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Caveat: I've made the following information as useful and accurate as I can... but I won't be held responsible for your actions or inactions. YOU need to know the regulations which apply to you and the resources that you have available; use what I give you as a starting point. I've used my free time to create this page, and I'm offering it freely - remember that what you get may be worth what you paid for.

Hazard Communication - Table of Contents

  1. Canadian WHMIS Labels
  2. Material Safety Data Sheets (MSDS)
  3. US EPA RCRA Waste Codes
  4. Shipping Papers
  5. Sample Labels & Placards
  6. North American Emergency Response Guidebook (NAERG)

For further information consult the additional tables at the Hazard Communication Definitions page. The HazCom Definitions page also has my comments on how the regulations of various agencies interact.

Hazard Communication Overview

What is Hazard Communication?

"Hazard Communication" means communicating the hazards of a dangerous chemical to people who need to know, such as workers or emergency responders. It includes workplace right-to-know initiatives such as Canada's Workplace Hazardous Materials Information System (WHMIS) and the US Occupational Safety and Health Administration's Hazard Communication Standard. It also includes transportation initiatives such as the Canadian Transport of Dangerous Goods Act and Regulations, the US Hazardous Materials Regulations, and the North American Emergency Response Guidebook.

In the following sections I will discuss what I know of Hazard Communication issues in Canada and the US; I will also mention what I know of Mexico's Secretariat of Labour and Social Security's (STPS's) worker health and safety requirements. Please note that my knowledge of Mexico's regulations is limited: I have not taught there in several years, and Mexico has recently implemented many new transportation regulations as a result of agreements with Canada and the United States.

History of "Right-to-Know" Regulations

Hazard communication initiatives came from two sources. On Saturday, July 10th, 1976 a cloud of dioxin was released from a chemical plant in Seveso, Italy, near Milan, causing several thousand people to develop a skin disorder called chloracne and leading to long-term health problems. This lead to the European Economic Community's Seveso Directive. Then on the night of December 2, 1984, a Union Carbide pesticide plant in Bhopal, India released a plume of methyl isocyanate, killing over 2000 people. World-wide concern led to world-wide initiatives.

In the United States the Congress passed the Superfund Amendment and Reauthorization Act (SARA) and Emergency Planning and Community Right-Know Act (EPCRA). As part of SARA and EPCRA manufacturers had to publish MSDS, employers had to train workers, and businesses with toxic substances had to notify their local fire departments and Local Emergency Planning Committees of their emergency / contingency plans and of any exteremely hazardous substances on their sites.

In the meantime, industry was taking action to identify chemical hazards in the workplace. In Canada, the WHMIS regulations on Material Safety Data Sheets (MSDS) were implemented by the provinces based upon a federal program. This was the first program to lead to uniform nation-wide workplace regulations in that country. Similar initiatives in the US and other countries led to standardized Material Safety Data Sheets (MSDS).

Table 1: Canadian WHMIS Labels
Class A Class B
Compressed Gas Flammable / Combustible Material
Class C Class D Division 1
Oxidizing Material Poisonous Infectious Materials: Immediate & Serious Toxic Effects
Class D Division 2 Class D Division 3
Poisonous Infectious Materials: Other Toxic Effects Poisonous Infectious Materials: Biohazardous Infectious Material
Class E Class F
Corrosive Material Dangerously Reactive Material

Workplace Hazard Communication:

Hazard Communication / Workplace Hazardous Materials Information System (Right-to-Know / WHMIS / Material Safety Data Sheets)

