Information from the Canadian Centre for Occupational Health and Safety

If workers are not exposed to controlled products/chemicals, they do not require WHMIS training. The Ontario Occupational Health and Safety Act and Regulations (section 42(1)) states: The employer has a general duty of educate workers who are exposed or likely to be exposed to a controlled product on the job. The following is an excerpt from the MOL Publication "WHMIS: A Guide to the Legislation". From: 
  
http://www.labour.gov.on.ca/english/hs/pubs/whmis/whmis_4c.php
 
Who needs to be educated?

The law requires that the employer educate "a worker exposed or likely to be exposed" to a controlled product [section 42(1) of the Act]. The phrase "a worker exposed or likely to be exposed" is open to interpretation and may cause problems for the workplace parties and for regulators when determining the actual number of workers to be educated.
 
The following points are suggested as guidelines when determining who needs to be educated.

1.  An "exposed worker" is any worker who stores, handles, uses or disposes of a controlled product, or who supervises another worker performing these activities.

2. A worker "likely to be exposed" is any worker who could be at risk during:

• the storage, handling, use or disposal of a controlled product; 
• maintenance operations; or 
• emergencies, such as an accidental leak or spill.

For further interpretation, we suggest that you contact your local Ministry of Labour office. For contact information see: 
  
http://www.labour.gov.on.ca/english/about/reg_offices.php  

Although WHMIS training may not be required if controlled products are not present in the workplace, you may still be required to train workers for any potentially hazardous non-controlled products. For example, consumer cleaning products are partially exempt from WHMIS, however any worker who has the potential to be exposed should be trained on how to work safely with the products. Training for products not controlled by WHMIS does not have to include WHMIS training.
 
It's worth noting that the Ontario MOL has issued a warning alerting employers about the aggressive sales practices of some safety trainers. Below are examples of this warning.
 
Alerts

Employer Alert: High Pressure Sales Tactics Providing Misleading Information About Workplace Notices and Safety Training. Ontario Ministry of Labour. August 27, 2007. 
  
http://www.news.ontario.ca/archive/en/2007/08/23/c976797cd-27996-tpl.html