
Required in both countries are:worker training regarding the hazards present, how they are labeled, MSDS reading, proper work methods to avoid the dangers, knowledge of the proper protective equipment required when working with the hazard, signs and symptoms of overexposure, and first aid procedures.
Both OSHA and the WHMIS system also require that the employer or end user of a controlled product maintain a written program describing how you comply in your shop with the described procedures, as well as hazard assessment, labeling, MSDS and training. OSHA also requires that this written program include a list of the hazardous chemicals present in your shop. In the U.S., the worker RTK program applies to any shop with 10 or more employees. In Canada, I found no such exemption, so it applies to everyone.
In keeping with our neighborly Can/Am presentation here today, I will conclude by encouraging both suppliers and employers on both sides of the border to grab some paper, pull up a chair, flip on the football/hockey (choose one) game, pop open a Bud/Labatts (choose one...or both), and begin writing about/aboot (choose one) your shop's RTK/WHMIS (choose one) program, OK/eh?
The above article was written by David M. Brown, Chief Engineer of Johnson Manufacturing Company, Inc. and is published by JOHNSON with the expressed approval of the National Automotive Radiator Service Association and the Automotive Cooling Journal. Other reproduction or distribution of this information is forbidden without the written consent of JOHNSON and NARSA/ACJ. All rights reserved.
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