Supplier labels

The supplier label is the first line of hazard communication. It is attached by the supplier to every container of a hazardous product sold or imported for use in Canadian workplaces, and it gives the essential hazard information and precautions in a standard format. Workers often see the supplier label more than any other source of information, so understanding its content, knowing what to do if it is missing or damaged, and knowing the special rules for small containers and other situations is essential. This lesson covers the required elements of supplier labels, their layout, bilingual requirements, small containers, laboratory products and samples, labelling of bulk shipments, label maintenance and updates when new information becomes available.

Required label elements

Under the Hazardous Products Regulations, a supplier label must include:

• Product identifier: the name or code of the product, matching the product identifier on the SDS.
• Initial supplier identifier: the name, address and telephone number of the Canadian manufacturer or importer (with some exceptions for distributors who sell products under their own name).
• Pictograms for each applicable hazard, subject to precedence rules.
• Signal word: Danger or Warning, where applicable.
• Hazard statements for each hazard class and category.
• Precautionary statements for prevention, response, storage and disposal.
• Supplemental label information where required, such as the percentage of ingredients with unknown acute toxicity, a statement for products that may form combustible dust, or other information specified by the HPR.

All elements must be grouped together on the label, easy to read and clearly visible, in both English and French. Labels must be durable enough to remain legible under normal conditions of use. The HPR no longer requires the distinctive hatched border used by WHMIS 1988 labels, but suppliers may use a border.

Reading a label in seconds

A practical habit when you pick up a container is to read the label in a consistent order: product identifier (is this the product I expect?), pictograms and signal word (what kinds of hazard, and how serious?), hazard statements (what exactly can it do?), and precautionary statements (what must I do to work safely and what should I do if something goes wrong?). For more detail, such as the type of gloves or the exposure limits, go to the SDS. If anything on the label is unclear, ask before using the product.

Small containers

Some containers are too small for a full label. Under section 5.4 of the HPR, a hazardous product in a container of 100 mL or less is exempt from the requirement to show hazard statements and precautionary statements on the label, although the other elements, such as the product identifier, initial supplier identifier, pictograms and signal word, are still required, and the full information remains on the SDS. For containers of 3 mL or less, if a label would interfere with normal use of the product, the label may be one that is removable rather than permanently durable. Health Canada guidance explains the conditions in detail, and suppliers often place full labels on outer packaging as well.

Laboratory products and samples

Products sold by a laboratory supply house for use in laboratories, in quantities under 10 kg, may use a modified label in some circumstances, and samples for analysis or testing that are not otherwise available, such as samples sent to a laboratory, have special labelling options. Hazardous products imported for use in the importer's own workplace, and products in bulk shipments, also have specific rules: for bulk shipments, the label information may be provided in another form, such as on the shipping documents, as long as it is accessible to workers. Products transported under TDG rules must still meet WHMIS labelling once they reach the workplace.

Label maintenance and replacement

Labels must stay legible and attached for as long as the product remains in the container. Chemicals, abrasion, weather, heat and age can damage labels. Workers should report damaged, illegible or missing labels immediately, and should never use a product from a container they cannot identify with certainty. Employers must replace damaged supplier labels with a new supplier label or, depending on the jurisdiction and situation, a workplace label. Removing, defacing or covering a supplier label is not permitted while the product is in the container. When a container is emptied and will be reused for something else, old labels must be removed or completely covered and the container properly cleaned.

Updating labels when new information appears

When a supplier becomes aware of significant new data, information that changes the classification of a product or the way to protect against its hazards, it must update the label within 180 days and, until then, give purchasers the new information in writing. Employers receiving updated labels should replace old ones and update workplace labels and training as needed.

Supplier labels and other marks

Containers may carry other marks in addition to the hazard communication label: transport labels and placards, consumer product labels, pesticide labels, manufacturer instructions and logos. These do not replace the required label, but they can provide additional information. Transport placards on trucks and tanks identify hazards for emergency responders using UN numbers and classes, which differ from the workplace system: for example, a transport flammable liquid label uses a red diamond with a flame and the number 3. Workers should not confuse transport classes with workplace hazard categories.

