Canada’s New Chemicals
Management Plan (CMP) &
the Occupational Hygienist
Elizabeth Walpac, CIH, ROH
Senior SHE Specialist
Nalco Canada Co.
CMP - Topics Covered
• Scope and Origins of the CMP
• Some current actions taking place
• Items that may be of interest to the
practicing Occupational Hygienist
• Brief comparison with other programs
such as Europe’s REACH and the U.S.
HPV program.
CMP - Overview
• Announced December 8, 2006 by Prime Minister
Stephen Harper, Rona Ambrose, Minister of
Environment and Tony Clement, Minister of
Health
– Plan to take immediate action to regulate chemicals that
are harmful to human health or the environment.
– Make Canada a world leader in assessing and
regulating chemicals used in thousands of industrial and
consumer products
• Establishes a new information baseline that
sets clear priorities for action that are science
based.
CMP – Foundation or Origins
• Canadian Environmental Protection Act
(CEPA)1999 set a goal for the Government of
Canada to sort through or “categorize” all
23,000 ‘existing’ chemical substances
• ‘Existing’ is chemical substances that were in
use in Canada between Jan 1, 1984 and Dec
31, 1986 and mostly referred to as the
Domestic Substance List (DSL)
• 4,300 substances met categorization criteria
CMP – Categorization Criteria
• Inherently toxic to humans or to non-human
organisms as determined by laboratory or
other studies and that might be:
– Persistent (take a very long time to break down)
and/or
– Bioaccumulative (collect in living organisms and
end up in the food chain)
– e.g. PBiT,PiT,BiT
• Substances to which individuals in Canada
have greatest potential for exposure (GPE)
CMP - Key Objectives
• Strengthen CEPA’s coordination with other
federal statutes, including: Hazardous
Products Act, Food & Drugs Act and Pest
Control Products Act.
• Establish Government Accountability:
Enhanced risk communication to Canadians,
Increased research activities
• Strengthen industry’s role by proactively
identifying and safely managing risks
associated with chemicals they produce and
use.
CMP Scope: Sample of what is
Included
• Challenge to Industry – High concern substances
• Significant New Activity Controls (SNACs) Restrictions on re-introduction and new uses
• Rapid Screening of lower risk chemical substances
• Accelerated re-evaluation of older pesticides
• Prohibitions of Substances &Virtual Elimination List
• Regulations to address environmental risks posed by
pharmaceuticals and personal care products
• Petroleum Sector – Unique risk assessment and
management circumstances
• International engagement, monitoring, and research
• Good stewardship of chemical substances
CMP – Some Actions Taking Place
• Challenge to Industry
– 193 chemical substances identified that are
potentially harmful to human health or the
environment that represent the highest priorities
for risk assessment and appropriate controls
(PBiT, GPE)
– Every three months batches of 15-30 substances
are being released to stakeholders
• Rapid Screening
– 1066 substances using worst-case scenario to
determine if further assessment is necessary.
– 312 substances now identified as medium
priorities.
CMP – Industry Challenge
• Mandatory CEPA Section 71 Surveys to
Importers, Manufacturers, and Users of
Chemicals
– No de minimis for concentration, impurities
covered. 100 kg/year trigger for reporting Import &
Manufacture. 1000 kg/year for use.
– Substances are batched in groups of 15-30 and
publicized in Canada Gazette Part 1.
– Third Batch already released (examples of
substances include: 2-Methoxyacetate and
Diethylene Glycol Monomethyl Ether)
CMP – Section 71 Surveys
Mandatory Data collected includes:
• Use Patterns for the Substance
• Volumes Released or Transferred to off-site waste
management facility data
• Procedures to prevent/minimize release to
environment or potential exposure to Canadians,
– Handling procedures to minimize
dusts/vapours/spills
– Clean-up procedures & Emergency planning
– Regulatory/voluntary agreements in place to
minimize releases
CMP – Section 71 Surveys
Mandatory Data collected includes (cont’d):
• Studies or data that measure effect of these
procedures/policies
• Studies or data that measure the exposure
to the substance of individuals in Canada
– specify indoor air (i.e Occupational
Hygiene type Reports) in the guidelines to
most recent survey
CMP Industry Challenge Voluntary Survey?
