As we mentioned in Health Canada Cracking Down on Non Compliant Labels a number of products have been recalled for non-compliance with CCCR-2001 and the cosmetics regulations.  We have identified 22 sets of products that have been recalled for label violations this year (5 since our last post):

• Nov. 2008: 7 spray home fragrances (lacking flammability and corrosive warnings)
• Nov. 2008: Spray mist skin care product (flammability)
• Nov. 2008: Self-tanning mist spray (flammability)
• Nov. 2008: Spray foam hair-care product (flammability)
• Oct. 2008: Children’s spray silly string (explosive warning)
• Oct. 2008: Crack filler for asphalt (lacking necessary symbols)
• Oct. 2008: Tanning mist (flammability)
• Oct. 2008: Hair spray (flammability)
• Sep. 2008: Spa chemicals (lack of child proof cap)
• Sep. 2008: Paint solvent (lack of child proof cap)
• Sep. 2008: Film barrier lubricant (flame projection too long)
• Sep. 2008: Stainless steel polish aerosol (flammability)
• Sep. 2008: Carburetor cleaner (flame projection too long)
• Sep. 2008: Deodorant (flammability)
• Sep. 2008: Grout (lack of child proof cap)
• Aug. 2008: Spray truck bed coating (flame projection too long)
• Aug. 2008: Aerosol engine cleaners (flammability)
• Jul. 2008: Spray foundation (flammability)
• Jul. 2008: All purpose cleaner (flammability)
• Jul. 2008: Aerosol hair product (flammability)
• May 2008: Home fragrances (flammability)
• Apr 2008: Leather cleaner (child proof cap)

Note: 16 of the 22 product sets are packaged in pressurized spray/aerosol containers.  If you are have any doubts about the compliancy of your chemical products, please do not hesitate to contact us. More information about our label review services can be found here:

• Canadian Consumer Label Review
• Canadian Industrial Label Review
• Canadian Cosmetic Product Label Review

We can be contacted at:

Nexreg Toll Free: 1-866-361-3032
E-mail:info@nexreg.com

Relevant Nexreg Compliance Links: Nexreg, CCCR Consumer Label Reviews, WHMIS MSDS Authoring.

Excellent advice here from PlantServices.com on how to improve workplace safety, reduce liability and reduce the chances of running afoul of inspectors:

To begin, generate a list of hazardous materials already on-site. Compare the line items with entries in your material safety data sheet (MSDS) library. Review them to determine if they’re adequate, and request updates if necessary. Because dock and warehouse workers typically don’t handle chemicals in the same way that production workers do, hazard communication training might not need to be as detailed, but because there is potential for exposure, it should not be overlooked.

Educate anyone with authority to make purchases to request the MSDS for any new hazardous materials that will be brought on-site before they arrive. Establish a system to document or communicate them to areas that might potentially come in contact with the hazard. Electronic files are a convenient way to do this, but having hard copies also will suffice. By requesting MSDS earlier, everyone can become educated about new hazards in advance of their arrival.

In some facilities, it might be prudent for a safety officer or safety team to review and approve new materials before issuing a purchase order. In others, the receiving dock crew might be a first line of defense if it’s taught not to accept new items for which there is no MSDS. Establishing a protocol — whatever it might be — helps ensure that nothing unexpected arrives.

Click on the above link for more information.

Relevant Nexreg Compliance Links: Nexreg, OSHA MSDS Authoring, MSDS Authoring.

New herbicide law from the Canadian province of Alberta:

The Alberta government says farm chemicals won’t be affected in its plan to ban the sale of combination herbicide-fertilizer products for home and garden use.

Environment Minister Rob Renner announced Thursday that herbicide-fertilizer combinations, commonly known as “weed-and-feed” products, will no longer be sold in Alberta starting Jan. 1, 2010.

The decision “will not impact the agriculture sector or the landscaping industry since these products are almost exclusively used on homeowners’ lawns,” the province said in a release. And products intended for spot application to weeds will still be available for sale and home use, the province added.

2,4-D, a Group 4 herbicide used in such weed-and-feed products, is “highly mobile” and commonly appears in water downstream of municipalities, the province said, when excess chemical runs off lawns into drainage systems and is deposited into creeks and rivers.

