Ontario WHMIS: Update a Supplier SDS After Significant New Data

September 29, 2026·13 min read

A supplier emails a new warning about a solvent already used on the shop floor. The current safety data sheet is still in the workplace library. Workers can find it, but it does not describe the new hazard or the changed way to protect against it. A supervisor may assume the update can wait until the next annual document review. Ontario's WHMIS rules ask a more specific question: is the information significant new data, and has the workplace's supplier safety data sheet been updated as soon as practicable?

This guide is for an Ontario employer dealing with a hazardous product received from a supplier. It covers the decision from first notice through updated workplace information and a traceable follow-up. The Ontario WHMIS Regulation 860 is the legal source. The Ontario ministry's WHMIS employer guide explains the duties. The general Complys Canadian WHMIS overview covers labels, safety data sheets and training more broadly. This page owns the narrower new hazard data and supplier SDS update task.

Do not apply an Ontario rule to every Canadian workplace. WHMIS combines federal supplier requirements with employer duties under provincial, territorial and federal workplace regimes. This article describes Ontario's employer rule. A business operating in another province or in a federally regulated workplace should check the law that applies there before transferring the steps below.

What counts as significant new data?

Ontario Regulation 860, section 1 defines significant new data by its effect on the hazard information. It is new data about the hazard presented by a hazardous product that changes the product's classification within a category or subcategory of a hazard class, causes classification in another hazard class, or changes the ways to protect against the hazard. A spelling correction or a new supplier logo does not automatically meet that definition. A change to protective measures might.

The definition makes the substance of the information more important than the filename. A supplier could send a replacement safety data sheet, a written notice or other reliable information. Ask what changed in classification, exposure or protective measures. If the notice is unclear, obtain clarification from the supplier rather than deciding from the document's date alone. Do not infer that every newer SDS creates the legal significant-new-data trigger, and do not ignore significant data merely because the supplier has not yet issued a polished replacement document.

For a practical first pass, compare the information against the current workplace copy of the safety data sheet. Look for changed hazard classes or categories and changed instructions on safe handling, exposure protection, storage, first aid or emergency response. That comparison is a screening method, not a substitute for the statutory definition. A technically qualified person may need to resolve an ambiguous classification or protection question. The blog does not make that determination for a particular chemical.

The identity check matters too. Confirm the product identifier, formulation and supplier. A warning about a similar product is not automatically applicable to the material used at the workplace. Conversely, a business should not dismiss a notice because it uses a manufacturer's name while the local team uses an internal stock code. Match the notice to the actual container and existing SDS before deciding what must change.

The Ontario duty for a supplier SDS

Section 17, subsection 1 of Regulation 860 addresses an employer receiving a hazardous product from a supplier for use, storage or handling at a workplace. It requires the employer to obtain the supplier safety data sheet unless a federal supplier exemption applies. Subsection 2 requires the employer to update the supplier SDS obtained under subsection 1 as soon as practicable after significant new data is provided by the supplier or otherwise becomes available to the employer.

The second trigger is important. An employer should not use “the supplier has not sent us a revised PDF” as an automatic reason to leave the workplace information unchanged after reliable significant data becomes available in another way. The duty is framed around the availability of the data. Ask the supplier for a current SDS, keep the provenance of the new information clear, and make sure the workplace's active safety information reflects it as soon as practicable. The method of updating the workplace copy should preserve what came from the supplier and what the employer added or changed.

“As soon as practicable” is not a fixed number of days supplied by section 17. It calls for action in the real circumstances, particularly where the new information changes worker protection. A team should not invent a blanket 90-day period for supplier SDS updates. Document when the information arrived, when it was assessed and when the active workplace version changed. If the update cannot be completed immediately, record the reason and the temporary way affected workers receive the new information. That record helps explain the timing, but it does not convert an unjustified delay into compliance.

The ministry guide explains the supplier SDS update duty and the meaning of significant new data. It also notes that federal rules governing suppliers and provincial rules governing employers have different roles. This article relies on the Ontario regulation for the employer's legal obligation and uses the guide for explanation. The guide does not add a universal annual replacement deadline.

