CCSPA Current Issues

CCSPA Current Issues

CCSPA is involved in over 80 files that directly or indirectly impact our members. We are the premier association for consumer products and our ability to advocate for our industry speaks volumes. These are just a few examples for your perusal. If you require more information, please call Shannon Coombs, CCSPA President, at 613-232-6616, ext. 11.

Federal Government’s Chemicals Management Plan (CMP)

In 1999, the Canadian Environmental Protection Act (CEPA) required that the 23,000 substances on the Domestic Substances List (DSL) be categorized by 2006 and subject to a Screening Level Risk Assessment (SLRA), if warranted. On December 9, 2006, Prime Minister Stephen Harper announced the government’s new Chemicals Management Plan (CMP). In October 2011, the Government announced the renewal of the CMP at the Annual CCSPA Government Interface. Now we have started the CMP this year – and we have over ~ 500 business critical substances on the list! The next renewal is anticipated in early spring 2016. CCSPA is extremely active on all aspects of this important file and we are working hard to ensure our industry and our substances are supported and defended. CCSPA advocates for:

  • science-based decisions
  • due process for companies
  • effective communications to Canadians

We also:

  • work to engage our members about the importance of formulator, supplier and/or retailer awareness of the substances captured in the Industry Challenge Program, CMP2 and now CMP3
  • assist our members on the CMP process for submitting the necessary technical data to government that will allow continued access to technology and provide opportunities for engagement with officials on the science
  • increase the proactive communication by government, industry and retailers on risk management and regulation, approval processes and their actions on substances
  • provide key information documents to our members, their customers and retail associations handling media interviews on this important topic

Globally Harmonized System of Classification and Labelling of Chemicals

Over the past 3 years, CCSPA has been working with Health Canada, the provinces and stakeholders on the harmonization of the regulations with OSHA on GHS. On February 11, 2015, the final regulation was published; and the transition that CCSPA had proposed to meet the needs of all industry was adopted.  CCSPA has worked tirelessly to ensure that the guidance for industry was posted prior to the implementation deadline of 2017 and it was! We are working with senior officials to retain the use of concentration ranges so that the protection of confidential business information is not subject to the costly and lengthy review under the Hazardous Materials Information Review Act. CCSPA is your go to association on this file!

Volatile Organic Compounds

Volatile Organic Compounds (VOCs) were declared toxic under CEPA as precursors to ground-level ozone, a component of smog. They have been added to Schedule 1 of CEPA, the Toxic Substances List, and will undergo mandatory risk management as determined by Environment Canada. CCSPA has been actively engaged with Environment Canada to ensure the proposed regulations published in Canada Gazette, Part I, are harmonized with our major trading partner. In January 2013, a new draft consultation on the future regulations was published for comment. We have been successful in working with Environment Canada to ensure that the appropriate products are included and/or exempted in the proposed regulation, with the correct allowable VOC levels, to ensure harmonization. CCSPA is your go to association on this file!

 

“CCSPA is the premier association for chemical specialty products. Their knowledge of regulations and legislation is exceptional and they are always ahead of the curve on new plans and policies from regulators, which enables our industry to be proactive in working with Government”.

Dominic D’Amours
Director of Quality, R&D,
Regulatory Affairs and Sustainable Development
Lavo Inc.

 

The Pest Control Products Act and RegulationsThe new Pest Control Products Act (PCPA) received Royal Assent on December 12, 2002, and a Parliamentary Review was conducted in 2015. CCSPA appeared before the Parliamentary Committee to discuss the issues facing the PMRA. In 2015, CCSPA was requested to be part of the Auditor General’s Advisory Committee on pesticides for their 2016 audit; and our products were not impacted. CCSPA is committed to working with the PMRA to ensure the provincial governments who have taken action on pest control products do so based on science, to ensuring adequate funding for the Agency, that communication is a key strategic driver, and that future cost recovery regime results in faster timelines for Category C submissions. The PMRA is currently conducting a review of all PCPA regulations and we expect changes to be proposed in 2017.

Bureau of Chemical Safety, Food Directorate

CCSPA members raised concerns in early 2010 regarding the review process for consumer products that go through the Canadian Food Inspection Agency’s (CFIA) Non-Food Chemical and Container Integrity Programs for the safe use of Incidental Additives such as non-food chemical products. CFIA is no longer responsible for the process but Health Canada continues to provide this service. Manufacturers wishing to sell products for use in food establishments can submit an incidental additive submission form for formal approval of their product by Health Canada. Currently, this process can take 6 months to 3 years; and the onerous timelines are causing problems for manufacturers. You can also provide a letter of self-attestation.

In an effort to improve the existing Non-Food Chemical and Container Integrity Programs for the safe use of Incidental Additives for our members, CCSPA is working with Health Canada’s Bureau of Chemical Safety, Food Directorate (BCS FD) to help develop a predictable, timely, and transparent review process for Letters of No-Objection (LONO) and the iLONO process for processing aids.

Consumer Health Products Framework – now called the Self Care Framework

In June 2016, Health Canada proposed a new Self Care Framework for low risk products. Disinfectants and sanitizers were scoped out and have their own parallel process.  CCSPA continues to work with the Natural and Non-Prescription Health Products Directorate to develop the framework and achieve operational improvements as well. This is a key file for CCSPA in 2017!

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