Click on the above link for more information.

Relevant Nexreg Compliance Links: CCCR Label Review, Canadian Cosmetics Label Review, Nexreg.

Indonesia is requiring their exports to pre-register for REACH, according to this article:

The Indonesian Trade Ministry required exporters and producers to pre-register chemical products and other industry-related goods exporting to European Union (EU) markets, an official said.

“If Indonesian exporters don’t do that, they can not export the products. The regulation will be effective starting Dec. 1,” Partogi Pangaribuan, head of chemistry and mining directorate of the ministry told Xinhua by phone on Saturday.

EU imposed a new regulation on foreign exporters, requiring them to follow procedural registration, evaluation, authorization and restriction of chemical products (REACH) under the European Chemical Agency (ECHA).

Click on the links for more information.
Relevant Nexreg Compliance Links: Nexreg, REACH Compliance, EU SDS Authoring.

An article from Poland on the dangers of missing the REACH pre-registration date.  It is in somewhat broken English, but still worth a read:

There is not much time left. December 1st is the deadline to initially register chemical products being traded in the EU in the Reach system. Polish Ministry of Economy warns that companies which have failed to do it so far may have problems with registration of substances they produce or import. Unless they manage to do it in time, they may need to close operations. There are thousands of latecomers. Many small companies did not know they needed to register. Out of at least several thousands companies from Poland which should register products, only 449 actually did it.

Click on the links for more information.  Nexreg has more information on REACH at the following link:

• REACH Compliance Consulting

To speak to a Nexreg representative about how REACH will impact your company, please call or e-mail Nexreg at:

Nexreg Toll Free: 1-866-361-3032
Non-Toll Free: (519)488-5126 (London, ON, Canada)
E-mail:info@nexreg.com

Relevant Nexreg Compliance Links: Nexreg, REACH Compliance, EU SDS Authoring.

BusinessGreen.com on an issue that is not getting nearly enough attention – the EU’s Substances of Very High Concern list:

European businesses are being urged to assess which chemicals they use and attempt to avoid as many potentially hazardous substances as possible, after the European Chemicals Agency last week released its first list of chemicals that could soon be classified as being of very high concern under EU chemicals legislation.

The so-called Candidate List of Substances of Very High Concern features 15 chemicals, including a range of cobalt and arsenic compounds and other toxic and carcinogenic substances.

Under the EU’s Registration Evaluation Authorisation and Restriction of Chemicals (REACH) directive which came into effect last year, suppliers of products that contain any of the chemicals featured on the list are legally obliged to provide information on the chemical to their customers alongside a “safety data sheet”…

“What companies need to realise is that this is essentially a black list, and if they can avoid any of these chemicals they would be advised to do so,” he said, adding that environmental NGOs were likely to use the legislation to make data requests from those firms they suspect of using these chemicals…

“If you think that REACH will only affect big businesses who deal in large quantities of chemical products, then think again,” he said. “If you use chemicals to keep your machinery operating and your premises clean, if you import products like cars or batteries, or if you receive substances containing chemicals through a supplier and use them in an unusual way – then it’s likely you’ll need to take some action under REACH.”

Click on the above link for more information.

Relevant Nexreg Compliance Links: Nexreg, REACH Compliance, EU SDS Authoring.

An important Direct Final Rule from the EPA:

EPA is taking direct final action on the National Volatile Organic Compound Emission Standards for Aerosol Coatings, which establishes national reactivity-based emission standards for the aerosol coatings category (aerosol spray paints) under the Clean Air Act (CAA). In this direct final action, EPA is moving the applicability and compliance dates for aerosol coatings from January 1, 2009, to July 1, 2009. EPA is also making initial notifications required due on the compliance date, as opposed to 90 days in advance of the compliance date…

EPA is publishing this rule without a prior proposed rule because we view this as a non-controversial action and anticipate no adverse comment. The final rule has a provision that allows regulated entities to petition EPA to add compounds to Tables 2A, 2B, and 2C–Reactivity Factors of subpart E, 40 CFR part 59. It is necessary to move the compliance date to allow time to add compounds that are currently used in aerosol coatings, but were not included on the list of reactivity factors in Table 2 of the final rule. Removing the requirement for a 90 day advance submittal of initial notifications will make the aerosol coatings rule consistent with the requirements of other part 59 rules, increasing consistency and clarity for the regulated entities.

