Intertek’s scientific and regulatory experts can help your company successfully meet the requirements of Canada’s Chemicals Management Plan.
Canada's Chemicals Management Plan (CMP) is a federal government initiative intended to proactively manage the potential risks posed by the use of certain chemicals to both human health and the environment in Canada. Many reporting obligations and government assessments have been triggered by the CMP. The Government of Canada has and will continue to gather information from industry to complete risk assessments of priority substances grandfathered to the Canadian domestic inventory, the Domestic Substances List. Should a risk assessment indicate the potential for a substance to be “toxic” under the Canadian Environmental Protection Act of 1999 (CEPA 99), risk management tools will be developed for stakeholder implementation according to a well defined schedule.
The first phase of the Chemicals Management Plan (CMP1) involved several important initiatives, including the Industry Challenge, the Rapid Screening of ~600 substances, the Petroleum Sector Stream Approach, and the first phase of the DSL Inventory Update:
The Industry Challenge required importers, manufacturers and users of about 200 high-priority substances to provide the government with information on the use, exposure, releases and management of these substances. The Challenge substances were grouped into 12 batches which were addressed sequentially with Notices issued by the Canadian Government under Section 71 of the Canadian Environmental Protection Act, 1999 (CEPA, 1999) for the collection of data. The batches were assessed, draft assessment reports were provided for public comment, appropriate risk management plans were developed and final decisions were published in the Canada Gazette..
The Rapid Screening Approach allowed the Government of Canada to quickly assess DSL-listed substances that they expected to be of lower concern. Of the 1005 substances selected for review, it was determined that ~470 required additional information in order to address their potential toxicity. The final screening assessment of the remaining ~600 substances was published on Environment Canada's website in April 2013.
An additional 160 high-priority substances were grouped for assessment using a sector-specific approach. This Petroleum Sector Stream Approach ran in parallel to the Industry Challenge and was divided into five streams of substances. Stream 0 identified substances that were either no longer in commerce, or were not produced by the petroleum sector, and did not warrant reporting. Assessments for Streams 1-3 are publicly available, while the data for Stream 4 has been collected and is currently under review by the Canadian Government.
The second phase of the Chemicals Management Plan (CMP2) builds on the information obtained in the first phase, and expands the scope of the data collection to include medium priority substances through the Polymer Approach, the second phase of the Rapid Screening Approach, Substances Grouping Initiative and the second phase of the DSL Inventory Update (DSL IU2):
The Polymer Approach is a planned tiered approach for the assessment and management of certain categorized polymers, which will be based on the results from the DSL IU2 as well as a polymer-specific survey which is expected to be issued in 2014/2015.
The second phase of the Rapid Screening Approach, like the first phase conducted under CMP1, will identify lower-concern substances which can be assessed quickly, based on the data received from the DSL IU2. Results of this approach will be published in draft form after the substances have been assessed by the Government of Canada, and a 60-day public comment period will follow before the final assessment is published.
The Substances Grouping Initiative involved a review of the DSL-listed substances and the identification of certain specific groups of substances that were of interest. Those 9 groups were then prioritized and mandatory Section 71 surveys are issued for each group in sequence, for the purposes of gathering data from importers and manufacturers of those substances. 6 of the 9 groups have completed the data-gathering process and draft assessments are being prepared. The Section 71 surveys for the remaining 3 groups – Certain Organic Flame Retardants, Phthalates, and Boron-Containing Substances – are expected to be published by the end of 2013.
The key objectives of the DSL IU are to update the “commercial status” of substances, assist in planning for the next phase of the CMP, inform the Rapid Screening Approach for lower-risk substances, and inform the Polymer Approach. Phase 1 of the DSL IU was initiated in 2009 and targeted ~500 chemicals and ~50 microorganisms. The deadline for data submission under Phase 1 of the DSL IU was March 30, 2010. The second phase of the Domestic Substances List Inventory Update (DSL IU2) was launched on December 1, 2012 in the form of a mandatory survey under Section 71 requiring manufacturers and importers to report use information on ~2700 medium-priority substances. The deadline for submission of this data through Environment Canada’s Single Window Information Manager system is 5pm EDT on September 4, 2013.
Additional initiatives under CEPA include the Prohibition of Certain Toxic Substances Regulations. As existing substances are assessed under the CMP and where concerns for CEPA toxicity arise, one of the potential actions or “tools” available to Environment Canada/Health Canada to manage the associated risk continues to be the Prohibition of Certain Toxic Substances Regulations. In January 2013, Environment Canada repealed the existing Prohibition of Toxic Substances Regulations, 2005 legislation and issued new legislation in its place (Prohibition of Certain Toxic Substances Regulations, 2012). The new legislation regulates the prohibition, permitted use, concentration limits and reporting thresholds of twenty-six known toxic substances, thirteen more substances than were originally identified in the 2005 Regulations. Manufacturers, importers and users of these substances should be aware these new regulations, as some of the substances which were present in the 2005 Regulations have been moved within the 2012 Regulations to further restrict their use or sale. The Prohibition of Certain Toxic Substances Regulations, 2012, is available on Environment Canada’s website.
Chemical Management Plan (CMP) Compliance Services
Intertek recognizes that Canada's CMP has triggered the need for increased industry effort to review and respond to substance-specific reporting requirements, draft assessment reports, and proposed risk-management controls. Intertek’s experts can address these regulatory and scientific challenges by offering the following:
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