Cyclical Enforcement Projects – What has Health Canada been targeting?
By: Kirsten Alcock, Manager of Product Safety, email
The Consumer Product Safety Program of Health Canada routinely performs planned national inspections which are referred to as Cyclical Enforcement (CE) Projects. As part of Health Canada’s compliance verification mandate, the program is currently conducting projects in which a representative from Health Canada will contact consumer chemical product manufacturers and importers to inspect their classification records. These impact every company that imports or manufactures hazardous chemicals within our borders.
Health Canada is responsible for the administration and enforcement of the Canada Consumer Product Safety Act (CCSPA) and its regulations. The CCPSA provides the authority to protect the Canadian public by addressing and/or preventing dangers to human health or safety that are posed by the usage of consumer products within Canada. The Current List for cyclical enforcement can be found here.
In 2019-2020, there was a very large decrease in the amount of products undergoing cyclical enforcement – likely due to COVID-19. The most recent enforcements were involving infants: Drawstrings on children’s upper outerwear, pacifiers and infant feeding bottle regulations.
When it has been determined what the cyclical enforcement for the year may be, Health Canada will issue a meeting request with your company and advise which products they will be requesting samples for. In order to prepare for a meeting, your company may need the CCCR Checklist records for these hazardous products. The checklist itself requires knowledge of the packaging, toxicology, the physical hazards, which classifications are applicable, etc. If test data exists for the product as a whole, we would suggest providing this documentation to the inspectors as well. Be sure you are using a method that Health Canada currently accept. Although there are many new invitro test methods available, Health Canada has NOT accepted all of them. Note that the more complete the package, the fewer questions Health Canada will need to confirm with you.
The CCCR checklists can be very daunting to prepare however that is where Dell Tech comes in. We are experts in the preparation of CCCR Checklists. We have prepared hundreds of these documents over the years for a range of products from your regular household cleaners to the fragrances you use within your homes. In order to prepare for your inspections, you will need to have these checklists created. If you need help with this, do not hesitate to contact us. We can provide you with a quote and a turn-around time on their preparation.
Get prepared ahead of time! Have those checklists ready to provide to the inspector.
For more information on our services:
Kirsten Alcock, B.Sc. (Hons)
Manager, Product Safety Group
Dell Tech has provided professional, confidential consulting services to the chemical specialty
industry in Canada, the USA, Europe, and Asia for the last 40 years.
Contact us today for more information.