Page 27

Spray September 2016

September 2016 Spray 27 that measures are in place so that ordinary consumers cannot purchase the product, including at specialty retailers and online. The product must only be available for purchase by workplaces. There is no 98/2 or 90/10 rule in Canada allowing for some sales of workplace labeled products to consumers. If there is a single sale to a consumer, it must be labeled as a consumer product. No exceptions. Tung Oil products recalled for lack of flammability warnings On June 16, Health Canada issued a full public recall for ten different tung oil products, each in three different container sizes, marketed by SamaN. These products lacked the proper flammability warning statements and symbols. In the words of Health Canada, the “product is classified as spontaneously combustible and a rag with the product on it can catch fire on its own, with no outward flame source.” Flammability is the number one source of recalls for consumer chemicals in Canada. As such, we advise all of our clients to do their due diligence when it comes to their labels, and ensure they have the necessary flammability data, should Health Canada come asking questions. Liquid Plumr products recalled for lack of childproof caps What is the second most common source of recalls for consumer chemicals in Canada? A lack of child-resistant containers. Two Liquid Plumr products were recently the source of public recalls, with each selling more than one million units in Canada between 2012 and 2016. Under the CCCR, 2001, products that are classified under the subcategory of “toxic” require child-resistant containers, with two exceptions. The first exception is of particular importance to aerosol companies: “a spray container that cannot be opened and that disperses the product as a mist.” The “cannot be opened” reference is of utmost importance here; the exemption does not apply to products that can be opened, such as some types of pump containers. If your company is selling aerosol products under the subcategory of “toxic,” please ensure that it means the twin requirements of “a spray container that cannot be opened” and “disperses the product as a mist.” Given that this is a highly enforced category, the potential for public recall is high for non-compliant companies. The last thing anyone needs is a full public recall, so make sure you’ve done your homework! SPRAY


Spray September 2016
To see the actual publication please follow the link above