Compliance45
Worker Safety60
Inspector Confidence50
Module 1 · The Inspection

Inspector at the Gate

You are Jordan Ellis, Health and Safety Manager at Crestline Industries, a specialty chemicals plant in Sarnia, Ontario. Three weeks ago the WHMIS transition deadline closed: every supplier label and safety data sheet sold for use in a Canadian workplace had to be on the updated rules by December 14, 2025. A Ministry of Labour inspector has just arrived at reception. The clock starts now.

OPS
ALERT — MINISTRY OF LABOUR FIELD VISIT. Inspector Rachel Solis, Ontario Ministry of Labour (Occupational Health and Safety), presented at front desk 08:17. Unannounced. Triggered by a worker complaint: containers on Blend Line 2 with no readable labels.
OPS
Note: Inspector Solis is also designated by Health Canada to check supplier rules, so she can look at both sides of WHMIS today — the workplace side (your duties as an employer) and the supplier side (your duties as a maker and seller of hazardous products).
OPS
Program Status: 14 safety data sheets (the standard 16-section hazard documents that ship with each product, "SDS" for short) last updated 2024, before the new rules. 3 products Crestline makes and sells were reclassified as more hazardous; the customer labels still carry the old wording. 23 of 41 plant workers are overdue for WHMIS retraining, and 6 of them work mainly in French with English-only materials. The written WHMIS program still has a 2018 header.
Jordan
Forty-five minutes. I know where the gaps are. The real question is which hat she puts on first: are we an employer that didn't train its people, or a supplier that shipped the wrong labels? Because we're both, and they answer to two different laws.
Solis
Good morning. I'd like to start with your SDS binder and Blend Line 2, then your training records and the written program. And I'll want to see three products I believe you're shipping with out-of-date labels.

What You're Walking Into

Your in-house EHS dashboard is loading. Read each feed entry as it appears — these are the live gaps you're walking into the inspection with.

Triage: Where Do You Start?

The inspector is ready to begin. Where do you take her first? Your choice determines the order of findings AND triggers a background action.

Out of Date vs Current — CR-44 Hydrocarbon Solvent

Inspector Solis is reviewing Crestline's own outbound SDS for CR-44, the one you ship to customers. Getting this right is your duty as a supplier (the federal rule that says a company must correctly classify and document what it sells). New test data moved CR-44 up a hazard category. Click each cell on the RIGHT where the updated version differs from the one on file. Flag 5 real changes. Submit when ready.

Flagged: 0 / 5 target · Click cells to flag differences

Current SDS on file (2024)
Updated SDS (current WHMIS rules)
Section 2 — Hazard Identification
Flammable Liquid, Category 2 (Flash point 23–60°C)
Flammable Liquid, Category 1 (Flash point below 23°C, initial boiling point ≤35°C)
Section 2 — Signal Word
WARNING
DANGER
Section 7 — Handling and Storage
Store away from heat and ignition sources.
Store in a cool, well-ventilated place. Keep container tightly closed. Ground and bond container and receiving equipment. Use explosion-proof equipment.
Section 1 — Product Identifier
CR-44 Hydrocarbon Solvent — Industrial Grade
CR-44 Hydrocarbon Solvent — Industrial Grade
Section 14 — Transport Information (TDG)
UN1268 Petroleum Distillates, Flammable Liquid, 3, PG II
UN1268 Petroleum Distillates, Flammable Liquid, 3, PG I
Section 16 — Other Information
Last revised: March 2024
Last revised: November 2025

Pictogram Matching — Crestline Product Line

Inspector Solis asks you to match each of the six Crestline products to the correct hazard pictogram(s). Some need more than one. Drag tiles onto each product. WHMIS supplier labels must show the right pictograms for the product's current hazard class. Watch for the one product that carries Canada's own Biohazardous Infectious Materials symbol, a hazard class GHS does not use.

Pictogram Tray — Drag to Products
🔥Flame
Exclamation
Biohazardous
Corrosion
Gas Cylinder
Skull (Distractor)

Tiles are reusable — click a placed tile to remove it.

Spill — Blend Line 2

Response Window 15

Choices vanish when the timer hits zero.

Label Correction Approach

Solis
Three of your product labels — CR-44, CR-61, CR-78 — still show the old, weaker hazard wording. You make these products, so every customer you've shipped in the last 18 months has the wrong label. And the corrected labels have to be in both English and French. I'd like your plan before I finalise my notes.

Inspector Solis has confirmed three product labels are out of date. Because Crestline makes these, the problem is on everything you've shipped, not just what's on your floor. What's your play?

Inspector's Question Round

Inspector Solis has four direct WHMIS questions. For each: pick your answer, then rate your confidence 1–5. Your confidence vs accuracy shows up in the debrief. WHMIS reference.

Training Record Audit

Inspector Solis is reviewing your training records. This document has 4 compliance errors. Click any value that is wrong before she reaches the end of the page. WHMIS education and training sets out what a worker record must cover.

Errors flagged: 0 / 4 target

WHMIS Worker Education & Training Record — Crestline Industries
Training Date
February 14, 2024
Hazard system covered
WHMIS 1988 (old hatched-border symbols, pre-2015)
Topics covered
How to read an SDS; where SDSs are kept; what to do if exposed to a product
Products covered
General WHMIS overview — all products used at the site
Trainer name
J. Ellis, Health & Safety Manager
Number of workers trained
41 workers
Review trigger
Reviewed at least once a year, and whenever conditions change

Timeline Commitment

Solis
I've found four problems: out-of-date SDSs, both the ones you received and the ones you ship; labels on your own products that show the wrong hazard; overdue worker training; and a written program stuck on the old rules. I'm going to write compliance orders with dates on them. Propose the dates. Miss them and each day is a separate offence, on top of on-the-spot penalties I can now issue without going to court.

Your dates become binding orders. Pick the timeline you can actually deliver.

Orders Issued

OPS
Ministry of Labour — Field Visit Report. Crestline Industries, File #SAR-2026-00417.
OPS
Compliance order — safety data sheets: 14 received SDSs and 3 outbound SDSs are out of date. Update them and keep current copies available to workers. The outbound (supplier) defect is referred to Health Canada.
OPS
Compliance order — supplier labels: labels on 3 Crestline products (CR-44, CR-61, CR-78) show the wrong hazard and are not in both official languages. Correct and reissue.
OPS
Compliance order — worker training: 23 workers overdue for WHMIS training; 6 trained only in English although they work mainly in French. Deliver training the workers can understand.
OPS
Compliance order — written program: the written WHMIS program references the old rules and its contractor section is inadequate. Revise it.
Jordan
Four orders, firm dates. The label and SDS defects also went to Health Canada as supplier issues, where fines reach $1,000,000. It could have been far worse. If the spill had gone wrong, or she'd found the QC Lab sample jars before Mike did, we'd be in prosecution territory: up to $2,000,000 for the company, and I'd be personally on the hook.

Inspection Closed — Cooperative Outcome

0

Inspector Solis records a "cooperative employer that started fixing things on the spot." The orders carry firm but workable dates, and the supplier referral to Health Canada is noted as self-corrected. Being straight with her changed the whole character of the visit.

Citations Issued — Partial Compliance

0

You carry the risk through the order period. Miss a date and each day is a separate offence, with on-the-spot penalties available to the inspector. You did the work, and still have a month of exposure.

Module complete. Continue when you're ready.

Formal Investigation — Multiple Violations

0

Inspector Solis records "contested findings." The visit is no longer cooperative, and the file is being reviewed for prosecution. A conviction runs to $2,000,000 for the company, with personal liability for the managers involved.