WHMIS Roles and Responsibilities 3 — Questions and Answers
Question 1: A company manufactures a controlled product for export only. Under WHMIS, are they required to comply with Canadian labeling requirements?
- No, export-only products are exempt from WHMIS labeling (Correct answer)
- Yes, all products manufactured in Canada must carry WHMIS labels regardless of destination
- Only if the destination country requests WHMIS compliance
- Only if the product is also sold domestically
Correct answer: No, export-only products are exempt from WHMIS labeling
WHMIS labeling requirements apply to controlled products sold, offered for sale, or imported for use in Canadian workplaces; export-only products are generally exempt.
Question 2: Who is responsible for updating an SDS when new hazard information about a product becomes available?
- The employer who uses the product
- The supplier or manufacturer of the product (Correct answer)
- The joint health and safety committee
- The provincial government
Correct answer: The supplier or manufacturer of the product
Suppliers and manufacturers are responsible for keeping SDSs current and must update them when significant new hazard information is identified.
Question 3: Under WHMIS, if a product is produced and used entirely within one workplace (an in-house product), who is responsible for creating the required label and SDS?
- The federal government
- The employer who produces and uses the product (Correct answer)
- The supplier who provided the raw materials
- No label or SDS is required for in-house products
Correct answer: The employer who produces and uses the product
For products produced and used within the same workplace, the employer acts as both supplier and employer and must create workplace labels and SDSs.
Question 4: Which WHMIS obligation falls specifically on importers of hazardous products?
- Training workers at the point of manufacture
- Ensuring the product meets supplier labeling and SDS requirements (Correct answer)
- Registering each imported product with Health Canada
- Paying a WHMIS compliance fee to the province
Correct answer: Ensuring the product meets supplier labeling and SDS requirements
Importers are treated as suppliers under WHMIS and must ensure that imported products have compliant labels and SDSs before they enter Canadian workplaces.
Question 5: A new worker starts a job that involves handling solvents. Before the worker begins using the solvents, the employer must:
- Have the worker sign a liability waiver
- Ensure the worker has received WHMIS education and site-specific training (Correct answer)
- Provide the worker with only the SDS and allow self-directed learning
- Wait until the worker's 90-day probation period is complete
Correct answer: Ensure the worker has received WHMIS education and site-specific training
Employers must provide WHMIS education and site-specific training before a worker is exposed to or works with controlled products.
Question 6: Health and safety representatives in smaller workplaces (without a full JHSC) have what WHMIS-related role?
- Issuing fines to employers who violate WHMIS
- Performing the same advisory and hazard identification functions as a JHSC would (Correct answer)
- Taking over employer obligations for training
- None — only JHSCs have WHMIS roles
Correct answer: Performing the same advisory and hazard identification functions as a JHSC would
Health and safety representatives fulfill similar advisory functions to JHSCs in workplaces too small to require a full committee.
Question 7: Under WHMIS, employers are required to make SDSs accessible to workers:
- Only during regular business hours in the HR office
- At all times during the work shift when the controlled product is in use (Correct answer)
- Only when a worker specifically requests one
- Once per year during the annual safety review
Correct answer: At all times during the work shift when the controlled product is in use
SDSs must be readily accessible to workers at all times during their shift whenever the controlled product is present in the work area.
WHMIS Roles and Responsibilities 3
A company manufactures a controlled product for export only.
Under WHMIS, are they required to comply with Canadian labeling requirements?