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8. WHMIS and the Transportation of Dangerous Goods: A Comparison

  • ISBN: 978-1-4249-6996-8
  • Revised: August 2008
  • Content last reviewed: June 2009

This guideline is being updated to reflect changes that take effect July 1, 2016 as amendments to the WHMIS regulation, Regulation 860, come into force.

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:

  1. the exemption from WHMIS for products that are handled or transported pursuant to TDG legislation;
  2. the classification of products under WHMIS and TDG; and
  3. the colour restrictions for WHMIS hazard symbols to avoid confusion with TDG safety marks.

WHMIS Exemption for Products Covered by TDG

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.

  • "Handling and offering for transport" refer to activities such as assembling, packaging, storing, loading and unloading for transport. For example, WHMIS does not apply to products that are in temporary storage in a distribution warehouse, that is, in a warehouse that is operated solely as a trans-shipment point.
  • "Storing for transport" is storage in which goods will not be handled any further at the workplace other than to load them directly onto a transport vehicle for the purposes of removal from the workplace.
  • "Transportation" generally means to and from workplaces. WHMIS applies to all circumstances where goods are transported from one point to another within a workplace, except for radioactive substances and explosives, in which case TDG applies.

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.

Controlled Products Not Covered by TDG

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.

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