Chemical substances in Canada are regulated under the Canadian Environmental Protection Act, 1999. Substances are in one of two groups – existing or new. There are about 23,000 existing or current substances on the Domestic Substance List (DSL).
In 2006, the 23,000 substances of the Domestic Substances List were “categorized” according to the potential risk they posed to human health and the environment. This set the priority by which substances were to be assessed under the Chemicals Management Plan (CMP), beginning with the chemicals that were thought to pose the greatest risk.
Regulating Nanomaterials
What has generally not been assessed is the nanoscale use of the substances on the DSL (Canada has assessed 20 nanomaterials to date). So, Environment Canada and Health Canada recently (February 2015) provided a document, “Proposed Approach to Address Nanoscale Forms of Substances on the Domestic Substance List.”
In general, the February document is designed to inform stakeholders, as well as solicit feedback, about an approach to assess nanoscale forms of substances found on the DSL.
Nanomaterials are increasingly prevalent in manufacturing of everything from cosmetics and coatings to fuel cells and pharmaceuticals. But, little is known about how they may or may not be impacting the environment. And, in fact, the various properties of nanomaterials (electrical, magnetic, optical) can differ from their parent or non-nanomaterial.
According to Environment Canada, “The Department’s current interest mainly lies with determining what potentially unfamiliar or different properties and their effects may be evident in nanomaterials that are not observable in the ‘bulk’ form, and are different from the properties of the individual atoms or molecules.”
According to the agencies, nanoscale means 1 to 100 nanometers. As a point of reference, a human hair is 100,000 nanometers.
Next Steps in Regulating Nanomaterials
So what happens now? In June (2015), Environment Canada and Health Canada intend to conduct an information-gathering survey, as well as conduct workshops for stakeholders to discuss the next steps. However, according to the February 2015 document, Environment Canada and Health Canada are proposing a stepwise approach to addressing nanoscale forms of substances on the DSL.
The proposed approach includes:
1. Establishment of a list of existing nanomaterials in Canada,
2. Prioritization of existing nanomaterials for action, and
3. Action on substances identified for further work.
If this potentially affects you and your company, watch for additional information, including workshops, that should provide you with some more clarity.
If you have any questions relating to environmental compliance, planning, permitting or assessments, please feel free to contact me (cpare@dragun.com) at 519-979-7300, ext 114.