Do not confuse the separate 90-day rule

Ontario section 18, subsection 3 has a different duty for a safety data sheet prepared by an employer for a hazardous product the employer produces at the workplace. That SDS must be updated as soon as practicable, but not later than 90 days after significant new data becomes available. This is not the rule to quote without qualification when the product was received from a supplier and its supplier SDS is being updated under section 17.

Start by asking where the product and the safety data sheet came from. A supplier-provided product and an employer-produced product may sit in the same SDS library, but the cited sections are not interchangeable. The 90-day limit in section 18 is an outer limit for the specified employer-prepared SDS. It is not an instruction to wait 90 days when action is practicable sooner. Nor is it a general statement that every SDS in Ontario is valid for 90 days after any change.

This distinction matters in shared workplaces and laboratories where products can be both purchased and produced. Keep the source of each sheet clear. If a special exception or a different kind of product is involved, check the application provisions in Regulation 860 and the actual facts. The law includes scope and exemption provisions; a blog cannot classify a particular product solely from its trade name.

Update relevant supplier-label information too

An SDS is not the only place new hazard information may have to appear. Regulation 860, section 8, subsection 5 says that, if an employer receives significant new data from a supplier about a hazardous product, the employer must, as soon as practicable, attach new information reflecting that data to every relevant supplier label required under that section.

The source condition deserves attention. Section 17 can be engaged when data is supplied or otherwise becomes available. Section 8, subsection 5 speaks specifically to significant new data received from a supplier. Do not erase that distinction in a generic instruction to relabel every container after any rumour of a change. Equally, if the supplier sends significant new data, an updated SDS library alone does not address the relevant supplier-label duty.

Identify which products and containers have relevant supplier labels at the workplace. Check whether the attached information reflects the new data and is legible where workers will see it. Keep a record of what was attached and to which stock. A batch already in a storeroom may be missed if the process checks only new deliveries. If the supplier has issued replacement labels or further instructions, compare them with the active containers and the employer's legal duties.

This page does not reproduce the full Ontario labelling regime. A different completed draft addresses workplace labels on decanted containers. The new-data question here concerns the supplier-label update in section 8, subsection 5. An employer should separately review any workplace labels and worker instructions affected by the changed hazard information, without claiming that this subsection alone prescribes every such change.

Make the revised information available to workers

The updated SDS must be reachable by the people who may need it. The Ontario Occupational Health and Safety Act, section 38 addresses access to current safety data sheets. The ministry's WHMIS guide explains that current copies must be available to all workers and readily available to those who may be exposed to the hazardous product. A night-shift worker should not have to ask a daytime manager for access to the only current version.

Replace or clearly supersede the active copy in each workplace access point. A digital library may still expose an old file through a saved link or a downloaded copy. A paper binder may have a revised sheet at the front and the superseded one behind it without clear marking. Test the route a worker actually uses. Search for the product by the name on the container, open the current sheet and check that its revision and hazard information match the approved update.

Ontario Regulation 860, section 6 also requires an employer to ensure that a worker who works with or may be exposed to a supplier-provided hazardous product is informed about hazard information received from the supplier and further hazard information of which the employer is or ought to be aware. A changed SDS is therefore a prompt to consider what affected workers must be told. Placing a file in a folder is not the whole communication task if the protective measures used on the job have changed.

Identify the workers, supervisors, maintenance staff and contractors whose work may be affected. Explain what has changed in a form they can use, where the current SDS sits and whether work instructions or controls have changed. Check understanding where the new information alters a practical step. Keep the communication proportionate to the change. A new hazard classification with no change to a team's exposure route may still need explanation, but the briefing should describe the actual work rather than repeat generic WHMIS language.

A defensible change-control sequence

Receive and identify the information. Record the date, sender, product identifier and form of the notice. Link it to the product used at each Ontario workplace. Ask the supplier to resolve any uncertain identity or version mismatch.

