Canada requests early industry engagement for Phase 3 of the Chemicals Management Plan (CMP3)

Intertek addresses impact on the Chemical Industry

18 March 2016

This year marks the 10th anniversary of the federal government's launching of the Canadian Chemicals Management Plan (CMP), introduced in 2006 as part of the government's comprehensive environmental agenda.  With funding support from the earlier Economic Action Plan 2015's injection of $500M into the CMP budget for the next 5 years, Environment and Climate Change Canada and Health Canada are set to launch the third phase of the CMP (CMP3). With the launch of CMP3, the new Liberal government has extended the program to address the remaining 1550 substances (640 organics, 370 inorganics, 330 polymers and 220 petroleum substances) by 2021.  To kick off this third phase, a notice of intent was published in the Canada Gazette on February 6, 2016, inviting new, as well as previously identified industry stakeholders to provide any information they have on hand for these substances, particularly processing, function, use, and hazard information. Any data provided in response to this Notice, along with data previously gathered as part of phase 2 of the Domestic Substances List Inventory Update (DSL IU2), will be used to inform and shape future Phase 3 data gathering and assessment initiatives, which we could expect to see as early as spring 2016. Moving forward, the government's work plan will be updated to specify the substances for which additional information is needed and more detailed notifications will be published periodically, specifying the type of information, the associated timelines and details on how to provide this information.

How does this affect your business?

Whether or not you have any information you'd like to share at this time, if your organization has any interest in the manufacture, import or use of one or more of the 1,550 listed substances, there are multiple benefits to identifying as a stakeholder. By beginning the dialogue at this early stage in the process, stakeholders have an increased ability to influence the assessment approach. Further, government has indicated that they are moving away from the predisposition to issue mandatory surveys that trigger company-specific compliance activities and will maximize their opportunities to engage with industry through sector approaches and joint industry submissions. By reviewing this list of substances, you can begin to develop an early strategy for engagement, whether as a direct stakeholder or by working with your industry sector/association.  By engaging, you can gain an early understanding of the extent of information gathering and assessment effort for your substance(s), allowing you to focus your resources more effectively.

If you have not yet identified as a stakeholder for the Phase 3 substance assessment and would like to do so, a reporting tool will soon be made available through the Environment and Climate Change Canada Single Window Information Management (SWIM) website.

Do you have questions about the Chemicals Management Plan or other related topics? Share your comments or questions below and our expert, Joyce Borkhoff, will get back to you.

Today's expert blogger is Joyce Borkhoff. Joyce is the Director of the Intertek Chemicals Group and is well known for her ability to effectively characterize and communicate the impacts of the regulatory environment on the chemical industry. She is frequently invited to contribute to trade magazines and to present her advice and experience to a wide range of SME and large multi-national audiences. Her technical and regulatory experience and her deep knowledge of the Chemical Industry, makes Ms. Borkhoff uniquely qualified to provide practical, best-in-class service to help meet and understand Global Chemicals Management requirements.