RG-1 Regulatory Guidance:
Chapter 4 – Labelling and guarantees
4.13 Responsibilities regarding the Labelling of Livestock Feed Products under the Workplace Hazardous Material Information System (WHMIS)

Introduction

This section provides a brief description of the WHMIS and outlines responsibilities with respect to WHMIS labelling on livestock feeds, as well as describing the relevant legislation for livestock feed products. Health Canada has established the national WHMIS regulations, and all enquiries regarding WHMIS should be directed to Health Canada at the WHMIS web site, or the address listed below.

What is WHMIS?

WHMIS is Canada's standard for hazard communication. Complying with WHMIS requires the cautionary labelling of containers of hazardous materials, the provision of Material Safety Data Sheets (MSDSs), and worker education programs. The Hazardous Products Act (HPA) establishes the supplier/importer labelling and MSDS requirements of WHMIS. Section 12 of the HPA establishes exemptions from these requirements for certain product categories such as food, pesticides and medical devices. Feeds and feed supplements are not encompassed by any of these exemptions, and thus may be subject to the WHMIS requirements legislated under the HPA. Feeds and feed supplements are also subject to the employer requirements set out by federal, provincial and territorial regulatory authorities responsible for Occupational Health and Safety (OHS).

The Government of Canada has established administrative arrangements with federal, provincial and territorial OHS regulators to conduct inspections for compliance with the WHMIS requirements of the HPA. However, Health Canada remains ultimately responsible for the administration of the HPA and it is the WHMIS program officials at Health Canada who set national regulatory, compliance, and enforcement policies. The WHMIS Web site was developed, and is maintained, by Health Canada's WHMIS program, on behalf of all federal, provincial and territorial government WHMIS regulatory authorities. The site provides a single window for national policies and information related to the administration of the WHMIS program in Canada.

Labelling

The requirements for WHMIS labelling are not administered under the Feeds Act and Regulations. However, when a WHMIS label is used on a product subject to the Feeds Act, the information contained within the WHMIS label must not contravene the requirements of the Feeds Act and Regulations.

Cautionary statements required by both the Feeds Act and WHMIS need only appear in the WHMIS section of the label. Label information required under the Feeds Act, but not required under WHMIS, including guaranteed analysis, registration numbers, etc., must be placed outside the hatched border of the WHMIS label. For products regulated under the Feeds Act, WHMIS labelling is required for most processing aids, acids, mineral products, and any other product that has the potential to be used in the workplace. Medicated feeds are not WHMIS-controlled, however, MSDSs must be maintained and provided upon request. Please contact Health Canada if you are unsure whether your product requires WHMIS labelling. It is the responsibility of the supplier/importer to ensure that product labelling complies with both the Feeds Act and WHMIS.

WHMIS References

All information pertaining to WHMIS labelling, MSDS requirements, classifications, exemptions, and enforcement can be found in the WHMIS Reference Manual. The WHMIS Reference Manual provides a section-by-section discussion of the federal legislation which sets out labelling and MSDS requirements for Canadian suppliers and Canadian importers. The manual, which includes a comprehensive index, can be obtained from the national WHMIS Web site.

or by contacting Health Canada at:

WHMIS Program, Health Canada
MacDonald Building
123 Slater Street, 4^th Floor
Address Locator: 3504D
Ottawa, Ontario, K1A 0K9
Telephone: 613-957-2342

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