The
Industrial & Institutional Technical Forum (IITF) is a newly developed
membership category of the Canadian Sanitation Supply Association. Dedicated to
the chemists, consultants, lab technicians, R & D specialists, technical
managers and quality control supervisors in your company the IITF goals are:
To increase technical knowledge in
the I & I sector
To further individual ethical
guidelines amongst the membership
To provide opportunities for
education for existing and prospective members in theindustry
To provide a forum for professional
review of proposed regulations that affect the industry
To collect and distribute information
of value to the members
To stimulate friendship, acquaintance
and goodwill generally among its members by providing the means for a cordial
interchange of views.
The
Chairman of the IITF is Robert Akhavan of Flexo Products – e-mail:
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Click here to download the presentation by Dr. Syed Sattar held in Toronto on April 29, 2009 entitled "Preventing The Environmental Spread Of Infections: A Critical Look At Current Practices And Future Directions
Click hereto dowload the presentation by Dr. Syed Sattar held in Toronto on May 1, 2008 entitled "Microbicidal Activities of Environmental Surface Disinfectants"
Click hereto download the speaker presentation on "Green and Plant Based Cleaning Products" from the IITF meeting held in Toronto on May 2, 2007.
Click here to dowload the presentation on "The Current Regulatory Environment for Antimicrobial Products in Canada" from the IITF meeting held in Toronto on May 2, 2007
Regulatory Update
Environment Canada has issued a Notice of Intent to limit the use of
phosphorus based chemicals in laundry detergents, machine dishwashing
detergents, and general purpose cleaners effective 2010. CSSA has requested an
exemption for I &I applications:
Environment Canada has issued their proposed VOC limits for various
cleaning products which will be matching the California limits. Products
impacted may be found at the following link:
Comment on Environment Canada’s Draft Regulations Respecting the Concentration of Phosphorus in Certain Cleaning Products published in Canada Gazette, part I, June 28, 2008. Read more...
Canada Gazette I of September, 20/08 announced proposed additions to the List of Toxic Substances in Schedule 1 of CEPA, 1999. Once a chemical is on this list, the government is required by law to introduce methods to control its release. This may include further reporting, limits, application restrictions or virtual elimination by bans. These announcements are proposals at this time; and there will be a 60 day comment period. The following chemicals have been identified for addition to the Toxic Substances list:
Items 2-8 are covered in the following announcement: http://gazetteducanada.gc.ca/partI/2008/20080920/pdf/g1-14238.pdf p. 2668
Members may be using some of these chemicals directly or they may be impurities in some of their raw materials. It is expected that some controls will be required for these chemicals.
As the government continues the examination of the DSL there will be many more chemicals that will be added to the list of Toxic Substances. Most chemicals will be listed by their CAS no., Chemical Abstracts Services number. It is strongly recommended that members have the CAS no. for all of their raw materials so that they are able to determine quickly if these changes could impact them. This information is available on the MSDS.
Environment Canada and Health Canada have issued the next list of chemicals for further review as part of the categorization and screening of the Domestic Substances list. The link to the document is: http://gazetteducanada.gc.ca/partI/2008/20090131/pdf/g1-14305.pdf
In summary, there were 9 substance identified that were persistant, bioaccumulative , or inherently toxic. Of these CAS # 65140-91-2 with trade name Irganox 1425 may be used by CSSA members. Of the 5 chemicals cited as being a high hazard to humans and a likelihood of exposure, 139-13-9, N,N-bis(carboxymethyl)-glycine or NTA is likely used by some CSSA members in some of their cleaning formulations. Under Section 71 of CEPA 1999 you are required to respond by completing sections 4,5,8,9, &10 of schedule 3 of this notice by April 7, 2009 if you imported or manufactured 100 kg of any of the listed chemicals or used 1000 kg in a product in 2006.
It is probable that some CSSA members would have used NTA at this level so will be required to report. Please check the link to download the required reporting forms and check to see if any other products listed are used by your company.
Canada Gazette I, Jan.31, 2009 issues follow-up to batch 2 challenge substances
The 16 chemicals listed for review in the Batch 2 challenge were classified as follows:
Virtual elimination: 2,4,6-tri-tert-butylphenol CAS # 732-26-3; a fuel additive;
Added to Toxic Substances list with risk management actions to be developed: Thiourea (CAS# 62-56-6), Isoprene (CAS# 78-79-5), Epichlorhdrin (CAS# 106-89-8), C.I. Pigment Yellow 34 (CAS# 1344-37-2), C.I. Pigment Red 104 (CAS# 12656-85-8), D4 and D5 siloxanes (CAS# 556-67-2, CAS# 541-02-6);
Did not meet toxic criteria, no further action: vinyl actetate monomer (CAS# 108-05-4), tetramethyl-m-xylylene diisocyanate (CAS# 2778-42-9), Acid Blue 80 (CAS# 4474-24-2), D&C Red No.21 (CAS# 15086-94-9), AMS (CAS# 125351-99-7), Acid Green 40:1 (CAS# 70161-19-2) ADIBSS (CAS# 83006-67-1), D6 (CAS# 540-97-6).
