WHMIS stands for Workplace Hazardous Materials Information System, and it’s Canada’s framework for communicating chemical hazards on the job. It covers three things: the labels suppliers put on products before they ship, the Safety Data Sheets that go along with those products, and the training workers need to understand both. First introduced in 1988 and significantly overhauled in 2015 to align with the UN’s Globally Harmonized System of chemical classification, WHMIS applies to nearly every Canadian workplace that stores, handles, or uses hazardous products. One part of that system deals specifically with what happens after a chemical leaves its original container, and that’s where secondary labeling comes in.

A secondary container, in WHMIS terms, is any container holding a hazardous product that isn’t the one it arrived in from the supplier. The moment you pour, scoop, or transfer a chemical out of its original packaging into a spray bottle, a smaller jug, or a mixing vessel, that new container needs its own label. This comes up constantly in manufacturing plants, cleaning operations, labs, and maintenance shops, anywhere a product gets decanted for use on the floor rather than used straight from the drum. WHMIS does allow an exception: if the person who transfers the product uses it entirely within their own shift and no one else handles it, a full workplace label isn’t strictly required, though the container still needs to be clearly identified. Once that product sits overnight, gets handed to a coworker, or spans more than one shift, a proper workplace label becomes mandatory.

What the Law Requires of Employers

The employer obligation comes from the legal framework behind WHMIS, built on the federal Hazardous Products Act and the Hazardous Products Regulations. Those two set the rules suppliers must follow when labeling products before they reach your workplace. Once a product arrives and gets transferred into another container, responsibility shifts to the employer, and that duty is spelled out under the definition of “workplace label” in the Hazardous Products Regulations. If your workplace falls under federal jurisdiction, the specific labeling obligation is laid out in the Canada Occupational Health and Safety Regulations, Part X, Division III, particularly section 10.35, which requires employers to apply a workplace label to containers they’ve filled themselves. Provincially regulated workplaces follow their own province’s OHS legislation, which mirrors these same requirements closely, so it’s worth checking your provincial regulation for the exact section number that applies to you. It’s also worth knowing that the Hazardous Products Regulations were amended in December 2022 to align with GHS Revision 7 and parts of Revision 8, and the transition period for suppliers to fully comply closed on December 14, 2025, so SDSs and supplier labels issued from that point forward should reflect the updated hazard classes.

How to Build a WHMIS Compliant Label Yourself

To build a WHMIS compliant label by hand, start by referencing the chemical’s current Safety Data Sheet. WHMIS requires three things on a workplace label. :

1. Copy the product identifier exactly as it appears on the SDS, without shortening or rewording.

2. Look at the hazard information on the SDS and translate it into something appropriate for your workplace, whether that’s a pictogram, a short phrase like “corrosive, wear gloves,” or a colour code your team already recognizes.

3. Add a line stating that a Safety Data Sheet is available for the product, even though the label itself doesn’t need to reproduce the SDS content.

Attach the label to the container in a spot that won’t get worn off by handling. Finally, check that the wording still matches what’s in the SDS binder or system employees can access, since the label works together with the SDS rather than replacing it.

How sdsLite Takes the Work Off Your Plate

Doing this by hand for every product in your inventory adds up fast, and that’s exactly where sdsLite comes in. Every chemical in your sdsLite SDS library comes with a WHMIS compliant Secondary Label ready to download, generated directly from the product identifier and hazard information already sitting in that chemical’s SDS. There’s no retyping product names by hand and no guessing at which hazard statement applies, since everything pulls straight from the source document. Select the chemical, download the label, and print it, all built from data that’s already accurate and ready if an inspector ever asks to see it.