Must the SDS be in French?

Someone wrote in to our company recently with a question. “I need to know if Canadian law states that the MSDS or SDS has to be in French if requested,” the writer asked. The answer is yes.

Ours is a software company, not an advice column (!) — so typically folks write to request a demonstration of the latest software for GHS, SDS or REACH or supplier management. That kind of thing.

We don’t often get a straight up regulations question like this one.  But why not answer it?  It’s always good to check back over basics, when “the basics” change so often these days.

“Does Canadian law state that the MSDS or SDS have to be in French if requested?”

Yes, Canadian (M)SDS must have French versions  So the answer is yes, in Canada you are required to have English and French versions of the (M)SDS. In Europe, the SDS must be authored in the official language of the country where you are selling or plan to sell your product. This applies if you’re selling in Asia, too.

Online there is a great case study about SDS in a global market—how one company solved the problem of creating MSDS documents in local language, in the 11th hour no less. Very dramatic, but they made it happen. Actually, that case study won an award from IDG ComputerWorld for its “forward thinking” aspects—take a look.

WHMIS is Canada’s national hazard communication system  The prime objective of WHMIS is to provide relevant safety and health information to Canadian workers, the idea being, like most safety initiatives, to avert injury, illness and premature death. The key elements of WHMIS are cautionary labelling, MSDSs and worker education and training programs.

Labels The precautionary information, including hazard symbols, which must be disclosed on a WHMIS supplier label are prescribed in section 19 of the Controlled Products Regulation or CPR. The information must be disclosed in both English and French, and it must look nice, that is, it must be enclosed within a “hatched” border as depicted in Schedule III of the CPR.

Note: There are software solutions for GHS SDS management and authoring, in any language.

Also note: There is a website reference for all things WHMIS and GHS.  And this page is helpful: a FAQ.

The Canadian Hazardous Products Act is available online and may be of interest.  Hope this clarifies things.

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About Kal

Kal Kawar, CIH, PE, has a bachelor's in chemical engineering and a master's in industrial hygiene. His professional experience includes serving as staff industrial hygienist for IBM's New York semiconductor manufacturing facility, and as industrial hygienist for IBM’s US headquarters. Now executive vice president of Actio, Kal taps more than 20 years' worth of chemical engineering, industrial hygiene, and environmental engineering experience. His far-reaching expertise with global regulatory challenges created by EPA, TSCA, REACH, RoHS, WEEE – and hundreds of others – aid in developing Actio software solutions for MSDS management, raw material disclosure compliance, and product stewardship in a supply chain.