Of these Thiourea, used in silver polish, and some of the dyes may be used by the CSSA membership. Complete details are found at the following link; http://gazetteducanada.gc.ca/partI/2008/20090131/pdf/g1-14305.pdf
The results of the Batch 5 challenge substances review was released in Canada Gazette I Feb.21/09. There were 19 substances examined, mostly dyes, and only 2 products were to be added to Schedule 1, the Toxic Substances List:
1. acrylamide, CAS # 79-06-1
2. TCEP, CAS # 115 -96-8, a plasticize and viscosity regulator in carpet backing; due to potential carcinogenic responses.
CSSA May Regulatory Report
In the May 16/09 Canada Gazette I, nine substances from the Batch 2 Challenge list and four from Batch 3 were proposed to be added to Schedule 1 of CEPA (toxic substances list). These substances, by CAS # and name are:
• 62-56-6, Thiourea
• 78-79-5, Isoprene
• 80-05-7, Bisphenol A
• 106-89-8, Epichlorhydrin
• 541-02-6, D5 siloxane
• 556-67-2, D4 siloxane
• 732-26-3, phenol,2,4,6-tris(1,1-dimethylethyl); a fuel additive
• 1344-37-2, C.I. Pigment Yellow 34
• 12656-85-8, C.I. Pigment Red 104
• 110-46-6, 2-methoxyethanol acetate, 2-MEA
• 111-77-3, 2-(2 methoxyethoxy) ethanol, DEGME
• 1589-47-5, 2-methoxypropanol, PGME
• 2425-85-6, Pigment Red 3
In the June 24, 2009 Canada Gazette II, there were 2 items of interest to the CSSA membership:
1. The Phosphorus Concentration Regulations have been
finalized in Canada Gazette II, SOR/2009/179. There were no changes
from the proposed regulations. Household laundry detergents will have
a maximum concentration of 0.5 % P, household automatic dish
detergents, 0.5% P, and general cleaners also 0.5 %P. Industrial
laundry detergents will continue to have a maximum of 2.2 % P.
Industrial cleaners and automatic dishwashing detergents will NOT be
impacted. These regulations will take effect on July 1, 2010. A
further clarification of the meaning of general cleaners will be
forthcoming. CSSA was successful in maintaining the I&I exemption
for our products.
http://www.gazette.gc.ca/rp-pr/p2/2009/2009-06-24/pdf/g2-14313.pdf
2. Consumer Chemicals and Container Regulations, 2001 were
amended to update language, and testing methods. Further clarification
of flashback and a new test method was provided. This also puts into
the regulations that were previously referenced as guidelines and
interpretation memos. No major changes from the previous document.
Complete details are found at the following: http://www.gazette.gc.ca/rp-pr/p2/2009/2009-06-24/pdf/g2-14313.pdf
CSSA Regulatory Report July, 2009 Canada Gazette Part 1 of August 1, 2009 presented the results of the investigations of the 18 chemicals presented in Batch 4 of the Challenge.
