WHAT are Compliance Labels?
When affixed, WHMIS compliance labels allow labs to legally store and use hazardous chemicals that have old supplier labels (i.e., do not have a WHMIS 2015 supplier label).
WHERE can I get Compliance Labels?
Compliance labels are provided by the University of Toronto Department of Environmental Health and Safety (EHS) free of charge. Labels are now only available in one size: 35 mm x 19 mm. You can request labels for your lab by emailing the WHMIS Compliance Officer. Extra compliance labels will be collected at the time of your lab’s next WHMIS Compliance Inspection.
WHEN should I use Compliance Labels?
Compliance labels should be affixed to the original container of all hazardous chemicals that have old supplier labels. Chemicals that have a new WHMIS supplier label, non-hazardous chemicals (e.g., phosphate buffered saline, glucose, etc.) and chemicals that have a consumer label (e.g., Javex, WD-40, etc.) do not require compliance labeling.
Old supplier labels may have circular symbols, square symbols, other symbols, hazard statements in words, or no information at all. If in doubt, check the Safety Data Sheet (SDS) to determine whether a chemical is hazardous. You must affix a compliance label to hazardous chemicals with old supplier labels in order to legally store and use these chemicals.
All hazardous chemicals with old supplier labels must be affixed with compliance labels prior to your lab’s next WHMIS Compliance Inspection.
WHY do we have to use Compliance Labels?
As originally written, the WHMIS 2015 legislation did not allow for the storage or use of chemicals with old supplier labels. All old hazardous chemicals would need to be disposed of and re-purchased. It was estimated that this would cost UofT investigators a combined total of ~$90 million. Successful lobbying of government officials by UofT EHS staff resulted in two amendments to R.R.O. 1990, Reg. 860, which allow the storage and use of hazardous chemicals with old supplier labels as long as a compliance label is affixed to the chemical.