Click on the above link for more information.

Relevant Nexreg Compliance Links: OSHA MSDS Authoring, CPSC Consumer Label Reviews, Nexreg.

From Small Times:

The US Environmental Protection Agency (EPA) has issued a Federal Register notice regarding carbon nanotubes (CNTs).

The document gives notice of the Toxic Substances Control Act (TSCA) requirements potentially applicable to CNTs, reminding manufacturers and importers that they must notify EPA 90 days prior to the manufacture or import of new chemical CNTs for commercial purposes, in accordance with TSCA Section 5 regulations for new chemicals at 40 C.F.R. 720.22..

Manufacturers or importers of CNTs not on the TSCA Inventory must submit a premanufacture notice (PMN) (or applicable exemption) under TSCA section 5 where required under 40 CFR part 720 or part 723. In order to determine the TSCA Inventory status of a CNT, a manufacturer may submit to EPA a bona-fide intent to manufacture or import under 40 CFR 720.25.

Click on the above link for more information.

An article from the Toronto Star.  We will be watching closely to see what, if any, actions Health Canada takes:

Twelve national health and environmental organizations are calling on Health Canada to speed up the process it uses to deal with the toxins under the Chemical Management Plan and promote safer alternative products…

They are found in cosmetics such as perfume, hairspray, skin creams and cleansers, or in common household products such as window cleaners, floor care products, pesticides and carpet cleaners.

Among the chemicals targeted by the environmental groups are:

• Pigment Red 3 (2-Naphthalenol) found in nail polish, soap bars, plastic colourants and industrial painting inks;
• DEGME (2-Methoxyethoxy): a solvent found in household paints, pesticides and floor care products, window washer fluids, skin creams, cleansers, hairspray and perfumes;
• 2-MEA (2-Methoxyethanol acetate): found in nail polish, dry cleaning treatments and glues. These three have been placed on Health Canada’s “Cosmetic Ingredient Hot List,” which means their use is being scrutinized, with the possibility of a restriction or ban.

The fourth chemical, not included on the list, is 2-methoxypropanol: It is found in nail polish enamel and remover; hair conditioners and sprays; false eyelash adhesives and removal solvents; and pesticides.

Click on the above link for more information.

Relevant Nexreg Compliance Links: CCCR Label Review, Canadian Cosmetics Label Review, Nexreg.

A useful reminder from BusinessGreen.com:

The government has warned today that large numbers of companies could find themselves in breach of EU chemicals legislation from 1 December if they fail to pre-register any chemical substances they import or manufacture with the European Chemicals Agency (ECA)…

Firms can reduce the cost and hassle of this registration process by pre-registering their chemicals ahead of the 1 December deadline. Those that fail to meet this deadline will have to suspend manufacture or import of their chemicals until the full registration process is completed or risk fines for breaching the directive.

However, while the majority of firms within the chemicals industry are believed to have largely completed the pre-registration processes fears are mounting that other importers of chemicals, such as IT and electronics firms, cleaning companies, hairdressers, construction firms and food manufacturers, are still unaware of the legislation…

“The European Chemicals Agency estimated that 200,000 firms would pre-register chemicals, but the figure now is that around 800,000 firms have already pre-registered,” he explained. “So when it comes to how many should be pre-registered all bets are off – it is safe to believe that there are companies out there that should be pre-registered but won’t be.”

Click on the links for more information.  Nexreg has more information on REACH at the following link:

• REACH Compliance Consulting

To speak to a Nexreg representative about how REACH will impact your company, please call or e-mail Nexreg at:

Nexreg Toll Free: 1-866-361-3032
Non-Toll Free: (519)488-5126 (London, ON, Canada)
E-mail:info@nexreg.com

Relevant Nexreg Compliance Links: Nexreg, REACH Compliance, EU SDS Authoring.