Hazardous Substance Assessments (HSAs). Can we expect more to come?
By: Kirsten Alcock, Manager of Product Safety, email
Last year at the Society for Chemical Hazard Classification (SCHC) conference in Washington DC, Kim Godard and Véronique Lalonde of Health Canada gave an update of where the Globally Harmonized System (GHS) stands in Canada. With this information, they advised that Health Canada is looking into providing “Hazardous Substance Assessments” for commonly used chemicals in Canada. On January 22, 2020, of this year, Health Canada provided assessments on five chemicals.
The following chemicals have a Hazardous Substance Assessment:
- Adipic Acid
- Diethylene Glycol Monomethyl Ether
- n-Butyl Acetate
- Sodium Hydroxide
They described these Hazardous Substance Assessments (HSAs) as technical documents that describe the GHS classification of a chemical and place them into the categories outlined in the Hazardous Products Act (HPA). In accordance with the regulations in Canada, they are planning on providing HSAs with detail to advise on which of the 12 health hazards a chemical falls into as well as the 20 physical hazards.
Yesterday at the SCHC Virtual Conference, Lynn Berndt-Weis advised that Health Canada is continuing to look into providing more HSA’s for Canadian companies. We were advised that we would not receive any further HSAs in 2020 but it is something that they will be providing in the near future.
When asked if Canadian companies can make suggestions on chemicals to look into for HSAs in the future, we were advised that Health Canada would accept nominations of chemicals that Canadians are concerned about. If there is a chemical that you’ve been having issues assessing, we were advised that we could send an email to Health Canada to let them know. They may look into adding that chemical in the future. We suggest contacting them directly. It is important for Health Canada to know what Canadian companies are having issues with.
The HSAs are expected to serve as an information source that can be used by suppliers or employers to help classify their own products and help with Health Canada inspection reviews.
They also advised that the HSAs will not represent a classification decision for a specific product. Ultimately you are responsible for providing the proper classification for your product as a whole. If there is more recent data available, one is expected to use this instead of the HSA. Should you have test data for your product as a whole, this will always trump the HSA information. According to Health Canada, “It is the responsibility of the supplier to ensure the accuracy, sufficiency, and reliability of their hazardous product classifications”.
The HSA breakdown is as follows:
- Health Hazards
- Physical Hazards
- Regulatory and Other Information
Health Canada plans to establish a growing online repository of the HSAs in the future so look out for them. If you have questions about the data provided by Health Canada, they encourage you to contact them:
Teletypewriter: 1-800-465-7735 (Service Canada)
If you need help with your classifications for those that aren’t classified by Health Canada, we do offer a raw material classification service to our clients. Many of our clients have internal sources for creating SDSs but the raw materials themselves need to be classified properly first before you can do your assessment for your product as a whole. Please feel free to contact us for further information on our consulting services and how we can help keep your SDSs and labels in compliance.
Kirsten Alcock, B.Sc. (Hons)
Manager, Product Safety Group
Dell Tech has provided professional, confidential consulting services to the chemical specialty
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