Difference between revisions of "CCCR Very Flammable Products"

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==CCCR 2001: Section 53: Prohibition and exceptions==
 
==CCCR 2001: Section 53: Prohibition and exceptions==
 
The advertising, sale or importation of a flammable product that is classified in the sub-category "very flammable" under section 48 is prohibited unless the product is set out in column 1 of the table to this section and meets the conditions set out in column 2.
 
The advertising, sale or importation of a flammable product that is classified in the sub-category "very flammable" under section 48 is prohibited unless the product is set out in column 1 of the table to this section and meets the conditions set out in column 2.
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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:''
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''Spray containers that exhibit a flashback are not prohibited if they meet section 53. However, this exception does not apply to products classified by the other "very flammable" criteria, such as spray containers that have a flame projection of 100 cm or more, or that contain a liquid with a flash point of less than -18°C.''
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''Clearer wording will lead to the appropriate restriction of very flammable products. The proposed text for item 2 to the table to section 53 (above) reflects this amendment.''
  
  
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==CCCR 2001: Section 49, Subsection 2: Flammable liquid in a refillable spray container ==
 
In the case of a liquid flammable product in a refillable spray container, the person responsible must
 
  
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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:''
  
(a) determine both the product’s flash point, in accordance with section 50, and its flame projection and flashback, in accordance with section 52; and
 
  
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''The exception for labelling on permanently attached fuel containers is not consistent. At present, the exception applies to fuels classified as "toxic", "harmful" and "very flammable", such as gasoline. However, fuels that are classified as "flammable" or "combustible", such as propane, ethanol or kerosene, would need to be labelled.''
  
(b) classify the product in the most flammable sub-category of the applicable sub-categories as determined under items 3 and 7 of the table to subsection (1).
 
  
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''The amendment would exempt permanently attached fuel tanks from all CCCR-2001 requirements. This exception would be included in subsection 2(2). Subsequent deletions would occur in sections 39 and 53.''
  
  
==CCCR Reference Manual - Sections 48 and 49==
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''The table to section 53 of the Regulations is replaced by the following:''
Health Canada's CCCR reference manual for sections 41 and 42 is available at: [http://www.hc-sc.gc.ca/cps-spc/pubs/indust/cccr-2001-rpccc/ref_man/sec-48-article_e.html CCCR Reference Manual, Sections 48 and 49].  One of the important points they note is as follows:
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==CCCR 2001: Section 53: Table - Prohibition and exceptions (Amended)==
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<table border="1">
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<tr>
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<th scope="col" class="align-bottom" style="border-bottom:1px solid #000000; border-top:1px solid #000000;" width="10%">Item<br><br></th>
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<th scope="col" style="border-bottom:1px solid #000000; border-top:1px solid #000000;" width="35%">Column 1<br><br>Chemical product</th>
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<th scope="col" style="border-bottom:1px solid #000000; border-top:1px solid #000000;">Column 2<br><br>Conditions</th>
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</tr>
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<tr>
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<td>1.</td>
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<td>A fuel</td>
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<td>The container of the fuel is separate or detachable from the internal combustion engine, gas turbine or appliance that uses the fuel, and displays the information set out in the table to subsection 54(1).
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</td>
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</tr>
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<tr>
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<td style="border-bottom:1px solid #000000;">2.</td>
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<td style="border-bottom:1px solid #000000;">A product that exhibits a flashback, other than one that is: (a) a liquid that is classified in the sub-category "very flammable"; or
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(b) described in paragraph (a) of item 7 of the table to subsection 49(1).
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</td>
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<td style="border-bottom:1px solid #000000;">The container of the product displays the information set out in the table to subsection 54(1).</td>
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</tr>
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</table>
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'''Fuels classified as "very flammable", such as gasoline, are not prohibited if they meet the requirements of section 53. But the current wording allows "a fuel such as gasoline, ethanol or propane". The reference to ethanol and propane fuels will be removed because these fuels would fall under the "flammable" sub-category. As "flammable" fuels are not prohibited, this amendment is very minor. But the current wording may lead to inappropriate over-labelling of ethanol and propane fuels, if these products were labelled according to the "very flammable" rather than the "flammable" requirements.'''
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'''Clearer wording will lead to less misinterpretation of the labelling for ethanol and propane fuels. The proposed text for the table to section 53 (above) reflects this amendment.'''
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==CCCR Reference Manual - Section 53==
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Health Canada's CCCR reference manual for section 53 is available at: [http://www.hc-sc.gc.ca/cps-spc/pubs/indust/cccr-2001-rpccc/ref_man/sec-53-article_e.html CCCR Reference Manual, Section 53].  One of the important points they note is as follows:
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"The flash point for acetone is often reported as -18°C. The Product Safety Laboratory has tested various brands of acetone available for consumer use. The test results indicate that the flash points of these products were above -18.0°C. Hence these products were not classified as very flammable. However, the results were so close to the classification limit, that the confidence intervals for some products included values below -18°C. It is the responsibility of the manufacturer or importer of acetone that is destined for consumer use to ensure that their products have a flash point of -18°C or greater."
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==CCCR Technical Amendments - Section 53==
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There are a number of references to section 53 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:
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3. Fuel Containers
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The exception for labelling on permanently attached fuel containers is not consistent. At present, the exception applies to fuels classified as "toxic", "harmful" and "very flammable", such as gasoline. However, fuels that are classified as "flammable" or "combustible", such as propane, ethanol or kerosene, would need to be labelled.
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 +
 