Wherever you are in the U.S., Canada or Mexico some type of Safety Data Sheet is used for workplace controlled products / hazardous chemicals. In Canada, this program is regulated through the Workplace Hazardous Materials Information System (WHMIS); in the US, through OSHA's Hazard Communication/"Right to Know" regulations. In Mexico a similar program is administered by the Secretariat of Labour and Social Security (STPS). Of course MSD sheets are not available for everything--for example, hazardous wastes do not require MSDS in Canada or the US, nor do consumer products. A good Right-to-Know / WHMIS program will include:
  • Worker training on the program;
  • Appropriate labels for workplace hazardous chemicals;
  • A list or inventory of all hazardous chemicals in the workplace;
  • Material Safety Data Sheets that describe the hazards of those chemicals.
Note that unlike Canada, the US does not use a cross-hatched border on the item's container to indicate which products require MSDS. The US also does not use the Canadian labels or the three-year limit on MSDS age.
Table 2: Material Safety Data Sheets
[MSDS page 1]

[MSDS page 2]

Environmental Safety

Materials Without MSDS: Dangerous / Hazardous Wastes

In the US and Canada some materials do not require Material Safety Data Sheets. Also many substances pose a threat to public health and the environment as well as to workers. Even though these substances may not have MSDS, there is normally other information available. For example, there may be pesticide markings or PCB markings.

Of particular interest are dangerous or hazardous wastes. When an MSDS is not available a worker or responder can look for other information, such as information from a remediation/clean-up site characterization, or a waste "profile" for disposal. Wastes from US Superfund sites must be characterized, and are regulated under the Comprehensive Environmental Response, Compensation and Liabiliy Act (CERCLA) and the Superfund Amendment and Reauthoriztion Act (SARA). Shipping papers may also provide needed information on the hazards in a waste.

Other information may be available for toxic and hazardous wastes in the US. Asbestos and Polychlorinated biphenyl (PCB) wastes are regulated by the Toxic Substance Control Act (TSCA), which gives specific waste definitions. Hazardous wastes are regulated under the Resource Conservation and Recovery Act (RCRA), which also uses strict definitions. RCRA hazardous wastes use "waste codes." These codes are based on EPA lists and descriptions of characteristics. Several waste codes may apply to the same waste if it is covered by more than one category. See the RCRA Waste Code table for more information.

Table 3: US RCRA Waste Codes
Waste Code Description
D001 Ignitable Waste. Waste has a flash point below 140 F (60C), or is an oxidizer that will ignite flammable materials.
D002 Corrosive Waste. Waste either corrode metal or has a pH below 2 (acid wastes) or above 12.5 (caustic, alkaline, or basic wastes). Unlike WHMIS, OSHA, Canadian TDG and US DOT HMR definitions for corrosives, wastes must be liquids to have the corrosivity characteristic.
D003 Reactive Waste. Waste may undergo violent changes, react with water or other wastes, generate toxic gases, vapors, or fumes. Cyanide or sulfide wastes that may generate toxic gases at pHs between 2 and 12.5 fall into this category.
D004 - D043 Specific wastes listed for their toxicity (e.g., D008, lead).
F-listed wastes Wastes from generic sources, such as spent chlorinated or halogenated solvents.
K-listed wastes Wastes from specific sources (e.g., K051, API separator sludge from the petroleum refining industry).
P-listed wastes Commercial chemical products, containers, or spill residue with unspent waste with acute (short term) toxicity (e.g., P098, Potassium cyanide.
U-listed wastes Commercial chemical products, containers, or spill residue with unspent waste with chronic (long term) toxicity (e.g., U151, Mercury).

Transportation Hazard Communication:

Shipping Papers

People who work with shipping dangerous goods / hazardous materials may need to quickly identify the hazard with which they work. Emergency responders may also need to identify dangerous cargo as quickly as possible. Some industries use industry- wide ways of describing cargos, such as the American Association of Railroads' Standard Transport Commodity Codes (STCC).