Common label problems

Real labels are not always perfect. Problems you may encounter include labels that are faded, torn or soaked with product; labels in only one language where two are required; labels from another country that do not meet local requirements; labels that do not match the SDS, for example with different pictograms or product names; labels that have been partly covered by tape, price stickers or other labels; and old labels with outdated symbols. In each case, report the problem. Supervisors should contact the supplier for a correct label or SDS, and in the meantime ensure the product is identified with a workplace label as permitted and that workers know its hazards.

Imported and online purchases

Products bought online, imported directly from overseas or obtained from small suppliers are more likely to arrive without compliant labels and SDSs. Some may carry labels designed for another country, consumer labels when the product will be used at work, or no hazard information at all. Organizations should route all purchases of hazardous products through a process that checks for compliant labels and SDSs before the product is used. If a product cannot be supplied with proper hazard information, consider whether it should be used at all.

Labels and the receiving process

The receiving area is the first chance to catch labelling problems. When hazardous products arrive, receivers should check that containers are undamaged and not leaking, that each container carries a legible label, that the product matches the order and the SDS on file, and that a current SDS is available. Damaged or leaking containers should be isolated and handled according to the spill procedure. Records of receipt help maintain the chemical inventory. Simple checklists at receiving desks make these checks routine.

Label design for clarity

While suppliers must include the required elements, good label design makes the information easier to use: grouping pictograms, signal word and hazard statements together near the top; using clear, large type; keeping supplementary marketing text separate; and avoiding clutter. Employers who design workplace labels can apply the same principles, with large product names, clear pictograms and a few key precautions rather than long blocks of small text.

Practice: checking a label

Try this exercise with a real container at your workplace. Find the product identifier and check that it matches the SDS on file. Identify each pictogram and say what hazard it represents. Note the signal word. Read each hazard statement and put it in your own words. Read the precautionary statements and list what you should do before, during and after using the product, and in an emergency. Find the supplier's contact information. Finally, check whether the label is in good condition and in the required language. Doing this for the products you use most often turns label reading into a quick habit.

Labels on containers you receive from other workplaces

Products sometimes arrive from other company sites, contractors or customers, rather than from a supplier. These may carry workplace labels rather than supplier labels, or no label at all. Treat such products carefully: confirm their identity and obtain the SDS before use, and apply proper labels. The same applies to samples, returned products and products left behind by previous occupants of a building.

When labels conflict with experience

Experienced workers sometimes feel that a label overstates the hazard of a product they have used for years without problems. But many chemical effects, such as sensitization and chronic organ damage, appear only after long exposure, and incidents can happen the first time conditions change, such as higher temperatures, a confined space or mixing with another product. Labels reflect the best available evidence. If you believe a label is wrong, raise it, but follow it until it is reviewed.

Labels and people with limited literacy or vision

Some workers have limited literacy, read the label language as a second language, or have visual impairments. Pictograms help, but they are not enough on their own, since many people misinterpret some symbols. Employers can support these workers with training that uses real containers and demonstrations, translated summaries, larger-print workplace labels, colour and position cues used consistently, and buddy systems for unfamiliar products. The goal is that every worker can identify the hazards of every product they use.

Labels and storage temperature

Labels and SDSs sometimes specify storage temperature limits, such as "Store below 30 °C" or "Protect from freezing". Exceeding these limits can change a product's behaviour: some products degrade, separate or become more hazardous, and pressurized containers can rupture. Check labels when storing products in unheated buildings, vehicles or outdoor areas.

Labels and secondary hazards

A label lists all the classified hazards of a product, but users sometimes focus only on the first pictogram they see. A solvent may carry the flame pictogram most prominently while also carrying the health hazard pictogram for aspiration or organ toxicity. Read every pictogram and every hazard statement, not just the first.