The reporting of chemical use, due later this year, will be the third inventory update (IU) (since 2009) of Canada’s Chemicals Management Plan (CMP). The IU is conducted in an on-going, cyclical manner, with reporting to the government every four years.
Previously, Health Canada collected information on approximately 550 substances in 2009 and another 2,700 in 2012. In 2017, the IU will collect information on approximately 1,500 chemicals and polymers.
The good news is there is an online reporting tool, and Environment and Climate Change Canada has provided detailed information on their website. Beyond this “good news,” it’s fair to say that, if this applies to your company, and depending to what extent it applies, you may be spending some time between now and the reporting deadline of July 17, 2017, preparing to comply with the CMP requirements (see “Guidance for responding to the Notice with respect to substances included as part of the 2017 Inventory Update“).
Chemicals Management Plan
The Chemicals Management Plan (jointly administered by Environment and Climate Change Canada and Health Canada) was created in 2006 by the Canadian Government. The CMP “…assesses environmental and human health risks posed by chemical substances, and develops and implements measures to prevent or manage those risks.”
Commercial & Consumer Products in the Third IU
The list of reportable substances for the 2017 IU (applicable to those who manufacture or import specified chemicals: See 3.4 Reportable Activities) are found in “Schedule 1” of the Notice and is divided into four separate parts. You can find the complete list on Environment and Climate Change Canada’s website. Note that you can download the file in an Excel document which may be helpful in your evaluation process.
- Part 1 contains 219 substances
- Part 2 contains 26 substances
- Part 3 contains 507 substances
- Part 4 contains 678 substances
Figuring out if and how reporting applies to your company can be challenging. If you look at 3.4.3 “Import of Mixtures, Products, and Manufactured Items,” you will see a list of common commercially-used products. This list includes paints and coatings, ink toners and colourants, cosmetics and personal care products, cleaning liquids, gels or sprays, and adhesives and glues.
Environment and Climate Change Canada provides a reporting flowchart for each of the four parts (above). This could prove helpful in figuring out if the reporting applies to your company. See Figures 1-3 on the website.
As you consider the potential applicability of the third IU to your facility, you will need to consider (among other parameters) the following: 1) potential exclusions, 2) calendar-year use, 3) type of activity, and 4) quantity and concentration.
The list of regulated activities, exemptions, and distinctions of what is and is not regulated is lengthy, and you will need to carefully consider your specific operations.
What Information Do You Need to Submit?
If this applies to your company, you will be required to provide information that your company possesses or to which you may be reasonably expected to have access. For manufacturers, this can include formulations that may require working with your vendors (sooner than later) to begin to develop your data.
Again, this report is due July 17, 2017, at 3 pm (Eastern Time). Depending on your particular operations, number of regulated chemicals your company is using, and the number of facilities you may have, this deadline may or may not be a concern to you.
If you need assistance with your CMP or other environmental related issues, please contact me at (cpare@dragun.com) at 519-979-7300, ext. 114.