Supplier Labels vs Workplace Labels: WHMIS Rules (Canada)

One label arrives on the container. The other one is your job to make. Here is how to tell them apart, and when the law says you have to write a new one.

Who is responsible for which label

WHMIS splits label duties between two different levels of government, and that is the root of most of the confusion.

The federal Hazardous Products Act and Hazardous Products Regulations govern suppliers. If a company manufactures, imports, or sells a hazardous product in Canada, it must correctly classify the product and affix a compliant supplier label before it goes out the door.

Your province or territory governs employers. Once the product arrives at your workplace, provincial occupational health and safety law takes over. The employer has to make sure every hazardous product on site carries a proper label, and create a workplace label whenever the supplier label cannot do the job.

So the drum arrives labelled by the supplier. What happens the moment somebody pours it into a spray bottle? That is where the second label comes in, and the required contents are surprisingly short.

What a supplier label must contain?

A supplier label is the detailed one. Under the federal regulations, it carries 6 information elements:

• Product identifier. The brand name, chemical name, or trade name of the product.
• Initial supplier identifier. The name, address, and phone number of the Canadian manufacturer or importer.
• Hazard pictograms. The GHS symbols inside a red diamond border.
• Signal word. Either Danger or Warning, depending on severity.
• Hazard statements. Standard wording that names the hazard, such as fatal if swallowed.
• Precautionary statements. Plain instructions for handling, storage, first aid, and disposal.

The regulations also control the layout. The pictograms, signal word, and hazard statements must be grouped, and the whole label must stand out from any other printing on the container, remain legible, and remain attached under normal use.

If you want to know how the pictograms themselves work, our guide to WHMIS pictograms covers each symbol and what it warns you about.

What a workplace label must contain?

A workplace label is far simpler. It needs only 3 elements:

1. Product identifier that exactly matches the name on the safety data sheet.
2. Safe handling information written in a way that suits your workplace.
3. A reference to the safety data sheet, telling workers an SDS is available.

That is it: no supplier address, no signal word, no pictograms required. Alberta's OHS Code refers to this as a work site label rather than a workplace label, but the three required parts are the same.

Nothing stops an employer from adding more. Copying the pictograms and hazard statements onto a workplace label is allowed and is good practice. The three elements are the floor, not the ceiling.

So when does that floor actually apply? There are three moments, and one of them happens in almost every workplace I walk into.

The 3 times you need a workplace label.

1. You pour the product into another container

This is called decanting, and it is the one that catches people. The moment a product leaves the container it arrived in, the new container needs a workplace label. In BC, WorkSafeBC's regulation states this directly. If a hazardous product is in a container other than the one it was received in, the employer must ensure that container has a workplace label on it.

Spray bottles of sanitizer and degreaser are the number-one things I see unlabelled in commercial kitchens. Somebody fills a bottle in the morning, sets it on a shelf, and by dinner service nobody remembers what is in it. Blank bottles and a marker beside the dispenser fix it in seconds.

2. Your workplace produces the product

If the employer makes a hazardous product on-site, that product requires a workplace label before anyone uses it. Mixing something in-house does not exempt it from WHMIS.

3. The supplier label is damaged or gone

If the original label becomes unreadable, peels off, or gets covered with product, the employer must replace it. In BC and in Alberta, the rule is the same in substance: replace it with either a new supplier label or a workplace label. Alberta's OHS Code says this must happen immediately.

"The unlabelled spray bottle is the most common WHMIS problem in food service, and it is also the cheapest one to fix. A pack of blank labels costs less than lunch. Not having them has cost people their eyesight."

Samira AliCertified Public Health Inspector, 10+ years across Canada and the U.S.

When no label is needed at all

The law does not expect a printed sticker on every cup of cleaner. In BC, WorkSafeBC's regulation sets out two exceptions for a portable container filled from a properly labelled one.

• Immediate use. All of the product is needed and used right away.
• One worker, one shift. The product remains under the control of the worker who filled the container, is used only by that worker, only during that shift, and the contents are still clearly identified.

Read that second one carefully, because every condition has to hold. The moment you set the bottle down, walk away, hand it to a coworker, or leave it for the next shift, the exception is gone, and a workplace label is required.

Here is the training scenario I use to make it stick. A mechanic decants brake cleaner into a spray bottle for a morning job and skips the label, planning to finish it before lunch. He gets called away, the bottle stays on a shared bench, and a coworker picks it up assuming it is water. Nobody broke the rule at the moment of pouring. It broke the second the bottle was left behind.

Language is the next thing people get wrong, and the answer varies by label type.

The English and French rule

Supplier labels must be in both official languages. The federal regulations require that the information elements appear in English and French, either on a single bilingual label or as two unilingual parts that together form a single bilingual label.

Workplace labels are different. Provincial regulations do not set a bilingual requirement for them. Instead, the safe handling information has to be conveyed in a manner appropriate to the workplace, which means the language your workers actually read. If your kitchen crew works in Punjabi and Spanish, a label they cannot read does not meet the rule's intent, even if it is in perfect English.

Pipes, tanks, and bulk shipments

Not every hazardous product sits in a bottle on a shelf. The rules bend for industrial setups.

• Piping systems, reaction vessels, and conveyors. These do not get standard labels. In BC and Alberta, the employer instead identifies the contents using colour coding, placards, labels, or another effective method, backed by worker training.
• Bulk shipments arriving without a supplier label. Where a federal exemption means no supplier label was applied, BC's regulation requires the employer to apply a label carrying the supplier label information once it is in the workplace.
• Storage tanks. The federal definition of a container excludes storage tanks, so they fall under the provincial rules for piping and vessels rather than sticker labels.
• Placards. Where a placard replaces a label, it must be large enough and placed where workers can actually see and read it.

Labels that fall off or arrive missing

Two situations, two answers.

The label came off or became unreadable. Replace it right away with a supplier label or a workplace label. Alberta's OHS Code uses the word immediately. Do not wait for a reorder, and do not let anyone use the product in the meantime.

The product arrived with no compliant supplier label. In BC, where an employer imports or receives a hazardous product without a compliant supplier label, the employer must affix a workplace label that meets federal requirements before the product is used.

And when an inspector visits, labels are one of the first things checked. CCOHS notes that inspectors check whether products arrive from suppliers with the required labels and safety data sheets, and employers should be ready to show that hazardous products on site are properly labelled. In practice, they will also open a few spray-bottle-worth of questions with your staff.

Every one of those questions is answerable if your team has done WHMIS training. The general education part teaches labels, pictograms, and how to read a safety data sheet. Your employer then adds the site-specific part for the exact products you handle. If you need the general certificate, our online WHMIS course covers it all, and the complete guide to WHMIS in Canada explains how the whole system fits together.