Difference between revisions of "CCCR Application and Apparatus"

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==CCCR Application and Apparatus (Schedule I: Sections 1 and 2)==
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==CCCR Application and Apparatus (Schedule 1: Sections 1 and 2)==
 
The legal text of the regulations in Schedule 1, sections 1 and 2 follow below:
 
The legal text of the regulations in Schedule 1, sections 1 and 2 follow below:
  
==CCCR 2001: Schedule 1, Section 33: Application==
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==CCCR 2001: Schedule 1, Section 1: Application==
 
This test is to be used to determine the flashback and the length of the flame projection of a flammable product enclosed in a spray container.
 
This test is to be used to determine the flashback and the length of the flame projection of a flammable product enclosed in a spray container.
  
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==CCCR Reference Manual - Sections 33 and 34==
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'''Note''': ''In the [http://www.hc-sc.gc.ca/cps-spc/legislation/acts-lois/techni_e.html Proposed Technical Amendments to the Consumer Chemicals and Containers Regulations, 2001] there is the following amendment:''
Health Canada's CCCR reference manual for sections 33 and 34 is available at: [http://www.hc-sc.gc.ca/cps-spc/pubs/indust/cccr-2001-rpccc/ref_man/sec-33-article_e.html CCCR Reference Manual, Sections 33 and 34].  One of the important points they note is as follows:
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"The classification criteria in subsection 34(1) assume that the other ingredients in the product are benign. However, if a product contains ingredients in addition to the substance of special concern that would make the product more hazardous, then the product must be classified into the higher sub-category (see subsection 4(3)). This means that the product will at least be classified according to subsection 34(1) and may be classified into a higher subcategory if other hazardous ingredients are present."
 
  
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''Technical amendments are required to Schedule 1 "Test for Determining the Flashback and the Length of the Flame Projection of a Flammable Product Enclosed in a Spray Container":''
  
==CCCR Technical Amendments - Sections 33 and 34==
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''* There is an inconsistency between the text and Figures 1 and 2 of the testing apparatus. The height of the internal open space should be 45 cm, as indicated in the figures. (Section 2)''
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''* The number of sprays required for pump-spray containers is excessive and time-consuming. For example, it is possible that a test container would need 1200 sprays (not including priming and trial discharges to adjust the flame). As a result, it is conceivable that the product could be used-up before the test is completed.''
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'''Proposed Text:'''
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''Clause 2(a)(iv)(A) of Schedule 1 to the Regulations is replaced by the following:''
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''(A) has an internal open space of 35 cm wide by 45 cm high,''
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==CCCR Technical Amendments - Schedule 1, Sections 1 and 2==
 
There are a number of references to section 34 in the [http://www.hc-sc.gc.ca/cps-spc/legislation/acts-lois/techni_e.html Proposed Technical Amendments to the Consumer Chemicals and Containers Regulations, 2001].  They are as follows:
 
There are a number of references to section 34 in the [http://www.hc-sc.gc.ca/cps-spc/legislation/acts-lois/techni_e.html Proposed Technical Amendments to the Consumer Chemicals and Containers Regulations, 2001].  They are as follows:
  
  
1. A chemical product that contains hydrocyanic acid or its salts, such as sodium cyanide or potassium cyanide, is classified as "very toxic" and is prohibited from consumer sale. These substances have been prohibited from consumer products under the Hazardous Products Act since 1988, and the prohibition was incorporated into the CCCR-2001. However, the Regulations are not consistent between English and French. The French wording correctly reads: "acide cyanhydrique ou ses sels"; the equivalent wording in English would be: "hydrocyanic acid or its salts".
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Technical amendments are required to Schedule 1 "Test for Determining the Flashback and the Length of the Flame Projection of a Flammable Product Enclosed in a Spray Container":
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The CCCR-2001 will be amended to clarify the English text in subsection 34(1).
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* There is an inconsistency between the text and Figures 1 and 2 of the testing apparatus. The height of the internal open space should be 45 cm, as indicated in the figures. (Section 2)
  
Proposed Text:
 
  
The portion of item 5 of the table to subsection 34(1) of the English version of the Regulations in column 1 is replaced by the following: Hydrocyanic acid or its salts
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* The number of sprays required for pump-spray containers is excessive and time-consuming. For example, it is possible that a test container would need 1200 sprays (not including priming and trial discharges to adjust the flame). As a result, it is conceivable that the product could be used-up before the test is completed.
  
  
2. The table to subsection 34(1) contains a list of substances which pose specific hazards to human health, thus requiring special classification. At present, the table to subsection 34(1) does not contain any information pertaining to the 'route of exposure' through which these substances pose a hazard. This will be addressed by adding a new column, "Column 4", to this table called "Route of exposure", which will permit manufacturers/importers to properly label their products for the dangers inherent to these chemical ingredients.
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'''Proposed Text:'''
  
  
3. The units for the LC50 criteria for gases and vapours should be mL/m3, not mg/m3. The toxicity limits that were developed in collaboration with all stakeholders were harmonized with Canadian and other international systems, in order to avoid redundant toxicity evaluations. The recommended limits were expressed in the units of ppm by volume. In the drafting of the CCCR-2001, it was intended to express the units in clear and unambiguous terms. However, the units were inadvertently printed as mg/m3 rather than mL/m3. As a result, the values are no longer harmonized with other systems and the criteria limits do not correspond to the stakeholder recommendations.
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Clause 2(a)(iv)(A) of Schedule 1 to the Regulations is replaced by the following:
  
The difference in units is related to the molecular weight of the substance relative to the molar volume of air. This means that higher molecular weight gases and vapours, such as toluene and xylene, would be excluded from classification when they were intended to be captured, whereas those with a lower molecular weight, such as ammonia, would be inappropriately classified into a higher sub-category.
 
  
The amendment would change all references from mg/m3 to mL/m3 in the tables to subsections 1(4) and 34(4).
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(A) has an internal open space of 35 cm wide by 45 cm high,''
  
  
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==CCCR NexregWiki Links==
 
==CCCR NexregWiki Links==
 
*[[CCCR 2001 Canadian Consumer Chemical Label Compliance]]
 
*[[CCCR 2001 Canadian Consumer Chemical Label Compliance]]
*[[CCCR Toxic Products]]
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*[[CCCR Flashback and Flame Projection]]
  
  

Revision as of 16:27, 6 January 2008

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