1. The following chemicals were found to meet the CEPA criteria and will be added to Schedule I, Toxic Substances List:
CAS # 64-67-5, Diethyl sulfate
CAS # 77-78-1, Dimethyl sulfate
CAS # 68921-45-9, BNST
2. The following chemicals were felt to meet the toxicity criteria but would be included in the risk management program for 1,3-butadiene (CAS #106-99-0) already on Schedule 1:
CAS # 106-97-8, butane
CAS # 75-28-5, isobutane
3. The following chemicals were found to meet the criteria but were not present in sufficient quantity in Canada at this time. No further action was planned for these chemicals but would be subject to Significant New Activities provisions if future use increased:
CAS # 64325-78-6, DMTBA
CAS # 1154-59-2, tetrachlorosalicylanalide
CAS # 1176-74-5, Magenta E
CAS # 70776-86-2, BODPA
CAS # 68443 -10-7, ATAE
4. The following chemicals were not found to meet the CEPA criteria and no further action will be taken at this time
CAS # 110-54-3, n-hexane
CAS # 115-39-9, bromophenol blue
CAS # 115-40-2, bromcresol purple
CAS # 125-31-5, xylenol blue
CAS # 62625-32-5, PBTBO
CAS # 68308-48-5, ATAEP
CAS # 79357-73-6, ATACP
CAS # 17321-77-6, clomipramine Complete details are found at the following: http://www.gazette.gc.ca/rp-pr/p1/2009/2009-08-01/pdf/g1-14331.pdf
CSSA August Regulatory Report
As outlined in Canada Gazette I of August 22/09 final decisions on the screening assessment of Batch 5 chemicals was released. Two of the 19 chemicals highlighted were to be added to Schedule 1 of the CEPA the Toxic Substances List. The others were felt to not meet the CEPA definitions for toxicity and no further action would be taken. The chemicals involved are:
CAS # 79-06-1, Acrylamide, a coagulant /flocculant will be added to Schedule 1
CAS # 115-96-8, TCEP, a flame retardant in plastics will be added to Schedule 1
The following were found to not meet the criteria for listing and no further action would be taken:
CAS # 126-73-8, Tributyl phosphate TPB
CAS # 127-19-5, DMAc
CAS # 75-07-7, Formamide
CAS #, 79-07-2, 2-chloroacteamide ; no further action but subject to Significant New Activity Provisions
The following dyes and colorants were found to not meet the CEPA requirements and no further action was to be taken:
CAS # 6232-56-0, Disperse Orange 5
CAS # 5261-31-4, Disperse Orange 30
CAS # 12239-34-8, Disperse Blue 79
CAS # 16421-40-2, ANAM
CAS # 16421-41-3, AADM
CAS # 17464-91-4, Disperse Brown 1:1
CAS # 23355-64-8, Disperse Brown
CAS # 26850-12-4, Disperse Red 167
CAS # 29765-00-2, BANAP
CAS # 52697-38-8, BDAP
CAS # 55281-26-0, Disperse Orange 61
CAS # 55619-18-6, EED
CAS # 72927-94-7, DNAN
Complete details are found at the following: http://www.gazette.gc.ca/rp-pr/p1/2009/2009-08-22/pdf/g1-14334.pdf
CSSA Regulatory Report Sept. /09
Continuing the examination of the Challenge substances, Environment Canada and Health Canada have completed their examination of 14 more chemicals. Three were to be added to Schedule 1 of CEPA while 11 others were found to not meet the CEPA requirements and no further action would take place.
To be added to the Toxic Substances List:
• CAS # 2426-08-6, Oxirane, used in epoxy resins
• CAS # 96-29-7, butanone oxime, anti skinning agent in alkyd paints
• CAS # 90-94-8, Michler’s ketone, solvent
Chemicals that were found not to meet CEPA toxic definitions and no further action would be taken at this time were:
• CAS # 6407-74-5, Pigment Yellow 60
• CAS # 6407-78-9, Solvent Yellow 18
• CAS # 1325-86-6, Solvent Blue 5
• CAS # 6786-83-0, Solvent Blue 4
• CAS # 29398-96-7, Pigment Brown 22
• CAS # 78-59-1, isophorone
• CAS # 106276-78-2, MATCB
• CAS # 123-91-1, 1,4 Dioxane
• CAS # 16586-42-8, Disperse Red 179
• CAS # 25176-89-0, DAPEP
• CAS # 72968-82-2, DADM
Further details may be found at the following site; http://www.gazette.gc.ca/rp-pr/p1/2009/2009-09-05/pdf/g1-14336.pdf
CSSA Regulatory Report Oct. 2009
The Canada Gazette of October 3, 2009 has officially indicated the intent to add to Schedule 1 , the toxic substances list, the following chemicals and chemical classes: Dimethyl sulfate, Diethyl sulfate, BNST, Acrylamide, TCEP, tributyl tins and tetrabutyl tins. There is now a requirement for the government to regulate within 2 years exposure these chemicals. Further details in the rationale may be found at: http://www.gazette.gc.ca/rp-pr/p1/2009/2009-10-03/pdf/g1-14340.pdf
CSSA Regulatory Report, Dec. 28/09 – Batch 12 Challenge Substances
In the Canada Gazette of December 26/09, 16 substances were listed as Batch 12 Challenge substances divided into 5 parts with different reporting requirements. Users of these chemicals at the specified reporting levels are required by law to report their 2006 usages.
Part 1 substances:
CAS # 53-19-0, Mitotane
CAS# 56-95-1, Chlorhexidine acetate
CAS# 102 -06-7, N,N-diphenyl guanidine
CAS# 107-51-7, octamethyl-trisiloxane
CAS# 116-66-5, musk moskene
CAS# 355-47-3, trisiloxane compound
CAS# 515-03-7, sclareol
CAS# 13080-86-9, BAPP
CAS# 59709-38-5, alanine compound
CAS# 101200-53-7, pyridine compound
Part 2 substances:
CAS# 68583-58-4, HMSSA
CAS# 68937-51-9, OMSSA, treated silica
Part 3 substances:
CAS# 68391-11-7, Pyridine, alkyl derivatives
Part 4 substances:
CAS# 14464 -46-1, cristobalite
CAS# 14808-60-7
Part 5 substances:
CAS# 133-86-4, Carbon black
Reporting is required if 100 kg or more of part 1, 2, or 3 substances were manufactured or imported in 2006; or if more than 1000 kg were used in a product.
