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Workplace Hazardous Materials Information System (WHMIS)

The PROC technique, which stands for Product, Resource, Operating, and Contingent costs, is a methodology used in government procurement to evaluate bids, offers, or arrangements, focusing on the total cost of ownership throughout the lifecycle of a project.

WHMIS is Canada's national hazard communication standard for workplace chemicals. If you're procuring anything from cleaning supplies to industrial solvents, understanding this system isn't optional—it's embedded in federal, provincial, and territorial legislation that governs how hazardous products must be labeled, documented, and communicated throughout the supply chain.

How It Works

The system operates through coordinated legislation across all levels of Canadian government. At the federal level, the Hazardous Products Act (HPA) and Hazardous Products Regulations (HPR) set the framework. The HPR, published February 11, 2015, aligned Canada's system with the Globally Harmonized System of Classification and Labelling of Chemicals (GHS), replacing the original framework that had been in place since October 31, 1988.

Here's what matters for procurement: suppliers must classify their hazardous products according to specific criteria, then provide bilingual labels and Safety Data Sheets (SDSs) at the time of sale. There's no pre-market approval process under the HPA. One exception exists—if a supplier wants to claim confidential business information (CBI) under the Hazardous Materials Information Review Act (HMIRA), that requires registration. Otherwise, suppliers can sell their products as long as they meet the classification and communication requirements outlined in Health Canada's supplier hazard communication requirements.

In practice, this means when your department orders anything that falls under WHMIS—paint, adhesives, compressed gases, you name it—the supplier is legally required to provide proper documentation. They must maintain labels, SDSs, and sales records for six years. The system applies to hazardous products sold or imported for use, handling, or storage in Canadian workplaces, which includes federal facilities operated by PSPC, DND, and other departments.

Key Considerations

  • The bilingual requirement isn't negotiable. Both labels and SDSs must be in English and French before products arrive at your workplace. This catches some suppliers off guard, particularly those new to the Canadian market.

  • WHMIS applies throughout the product lifecycle. When you're evaluating total cost of ownership, factor in training requirements, storage specifications, and disposal costs that stem from a product's hazard classification.

  • Federal facilities have additional obligations beyond what suppliers must provide. While suppliers deliver the classification and documentation, your department handles worker education, workplace labeling of decanted materials, and ensuring SDSs are accessible.

  • The 2015 alignment with GHS changed pictograms, hazard classes, and SDS formats. If you're working with older contracts or stored materials, you might encounter products with outdated labeling that predates the HPR revisions.

Related Terms

Environmental Compliance, Occupational Health and Safety, Supply Arrangement

Sources

When reviewing bids that include hazardous materials, verify that suppliers understand their WHMIS obligations before award. It's easier to confirm compliance upfront than to sort out missing documentation after delivery.

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