Management/Stewardship Information
• Occupational Health and Safety Regime
• Emergency Plans
• ISO 9001/14000 Certification
• Process Safety Management
Potential Actions
• Substance Replacement/Substitution
• Spill and Leak Prevention and Minimization
• Some now being asked for in the Section 71
Survey
CMP – Industry Challenge Chemical
Substance Profiles
 Government Publishing of Chemical Substance
Profiles for Industry Challenge Substances
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–
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–
–
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–
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Exposure Information based on use
Trade Names
Industrial and Consumer Uses
Health Related Hazard Information
Uncertainties
Physical and Chemical properties
Releases, Fate and Presence in the Environment
Evaluation of Persistence, Bioaccumulative, and
Inherently Toxic properties
CMP – State of Science Reports
 Government Publishing of State of Science Reports examples of Data included:
• Identity, uses and Sources of Exposure
• Exposure Assessment and Hazard
Characterization
• Estimates of exposure by inhalation & dermal
contact to substances when used by
individuals (i.e. Hygiene Modeled Data)
• Risk Evaluation
• Conclusion for Human Health
• Summary of Health Effects
 Will be used for Risk Assessment
CMP – and the Occupational
Hygienist
• Benefits
– More information will be publicly available
for Toxicological data
– Opportunity to improve MSDSs,
Occupational Hygiene Programs.
• Contributions that Hygienist can make:
– Share exposure data with Government
(mandatory under Section 71, otherwise
voluntary)
– Share expertise on control measures, etc.
CMP – Some Brief Comparisons with
other Global Programs
EU’s REACH
• Registration of Manufactured or Imported
Chemical substances
• Evaluation of the Information supplied and safety
in the use of selected substances (risk-based)
• Authorization for CHemicals of High concern
(e.g. carcinogens, persistent and bioaccumulative)
Aim is substitution where possible.
REACH and the Occupational
Hygienist
• Chemical Safety Reports to be attached to
SDS (MSDS)
– One requirement - Exposure Assessment which
contains:
•
•
•
•
•
Exposure Scenario
Concentration of Substance in Product, exposure limits
How Handled
Duration and Frequency of Use
Must be Use Specific (i.e.use of substance in paint
production)
• Recommended Risk Management Measures (PPE , etc.)
• Based on Assessment, a use may not be
allowed.
U.S. HPV Program - What is it?
• Ongoing challenge program to make Health and
Environmental effects data publicly available on
chemicals produced or imported in the U.S. in the
greatest Quantities
• Origins – Gaps in basic data to understand &
characterize potential hazards associated with
High Production Volume (HPV) chemicals
• Chemical manufactures and importers agreed to
sponsor and collect basic hazard data
• September 2007 - Release of first set of
Chemical Hazard Characterizations.
EU REACH, CMP, and U.S.
HPV – A connection
• Deal with ‘existing’ substances
• Work to Assess Risks of Chemicals
• Include measures to obtain existing data to
minimize need for additional testing
• U.S. & Canada plan to collaborate timing of
assessments to some extent. REACH
submitters/evaluators can benefit from early
U.S. and Canadian work. REACH
registration dossiers can help follow-up
testing needs for U.S. HPVs
• All will likely lead to Increased Control of
Chemicals
CMP, U.S. HPV, & REACH links
• CMP:
http://www.chemicalsubstanceschimiques.gc.ca/en/index.h
tml
• CMP State of Science Reports http://www.hcsc.gc.ca/ewh-semt/pubs/contaminants/index_e.html Click
on Existing substances under Screening Assessment
Reports
• U.S. HPV: http://www.epa.gov/hpv/
• REACH: http://ecb.jrc.it/reach/
• REACH/Hygienist: http://www.bohs.org click hot topics,
REACH, & The Role for Occupational Hygienists
• OECD ChemPortal: http://webnet3.oecd.org/echemportal/
THANK YOU!
Elizabeth Walpac, CIH, ROH
Senior SHE Specialist
Nalco Canada Co.
905-632-8791 ext 224
email: ewalpac@nalco.com