Hazardous Substance Assessments – What is the Status?
By: Kirsten Alcock, Manager of Product Safety, email
On January 22, 2020, Health Canada advised that they have performed assessments on five chemicals on the Hazardous Substance Assessments (HSA). They are providing these assessments for common chemicals in use within Canada. The information about Hazardous Substance Assessments can be found here.
The following chemicals currently have a Hazardous Substance Assessment:
- Adipic Acid
- Diethylene Glycol Monomethyl Ether
- n-Butyl Acetate
- Sodium Hydroxide
They described these Hazardous Substance Assessments as technical documents that describe the Globally Harmonized System (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.
The HSAs will provide transparency as to how Health Canada classifies certain chemicals under the HPA. 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. Due to COVID-19, they have been slowed in their journey to provide more to us. I have been advised to expect more in the future but it is not a priority right now. The health and safety of Canadians is very important to Health Canada and their priorities are elsewhere.
If you have questions about the data provided by Health Canada, they encourage you to contact them. If there are chemicals you believe should be added to the list, you are encouraged to contact them with your suggestions.
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.
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