Assess the statutory trigger. Compare the new information with the current SDS and the section 1 definition. Does it change classification or ways to protect against the hazard? Record the reason for the decision. Escalate a technical question rather than labelling a material change “minor” to avoid work.

Check the sheet's origin. Is this a supplier SDS for a product received from a supplier, or an SDS the employer prepared for its own product? Apply section 17 or section 18 accordingly. Do not import the 90-day outer limit from the employer-produced rule into the supplier-SDS task.

Update the active workplace information. Obtain the current supplier SDS where available. Ensure the active workplace copy reflects significant new data as soon as practicable and retains a clear source and version trail. Remove or mark superseded active copies so workers are not given conflicting instructions. Where the supplier has not yet issued a revised sheet, manage the new information openly and seek the correct document.

Check the label trigger. If the significant new data came from a supplier, review section 8, subsection 5 for every relevant supplier label. Attach information reflecting it as soon as practicable. Check existing stock as well as incoming deliveries.

Communicate and verify. Tell people whose work is affected about the new hazards or protective measures. Test the SDS access path from the work area and across shifts. Check that labels, instructions and the current sheet tell a coherent story. Record completion and set a follow-up if supplier documentation or workplace controls are still being finalised.

These steps are a management sequence, not six statutory stages. The legal tests are in the cited Act and regulation. The sequence is designed to make a change traceable from first notice to the information workers actually use.

What to record without inventing a legal checklist

A useful change record can contain the product identifier, workplaces affected, source of the new data, date received, old SDS revision, new or amended active version, sections changed, person who assessed the trigger, label action, worker communication and outstanding questions. Ontario's cited rules do not prescribe this exact spreadsheet layout. The record exists so another person can reconstruct the employer's decision and find the right current information.

Be careful with a field named “compliance approved.” Unless someone has actually resolved each legal and technical issue, that label can overstate what the review did. More useful statuses might distinguish information received, identity confirmed, significant-data assessment pending, active SDS updated, relevant label action complete and worker communication complete. If a product remains in use while a question is unresolved, record the actual interim arrangement and who is responsible for it.

An audit should trace both directions. Start with a container on the floor and find the current SDS. Then start with a significant-data notice and identify every workplace and relevant container that received the update. This catches different failures: a document with no matching product, or a product whose document and label were never updated.

Do not rely solely on the last modified timestamp of a file. A copied PDF can have a recent upload date while its hazard information is old. An older supplier document may still be current if there has been no change, but that conclusion should be based on the information and the supplier's current position, not on an invented universal expiry date.

Common errors after a supplier notice

Using the employer-produced 90-day rule for every sheet. Section 17 uses “as soon as practicable” for the supplier SDS after significant new data. Section 18 has the separate 90-day outer limit for an employer-prepared SDS. State which one applies.

Waiting for a new PDF before responding to reliable new data. The section 17 trigger includes significant new data otherwise becoming available to the employer. Seek the supplier's revised sheet, but do not hide a material protective change from workers in the meantime.

Updating the library but forgetting stock already at work. If the significant data came from a supplier, section 8, subsection 5 may require attached information on relevant supplier labels. A shipment already in storage is still relevant stock.

Leaving two apparently current versions accessible. Someone may open the first search result or a paper copy saved in a work area. Test the route and mark superseded active documents.

Treating document control as worker education. Section 6's information duty may require an explanation of changed hazards or controls to exposed workers. Workers need usable information for their own tasks.

Applying Ontario's rule across Canada. Another workplace may be under a different provincial, territorial or federal employer regime. Keep the jurisdiction attached to the legal conclusion.

Finish with a workplace check

An update is useful when the chemical, the active SDS, the relevant label information and what workers understand all agree. Ask a worker to locate the document for the actual product. Compare the new hazard or protective statement with the task and with the container. Confirm that the updated information is available on every shift and that any unresolved supplier question has an owner and follow-up date.

For a broader view of Canadian compliance records, visit Complys Canada. Assess any software against the actual document and worker-access process. This page does not claim Complys automatically detects significant new data, edits supplier safety data sheets or determines legal compliance.