The requirements under WHMIS (Workplace Hazardous Materials Information System) and under the TDG (Transportation of Dangerous Goods) legislation are for complementary information systems. TDG legislation sets out information requirements for products being shipped to and from workplaces. WHMIS applies to products inside workplaces. No overlap is intended. One system takes over where the other leaves off.
Worker exposure to dangerous goods that are in transit is most likely to occur during an emergency such as a vehicle accident or spill. Therefore, information provided under TDG requirements addresses short-term exposures and uses symbols on labels and placards.
Worker exposure to controlled products in the workplace can occur in a wider variety of circumstances and over longer periods of time. WHMIS requirements are more extensive than TDG and include the use of explicit labels and material safety data sheets.
This chapter provides information on 3 areas:
The WHMIS legislation does not apply to products being "handled or transported" under TDG legislation. The following interpretations are given in order to clarify when TDG requirements apply.
In general, the exemption for products being transported means that an employer in the transport industry does not have to provide WHMIS labels, material safety data sheets or education to drivers of vehicles transporting controlled products. An exception arises if a driver is exposed to a controlled product by being actively involved in its loading or unloading, for example, while filling an oil or gasoline tanker truck. In such cases, a driver should have access to a data sheet at the point of loading or unloading, and should undergo training.
It is possible to have a product that is covered by WHMIS but not TDG. This will likely be the case for controlled products in WHMIS Class D, Division 2 - Materials Causing Other Toxic Effects. There may be some confusion about the requirements that apply to these products while they are in temporary storage in a distribution warehouse. At present, it is the policy of the regulators that a WHMIS label on the outside of a container is all that is necessary for in-transit storage of controlled products not requiring a TDG label.