ANAC urges government to delay WHMIS 2015 implementation for the feed industry

February 28, 2018

With the June 1st deadline for WHMIS 2015 (Workplace Hazardous Materials Information System version incorporating Globally Harmonized System of Labelling and Classification, or GHS) implementation fast approaching, ANAC has received many questions from members on its application to their businesses. For most complete feed manufacturers, the main questions relate to methods for determining if a combustible dust hazard exists in products. For premix manufacturers, additional concerns include the logistics and cost of printing the red hatched border around defined hazard symbols, as required by the regulations.

ANAC has requested on several occasions clarification on key changes and exemptions from the Workplace Hazardous Material Bureau of Health Canada (responsible for the regulation); however, we have received few responses and many fundamental questions remain unanswered. As such, there is little additional information about compliance in feed available to members since ANAC’s industry-specific guidance (PDF) was published in May 2017. Moreover, the CFIA Animal Feed Division is largely unaware of the WHMIS 2015 requirements and it is still unclear who would be inspecting facilities or how likely it would be for feed facilities to receive a WHMIS-related inspection.

As agreed by the ANAC directors at their October meeting, the association has escalated this issue with Health Canada. A letter was sent to the Acting Director General of the Consumer Product Safety Directorate of Health Canada in December outlining the outstanding questions related to interpretation of the regulation and requesting that the WHMIS 2015 compliance deadline for the feed industry be pushed to a year from when industry’s questions could be answered. ANAC has yet to receive a response and we are committed to continuing to escalate this issue with Health Canada until our industry’s questions have been answered. ANAC will keep members informed of any new developments.

ANAC is also actively participating on a working group of the International Feed Industry Federation (IFIF) whose goal is to provide guidance and support on the global implementation of GHS in a pragmatic and harmonized way. A webinar introducing GHS was held on February 12th. It provides some useful information on the interpretation of GHS globally and includes European, US, and Canadian perspectives and challenges related to implementation. A recording of the webinar and presentation slides can be downloaded HERE