WHMIS Supplier and Workplace Labels 3 — Questions and Answers
Question 1: A worker pours a solvent from its original labeled drum into a small cup for immediate use during the same shift. Under WHMIS, is a workplace label required on the cup?
- Yes, all transferred products must have a label regardless of timing
- No, an exemption applies when the person filling the container uses it immediately (Correct answer)
- Only if the solvent is classified as flammable
- Yes, but a simple handwritten label is acceptable
Correct answer: No, an exemption applies when the person filling the container uses it immediately
WHMIS provides an exemption from workplace labeling when the person who fills the container uses the product immediately during the same work shift.
Question 2: Which of the following is NOT required on a WHMIS workplace label?
- Product identifier
- Safe handling information
- Reference to the Safety Data Sheet
- Supplier's name and address (Correct answer)
Correct answer: Supplier's name and address
Workplace labels require only the product identifier, safe handling information, and SDS reference — the supplier's name and address is a supplier label requirement, not a workplace label requirement.
Question 3: A supplier label on a container is partially torn during handling, making the hazard statements unreadable. What must the employer do?
- Continue using the container since partial label information is still visible
- Immediately replace the damaged label with complete and legible information (Correct answer)
- Tape the torn portion and attach a note directing workers to the SDS
- Return the container to the supplier for re-labeling before use
Correct answer: Immediately replace the damaged label with complete and legible information
Employers are legally required to ensure all labels remain complete and legible; damaged or illegible labels must be immediately replaced.
Question 4: Can a Safety Data Sheet physically attached to the outside of a container serve as a WHMIS workplace label?
- Yes, an attached SDS always satisfies workplace label requirements
- No, labels and SDSs are separate and distinct requirements (Correct answer)
- Yes, but only in laboratory or research settings
- Only if the SDS is laminated and permanently affixed
Correct answer: No, labels and SDSs are separate and distinct requirements
An SDS cannot replace a label; WHMIS requires both a label on the container and a separate SDS — they are complementary but not interchangeable.
Question 5: Which scenario requires a workplace label rather than a supplier label?
- A purchased chemical arrives with a complete, legible supplier label
- A hazardous product is manufactured on-site for in-house use (Correct answer)
- A worker reads the SDS before using a properly labeled product
- A supervisor posts safe handling instructions near a storage cabinet
Correct answer: A hazardous product is manufactured on-site for in-house use
Products manufactured at the workplace have no supplier, so the employer must create and apply a workplace label.
Question 6: Under U.S. HazCom regulations aligned with WHMIS/GHS, what language must labels be written in?
- English only (Correct answer)
- English and Spanish
- The primary language spoken by the majority of workers
- Any language, provided the employer offers translation services
Correct answer: English only
U.S. HazCom requires labels to be in English; employers may add additional languages but English is mandatory.
Question 7: How are workplace labels fundamentally different from supplier labels in terms of required content?
- Workplace labels require more detailed information than supplier labels
- Workplace labels require fewer elements and reference the SDS rather than repeating full hazard details (Correct answer)
- Both types require identical information and format
- Workplace labels require pictograms while supplier labels do not
Correct answer: Workplace labels require fewer elements and reference the SDS rather than repeating full hazard details
Workplace labels are simplified to three elements (product identifier, safe handling information, SDS reference) rather than the six required on supplier labels.
A worker pours a solvent from its original labeled drum into a small cup for immediate use during the same shift.
Under WHMIS, is a workplace label required on the cup?