Canada published the much anticipated final Hazardous Products Regulations (HPR) in the Canada Gazette Part II on 11 February 2015.

Representatives of the Canadian government and the United States OSHA have worked together to align the GHS regulations in both countries, and assurances continue that a single SDS can comply with both systems. There will be substantial complexities realizing this goal however; for example:

• US OSHA published mostly based on GHS Revision 3 while Canada published based on Revision 5. US OSHA has indicated that using newer revisions is acceptable -- if there is no reduction in the safety achieved. This raises questions such as: if a worker is trained to see a compressed gas cylinder on an aerosol product, does applying the GHS Revision 4 aerosols classification without that pictogram comply?
• Physical hazards not otherwise classified and Health hazards not otherwise classified are actual classes in Canada, given category 1 if any such unspecified hazard applies, AND they must have signal word, pictogram (pick your own from the ones in GHS) – anticipate a nightmare trying to organize precedence on these undefined elements together with the standardized elements. OSHA has indicated that using signal words and pictograms is acceptable, although not prescribed, for the single class of hazards not otherwise classified (HNOC) established by US OSHA.
• Canada created a GHS classification for biohazards which is not existing in the US OSHA regulations.
• Canada prescribes classifications for certain products subject to special status in transport regulations (see page 433+ of the Gazette).

Canada's GHS implementation dates

The first deadline is 1 June 2017, for manufacturers/importers. From 1 June 2018, distributors must apply the new HPR and from 1 Dec 2018, Employers must comply with the new rules (containers already labelled per the old CPR do not have to be relabeled until 1 June 2019.