Unfortunately, these common practices don't help responders from outside that industry. To ensure that workers and responders can easily identify dangerous goods or hazardous materials, shipments of these materials use standard names and other nomenclature as well as easily identifiable placards and labels. These names and information are put on shipping papers, such as Bills of Lading and US Uniformed Hazardous Waste Manifests.
Table 4: Shipping Papers
Highway Bill of Lading (non-wastes/non-reg wastes) / Dangerous Goods Waste Manifest / US Uniform Hazardous Waste Manifest (dangerous / hazardous wastes) Vehicle driver
Rail Rail Bill of Lading / Waybill Crew
Water Dangerous Cargo Manifest Captain
Air Air Bill with Shipper's Certification for Restricted Articles Pilot


There are many, many potentially hazardous chemicals in transport - too many to easily describe without grouping similar chemicals together. To make life easier for emergency responders, each of the three North America countries has identified dangerous good / hazardous material shipping names, hazard classes, and product identification numbers. These shipping names, hazard classes, and identification numbers are based on international agreements. They are written as Shipping Name, Hazard Class, Product Identification Number (PIN), and Packing Group. For example: "Waste Acetone solution, Class 3, UN 1090, Packing Group II." As a mnemonic (memory tool), Just think "SHIP."

In Canada these names and numbers are regulated by the Transport of Dangerous Goods Act and Regulations (TDGA / TDGR) and administered by Transport Canada. They are found in Schedule II, List I and II of the TDGR. As a rule, almost all of the names parallel the US names, because they come from the same international agreements. As an exception to this rule the "Waste Type" names parallel US EPA hazardous waste codes (e.g., both Canadian "Waste Type 77, Class 3, NA 9377, PG II" and the US EPA waste code K051 are "API separator sludge from the petroleum refining industry").

In the US these names and numbers are mandated by the Hazardous Materials Regulations and administered by the Office of Hazardous Materials of the US Department of Transportation's (US DOT) Research and Special Projects Administration (RSPA). They are found in Part 172.101 of Title 49 of the US Code of Federal Regulations (49 CFR 172.101).

Dangerous Goods / Hazardous Materials Placards and Labels

Along with the designated SHIP information, Mexico, Canada and the US all use container labels and vehicle or bulk-container placards to note the presence of hazardous materials. These are the diamond-shaped markings on small containers like drums (labels) and on vehicles (placards). The shape and color are also based on international standards. Take one example: Flammable Liquid, n.o.s. (a technical name), Class 3, UN1993, Packing Group (I, II, or III) is a standard name tied into the Emergency Response Guides / Guidebooks used in North America; the red-shaped Flammable Liquid label or placard is likewise a standard. Labels go on non-bulk containers like drums. Placards go on bulk containers such as vehicles.
Table 5: Sample Labels & Placards
Class 3, Flammable Liquids Placard] [Class 3]

North American Emergency Response Guidebook

In 1996 Canada, the US, and Mexico published a joint North American Emergency Response Guidebook that replaced the Canadian CANUTEC Dangerous Goods Initial Emergency Response Guide and the US Department of Transportation Emergency Response Guidebook. While this guide did not include basic container recognition (the graphics on the accompanying HazMat Transport page are partly based on the old Canadian CANUTEC guidebook and my experience), it did combine the best of the Canadian guidebook's response pages with the Initial Isolation and Protective Distances charts for Poison by Inhalation Hazards (PIHs).

Table 6: NAERG

Other Resources:

If you need more information, I recommend that you try the following sources:

HazMat Resources
[Drums] [North America] [Canada] [USA] [Mexico] [Private Sector] [Drums]
Hazard Communication Joint N. America Effort Canadian Agencies USA Agencies Mexican Agencies Private Sector Organizations HazMat Page

The above is copyright 10 May 1997, by Earle B. 'Glas' Durboraw.

This page, of course, does not represent my employer's views--just my own! I work with Safety-Kleen (ex-Laidlaw Environmental Services), and I've been dealing with aspects of chemical response since 1982, when I graduated from Hardin-Simmons University and was commissioned in the U.S. Army's Chemical Corps. I spent a very enjoyable decade on active duty before volunteering for President Bush's Drawdown bonus. I am also a Certified Environmental Trainer through the National Environmental Training Association, was a member of the National Fire Protection Association, and a professional member of the American Society of Safety Engineers.

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