Reporting is required if 100 kg of part 4 or 5 substances were manufactured or imported of use in a residence; of if 1000 kg were used in a product for use in a residence. Reporting is not required if used in a product not available for inhalation or if there is < 5% respirable silica in the product.
Complete details and reporting forms are found at the following link: http://www.gazette.gc.ca/rp-pr/p1/2009/2009-12-26/pdf/g1-14352.pdf
January Regulatory Report for CSSA
Canada Gazette I of January 30, 2010 presented the assessment of the 16 chemicals identified in the Batch 8 challenge substances. Of these 4 chemicals were proposed to be added to Schedule I, $ removed from the DSL, and 6 found to not meet the CEPA toxic requirements:
1. CAS # 79-46-9, 2-nitropropane would be added to Schedule I
2. CAS # 88-72-2, 2-nitrotoluene would be added to Schedule I
3. CAS # 17540-75-9, DTBSBP would be added to Schedule I
4. CAS # 72102-55-7, MAPBAP would be added to Schedule I
The following were not found to be in use in Canada and removed from the DSL. Further assessment would be required if used at a later date:
CAS # 626-39-1
CAS # 944-61-6
CAS # 65140-91-2
CAS # 68551-44-0
The following were assessed and found not to meet the criteria for CEPA toxicity and no further action will be taken at this time:
CAS # 75-52-5, Nitromethane
CAS # 139-13-9, NTA
CAS # 2215-35 -2, zinc BDBP
CAS # 70331-94-1, benzene propanoic acid ester
CAS # 75768-65-9, PTPTT
CAS # 25013-16-5, BHA
There is a 60 day comment period for these assessments. Complete details for the assessment may be found at the following link: http://www.gazette.gc.ca/rp-pr/p1/2010/2010-01-30/pdf/g1-14405.pdf
In the Canada Gazette of Jan.20/10 3 aluminum salts were found to not meet the CEPA toxic requirements with no further action to be taken. These are:
CAS # 7446-70-0, Aluminum nitrate
CAS # 13473-90-0, Aluminum sulphate
CAS # 10043-0103, Aluminum chloride
Details are found at: http://www.gazette.gc.ca/rp-pr/p1/2010/2010-01-23/pdf/g1-14404.pdf
February CSSA Regulatory Report
In response to the Batch 6 challenge substances, on the basis of carcinogenicity, it is proposed that Benzyl chloride be added to CEPA Schedule 1 Toxic Substances List. Benzyl chloride is an intermediate used in the production of benzalkonium chloride that in turn is used in sanitizers , I & I cleaners and skin antiseptics and may be present in these products as a residual. CSSA members should be checking their MSDSs for levels of this residual in their raw materials. Controlling a residual may present a challenge for the manufacturers.
Schedule 1 of the Hazardous Products Act is proposed to be amended to align with the US regulations on lead containing paints. A reduction from 600 mg/kg to 90 mg/kg is proposed. Particular targets are coated materials to which children may be exposed, toys, furniture, etc.
Complete details are found at the following link: http://www.gazette.gc.ca/rp-pr/p1/2010/2010-02-27/pdf/g1-14409.pdf
CSSA Regulatory Report May 2010
Of the 14 substances in Batch 7 of the Chemical Challenge lists, 3 chemicals were found to meet the “CEPA toxic” criteria:
Michler’s Ketone, CAS # 90-94-8, used in inks and colorants
2-Butanone Oxime, CAS # 96-29-7, a paint ingredient and corrosion inhibitor
n-butyl glycidyl ether, CAS # 2424-08-6, used in epoxy resins
were proposed additions to the List of Toxic Substances, CEPA Schedule I. Under law proposed regulations for these chemicals must be in place by March 2012. Complete details are found in Canada Gazette I , May 1,2010. http://www.gazette.gc.ca/rp-pr/p1/2010/2010-05-01/pdf/g1-14418.pdf
Ten chemicals confined to on-site use in the petroleum industry were found to have toxic properties but with little potential for exposure there would be no further action at this time. However if new applications were to occur a Significant New Activity notification would be required. It is unlikely that any of these chemicals are used by our members but details may be found in the Canada Gazette I, May 29/10 http://www.gazette.gc.ca/rp-pr/p1/2010/2010-05-29/pdf/g1-14422.pdf
