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.

Implementing An Environmental Management System

An environmental management system (EMS) keeps companies competitive and helps improve environmental performance by assuring regulatory compliance, reducing operating costs, and increasing awareness of the environmental impact of the company’s activities. Any company that handles chemicals or multiple MSDS-worthy products should have an EMS Plan in place. Manufacturers find an EMS most urgent, but almost every business can benefit.

Planning. Before you implement the EMS, decide where the EMS will apply within your organization. Choose your environmental management representative (EMR), who acts as the project manager for the EMS. Select a team of experts, consisting of facility and city representatives. Build an implementation team of personnel from the “shop floor,” ensuring adherence to the EMS at all levels of your organization.

During the planning phase of your company’s EMS, you must define the environmental aspects and impacts. An environmental aspect includes activities, products, or services that interact with the environment (i.e., air emissions, energy usage). An environmental impact includes any change to the environment resulting from activities, products, or services (i.e., air quality changes, natural resource usage).

It’s also important to identify legal requirements and issues related to your company with regard to regulations and compliance issues.

Once you’ve completed your planning, you can develop the environmental policy, consisting of regulatory compliance, pollution control, and a continual improvement program. Your EMS should also include an environmental objective (i.e., reduce energy usage) and environmental target (i.e., reduce energy usage by a specific date). You should figure out who’s responsible for each objective and target, what resources are available (i.e., personnel, financial), and when milestones will be achieved.

Documentation and training. Determine which operational procedures require documentation, and locate documentation related to environmental aspects that may already exist. Work with personnel to develop new documentation, and don’t forget to include health and safety requirements.

Your environmental aspect list also helps you to identify your training needs. All employees should be trained in:

·        Environmental policy
·        EMS roles and responsibilities
·        Procedures and work instructions
·        Consequences of not following EMS requirements

Your company’s EMS must detail how to communicate internally, as well as how to request, obtain, document, and respond to external communication. Communication can include items such as your environmental policy, legal requirements, and objectives.

Preparing for emergencies. Part of the EMS should focus on how to prepare for emergencies, such as spills, and should identify which procedures already exist to help you properly respond to the situation.

Evaluating your progress. It’s important to periodically assess your EMS to see how much progress it’s making toward your environmental objectives and targets. Based on the following, determine whether the EMS was carried out according to plan:

·        Have you identified what to monitor?
·        Have you chosen the indicators/metrics?
·        Did you establish a schedule for monitoring?
·        Did you document the process?
·        Have you communicated the information?

Auditing your EMS. Internal EMS audits review how well your company is meeting its objectives and targets by evaluating your procedures, documentation, programs, and implementation. The audit also determines whether your company is continually improving.

·        Prepare for the audit with planning, resource allocation, and determining audit objectives
·        Examine documents and records; identify conditions that require immediate action
·        Prepare and submit the report to management

Management action items. Management personnel decide whether the EMS is working efficiently, and whether changes or improvements are needed. Management should review the EMS process, determine what to evaluate, document the process, and record the outcome of the review.

More information. The Public Entity EMS Resource (PEER) Center ( offers tips on developing an EMS for your company — a good reference.

Guest blogger Laura Chidester has worked as a technical journalist for over 10 years.  By day she manages the documentation team at Actio Software Corp. while continuing to report on broader industry and environmental trends.