Health Canada Extends Comment Period for Proposed Hazardous Substance Disclosure Rules

Health Canada has extended the comment period for stakeholders to provide feedback on the proposed disclosure requirements for hazardous substances found in household chemical products such as cleaners and lubricants. This pre-consultation is open for public comment until October 20, 2023.This initiative is part of Health Canada's ongoing efforts to improve consumer safety by introducing new requirements for chemical products under the Canadian Consumer Product Safety Act (CCPSA). 

The primary aim of this proposal is to protect the well-being of Canadians by implementing a comprehensive hazard classification and information disclosure framework for Hazardous Household and Health-Related Chemicals (HHHOCs). In conjunction with this, additional protective measures, such as prohibitions, restrictions, and child-resistant container requirements, will be considered. This approach will ensure that consumers are well informed about the presence of HHHOCs in household chemical products and are provided with essential precautionary information, including safe use instructions and first aid guidelines on the associated risks. 

Background  

A wide range of consumer chemical products, including household cleaning products, adhesives, and lubricants, are readily available to the Canadian public. The Consumer Chemicals and Containers Regulations, 2001 (CCCR, 2001) under the CCPSA play a crucial role in protecting Canadians from acute human health and physical hazards associated with consumer chemical products. These regulations accomplish this through various means, such as prohibiting dangerous consumer chemical products, imposing restrictions, requiring information disclosure, and specifying container standards. The specific requirements for consumer chemical products are determined through scientific assessments of the hazards associated with the substances contained in the products, evaluated against the classification criteria established in the regulations. 

As of now, the CCCR, 2001 address acute human health and physical hazards, which include: 

1. Acute toxicity, which includes lethal or serious, non-lethal effects. 

2. Corrosivity, which covers chemical burns and eye damage. 

3. Flammability, which covers chemicals that can catch fire. 

4. Pressurized containers, which can explode if heated or punctured. 

5. Quick skin-bonding adhesives, adhesives that bond skin rapidly. 

However, there is a need to reduce the risks associated with Hazardous Household and Health-Related Chemicals (HHHOCs), which can cause adverse health effects from long-term or intermediate exposure. The current CCCR, 2001, lacks requirements to address the following HHHOCs: 

1. Carcinogenicity, associated with the induction of cancer. 

2. Germ cell mutagenicity, which involves heritable gene mutations. 

3. Reproductive toxicity, which includes adverse effects on sexual function, fertility, or developmental toxicity in the offspring. 

4. Specific target organ toxicity, resulting in adverse effects in target organs after single or repeated exposure. 

5. Respiratory or skin sensitization, resulting in allergic reactions or hypersensitivity. 

Requirements for consumer chemical products 

The proposed requirements for consumer chemical products under the CCPSA include: 

1. Classification criteria for HHHOCs, in line with the Globally Harmonized System of Classification and Labelling of Chemicals (GHS). 

2. Information disclosure requirements for HHHOCs, based on the GHS labelling elements, including hazard symbols, signal words (e.g., "Danger" or "Warning"), hazard statements (e.g., "May cause cancer"), precautionary statements (e.g., instructions for safe use and first aid), and ingredient disclosure requirements. 

3. Additional protective measures, such as prohibitions, restrictions, or child-resistant container requirements, as deemed necessary. 

It is important to note that the existing requirements of the Consumer Chemicals and Containers Regulations, 2001 (CCCR, 2001), including classification criteria, prohibitions, information disclosure requirements, and container specifications, will remain in force under this proposed regulation. 

Deadline 

To implement these proposed requirements, Health Canada is exploring various regulatory options, such as amending the CCCR, 2001, or introducing a new regulation under the CCPSA. This pre-consultation period is open for public comment until October 20, 2023.