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The amendment would exempt permanently attached fuel tanks from all CCCR-2001 requirements. This exception would be included in subsection 2(2). Subsequent deletions would occur in sections 39 and 53.
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''The table to section 53 of the Regulations is replaced by the following:''
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 +
 
 +
 
 +
 
 +
<table border="1">
 +
<tr>
 +
<th scope="col" class="align-bottom" style="border-bottom:1px solid #000000; border-top:1px solid #000000;" width="10%">Item<br><br></th>
 +
 
 +
<th scope="col" style="border-bottom:1px solid #000000; border-top:1px solid #000000;" width="35%">Column 1<br><br>Chemical product</th>
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<th scope="col" style="border-bottom:1px solid #000000; border-top:1px solid #000000;">Column 2<br><br>Conditions</th>
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</tr>
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<tr>
 +
<td>1.</td>
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<td>A fuel</td>
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<td>The container of the fuel is separate or detachable from the internal combustion engine, gas turbine or appliance that uses the fuel, and displays the information set out in the table to subsection 54(1).
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</td>
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</tr>
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<tr>
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<td style="border-bottom:1px solid #000000;">2.</td>
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<td style="border-bottom:1px solid #000000;">A product that exhibits a flashback, other than one that is: (a) a liquid that is classified in the sub-category "very flammable"; or
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(b) described in paragraph (a) of item 7 of the table to subsection 49(1).
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</td>
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<td style="border-bottom:1px solid #000000;">The container of the product displays the information set out in the table to subsection 54(1).</td>
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</tr>
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</table>
  
  
"The CCCR, 2001 criteria for gases are exactly the same as those for workplace chemicals under the requirements of WHMIS Division 1 of Class B (flammable gases).
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4. Very Flammable Fuels
  
  
For liquids, the "flammable" classification has the same limit as WHMIS Division 2 of Class B (flammable liquids), however WHMIS does not distinguish a "very flammable" subcategory. The sub-category "very flammable" is intended for products which are too hazardous to be routinely made available to consumers who lack the specialized knowledge and training to use such products. The average household does not have in place the engineering controls necessary to react to the hazards posed by these products. The upper flash point criteria for the "combustible" sub-category harmonizes with the Transportation of Dangerous Goods Regulations, but the WHMIS criteria for Division 3 of Class B (combustible liquids) sets the upper limit at 93.3°C, which is inappropriate for household conditions. Temperatures of 93.3°C, while being encountered in industrial settings, would rarely be met in the consumer environment.
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Fuels classified as "very flammable", such as gasoline, are not prohibited if they meet the requirements of section 53. But the current wording allows "a fuel such as gasoline, ethanol or propane". The reference to ethanol and propane fuels will be removed because these fuels would fall under the "flammable" sub-category. As "flammable" fuels are not prohibited, this amendment is very minor. But the current wording may lead to inappropriate over-labelling of ethanol and propane fuels, if these products were labelled according to the "very flammable" rather than the "flammable" requirements.
  
  
With respect to solids, the CCCR, 2001 are not harmonized with WHMIS Division 4 of Class B (flammable solids).
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Clearer wording will lead to less misinterpretation of the labelling for ethanol and propane fuels. The proposed text for the table to section 53 (above) reflects this amendment.
  
  
For spray containers, WHMIS classifies aerosol containers according to the same flame-projection test in Division 5 of Class B (flammable aerosols), but not pump-spray containers. Furthermore, WHMIS does not distinguish a "very flammable" subcategory for aerosol sprays.
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5. Spray Containers that have a Flashback
  
  
Finally, the criteria for spontaneous combustion in the CCCR, 2001 is also included in WHMIS Division 6 of Class B (reactive flammable materials)."
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Spray containers that exhibit a flashback are not prohibited if they meet section 53. However, this exception does not apply to products classified by the other "very flammable" criteria, such as spray containers that have a flame projection of 100 cm or more, or that contain a liquid with a flash point of less than -18°C.
  
  
==CCCR Technical Amendments - Sections 48 and 49==
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Clearer wording will lead to the appropriate restriction of very flammable products. The proposed text for item 2 to the table to section 53 (above) reflects this amendment.
There are no references to section 48 or section 49 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]
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==Canadian Goverment Links==
 
==Canadian Goverment Links==
*[http://www.hc-sc.gc.ca/cps-spc/pubs/indust/cccr-2001-rpccc/ref_man/sec-48-article_e.html CCCR Reference Manual, Sections 48 and 49]
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*[http://www.hc-sc.gc.ca/cps-spc/pubs/indust/cccr-2001-rpccc/ref_man/sec-53-article_e.html CCCR Reference Manual, Section 53]
 
*[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]
 
*[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]
  

Revision as of 11:55, 6 January 2008

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