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Cleaning chemicals are not ordinary consumer goods once they are used at work. Health Canada administers WHMIS through the Hazardous Products Act and the Hazardous Products Regulations, which set out how a hazardous product sold or imported for use in a Canadian workplace must be classified, what its supplier label must say, and what its safety data sheet must contain. The Canadian Centre for Occupational Health and Safety explains that safety data sheets run to sixteen standard sections set out in Schedule 1 of those regulations, are normally written by the manufacturer or supplier, and must be readily available to the workers exposed to the product and to the health and safety committee or representative.

The employer side is where most disputes start. CCOHS draws a line between education, meaning the general information about how WHMIS works and what the hazards are, and training, meaning the site- and job-specific procedures for storing, handling, using and disposing of a product and for dealing with spills and emergencies. Every Canadian jurisdiction requires employers to develop, implement and maintain a worker WHMIS education and training program, and CCOHS advises reviewing it at least annually, or sooner when products, processes or hazard information change. Ontario, for example, applies WHMIS through the Occupational Health and Safety Act and its WHMIS regulation.

The building owner does not get to hand all of this to the contractor. Under Ontario's Occupational Health and Safety Act, an employer must take every precaution reasonable in the circumstances for the protection of a worker and must provide information, instruction and supervision, while an owner, defined to include a tenant, lessee or occupier of premises used as a workplace, has duties of its own for the state of the premises. In practice that means telling the cleaning company about hazards in your space, not just expecting their staff to discover them at night.

Sources: Health Canada: Workplace Hazardous Materials Information System (WHMIS) · Hazardous Products Regulations (SOR/2015-17), Justice Laws Website · CCOHS: WHMIS education and training · CCOHS: WHMIS safety data sheets · Ontario: Workplace Hazardous Materials Information System (WHMIS) · Guide to the Occupational Health and Safety Act: duties of employers and other persons (Ontario) · WSIB Ontario: clearances