Mixing, Blending and Formulating: Salt does happen!
Remember to keep an eye out for ingredient interactions that might produce a new substance right there in the vat. Read more.
13 May 2013
A note of caution to all you formulators out there - when cold-mixing, blending or formulating (or whatever other name the activity goes by in your plant) your performance products for sale into Canada, remember to keep an eye out for ingredient interactions that might produce a new substance right there in the vat. For example, if your ingredient list includes both acidic and basic materials, check to see if you should expect them to form a salt, and if so, whether that salt is listed on the Domestic Substances List. If it isn't, then, by definition, it's a new substance, and is, therefore, notifiable.
The same consideration also should be given to polymers – during manufacture as well as formulation. Remember that Canada has no equivalent to the USEPA's TSCA "(h)(7)" exemption, so if you've neutralized your polymer at all, make sure that the CAS name and number you use to describe it adequately captures the counterions present, and are listed on the DSL.
Do you have questions about Canadian new substance notifications 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 North American Chemical Industry, makes Ms. Borkhoff uniquely qualified to provide practical, best-in-class service to help meet and understand the requirements of the Canadian Chemical Management Plan (CMP) including the Challenge to Industry and the DSL Inventory Update.