Health Canada, the supplier is required to reference the claim for exemption in lieu of disclosing the true concentration or true concentration range of the ingredient. This does not mean, however, that a company can simply use any concentration range they wish on their documents. They need to ensure their “masked” concentration range does not alter the overall hazard classification of their mixture: Where the ingredient concentration is the subject (or part of the subject) of the claim for exemption, a replacement range should be provided, as a best practice, in lieu of the true concentration or the true concentration range, subject to the following conditions: When a replacement concentration range is used on the SDS, the hazard classification must be accurate for the true concentration or the true concentration range and the replacement concentration range; and All other information provided on the SDS must be equally reflective of the true concentration or true concentration range and the replacement concentration range (e.g., the true concentration and true concentration range must be contained within the replacement concentration range). 2) Canadian supplier identifier The second item that caught our attention is the need for a “Canadian supplier identifier” on both the product label and SDS. A question we are often asked at Nexreg is “What if our company has no operations in Canada?” The guidance document addresses it as follows: The name, address and telephone number of a Canadian manufacturer or Canadian importer are required to appear on the label of any hazardous product that is sold in or imported into Canada and is intended for use, handling or storage in a workplace in Canada. However, where a hazardous product is sold by a Canadian distributor, the distributor may provide his own name, address and telephone number on the label and SDS in lieu of the name, address and telephone number of the Canadian manufacturer or Canadian importer. Furthermore, a Canadian importer can retain the name, address and telephone number of the foreign supplier on the label and SDS if the hazardous product is imported only for the importer’s own use… We expect this to cause headaches for many U.S. aerosol manufacturers, as the only “Canadian” entities they deal with are distributors. However, they deal with dozens, if not hundreds, of different distributors in Canada, which theoretically would require them to have dozens, if not hundreds, of different versions of their SDS and product labels. Given the financial and logistical costs such a scenario would create, U.S. companies will need to determine what information they will list as the “Canadian supplier identifier,” and have only until the end of May to make this determination. This only scratches the surface; at 542 pages, the Guidance document contains a wealth of information. If your company sells any product into Canada, I would highly recommend you obtain a copy. SPRAY March 2017 Spray 33
Spray March 2017
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