The Notice of Intent to add a Significant New Activity requirement for Calcium 2-ethylhexanoate) CAS RN 135-51-6)was published on December 15, 2018: http://gazette.gc.ca/rp-pr/p1/2018/2018-12-15/html/notice-avis-eng.html 

CPCA recently inquired about the status of  the SNAc Order for CAS RN 136-51-6  to be published later this year or in the first part of 2020 will likely target the same activities that were indicated in the previous SNAc NOI, notably:

  • To address human health concerns, the Order would target the use of the substance in consumer products to which the Canada Consumer Product Safety Act (CCPSA) applies and in cosmetics within the meaning of section 2 of the Food and Drugs Act.
  • For the manufacture of such products, notification would be required when the concentration of the substance in the product is greater than 0.1% by weight, other than in a paint or coating that would require notification if the concentration of the substance is greater than 0.5% by weight.
  • For any other activity related to consumer products and cosmetics other than a paint and a coating, notification would be required when the concentration of the substance in the product is greater than 0.1% by weight, and the total quantity of the substance in the product that is used during a calendar year is greater than 10 kg.
  • For any other activity in relation to a paint or coating, notification would be required when the concentration of the substance in the paint or coating is greater than 0.5% by weight and the total quantity of the substance in the product that is used during a calendar year is greater than 10 kg.

The proposed SNAc only applies to consumer products and not those for professional use only.

Therefore, with respect to consumer paints and coatings, notification would not be required if the concentration of the substance is less than and equal to 0.5% or being used in a quantity less than 10 kg during a calendar year.

See the example given in the past NOI regarding the applicability of the order for consumer products (we can assume it is the same for paint and coatings)

The manufacture of consumer products and cosmetics that contain the substance would not be subject to the Order if the concentration of the substance in the product is less than 0.1% by weight. Any other activity involving the use of the substance in a consumer product or cosmetic would not be subject to the Order if the total quantity of the substance involved in the activity is 10 kg or less in a calendar year. For activities involving more than 10 kg of the substance in a calendar year, the Order would not apply if the concentration of the substance in the consumer product or cosmetic involved in the activity is less than 0.1% by weight.

 

 

September 16, 2019

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