What is a CCCR Review?

The Consumer Chemicals and Containers Regulations, 2001 (CCCR, 2001) is a part of the Hazardous Products Act and was created in 2001 by the Canadian government to protect Canadian consumers. It dictates the minimum requirements for the appropriate retail labelling and packaging of chemical products. Any product that is available to consumers through retail purchasing, even if it is largely used in industrial situations, is regulated under the CCCR.

Product classification categories include toxic products, corrosive products, flammable products, quick skin-bonding products, and pressurized containers. A particular product’s classification determines the necessary labelling and packaging requirements, such as hazard symbols, safe handling instructions, first aid measures, and packaging type. Information on containers must be presented in both English and French, and displayed prominently so that it is likely to catch the attention of the consumer.

CCCR label review services are offered by chemical product compliance companies to ensure that the product manufacturer’s labels contain all necessary information in order to be compliant in their desired jurisdiction. A chemical regulatory consultant analyzes the chemical product based on a scientific assessment of the hazards one might encounter during the foreseeable use of the product. These hazards are determined by testing the physical and chemical properties of that chemical or its components (like Ph, boiling point, flash point, etc).

Product labelling is made up of four different components: hazard symbols, warning statements, safety instructions and first aid statements. The appropriate kinds of packaging and labelling for a product are determined from its hazard classification.

What information is required to author a WHMIS MSDS?

The Workplace Hazardous Materials Information System (WHMIS) is Canada’s national hazard communication standard. One of the most important aspects of the WHMIS system is the Material Safety Data Sheet (MSDS). A MSDS should be produced for all substances and mixtures which meet the harmonized criteria for physical, health or environmental hazards under the GHS and for all mixtures which contain ingredients that meet the criteria for carcinogenic, toxic to reproduction, or specific target organ toxicity in concentrations exceeding the cut-off limits.

A MSDS is a document that informs users of potential hazards (environmental, health, fire etc.) and describes how to work safely with a chemical product. The document also contains information regarding emergency procedures and possible hazards of the product as well as how to use, store and handle it.

Individual countries are able to determine what information is required on their MSDS. In Canada, there are nine categories on an MSDS: Hazardous Ingredients, Preparation Information, Product Information, Physical Data, Fire or Explosions Hazard, Reactivity Data, Toxicology Properties, Preventive Measure and First Aid Measures. Subcategories are included under each heading, with the number of subcategories varying in each category. The Physical Data and Toxicology Property categories are the largest with 11 subcategories each, while the First Aid Measures category is the smallest with only one subcategory required (Specific first aid measures).

One can visit the Canadian Centre for Occupational Health and Safety website for more detailed information on WHMIS MSDS authoring.

How to Become REACH Compliant

REACH stands for the Registration, Evaluation and Authorization of Chemicals of the European Union (EU). The new law came into existence on June 1, 2007, simplifying the 40 existing pieces of legislation into a single system of regulations for all chemicals. It provides information regarding chemicals acute and long-term effects. REACH compliance has five main components: pre-registration, registration, evaluation, authorization, and restriction.

REACH aims to slowly replace the use of substance of very high concern with substances that pose a lesser risk; therefore, applicants must also investigate the possibility or substituting these substances with safer alternatives.

To continue manufacturing/importing substances on the EU market after December 1, 2008, manufacturers and importers must’ve pre-registered these chemicals between June 1 and December 1, 2008. The Pre-registration data includes your identity and contact information, the estimated imported tonnage and expected registration deadline, and the EINECS and CAS numbers for each substance. This data will be used by the European Chemicals Agency (ACHA) to allow companies registering the same substances to share the relevant data. Becoming REACH compliant can be an overwhelming and difficult task. That is why many decide to outsource their chemical product compliance.

REACH consulting services provides your company with expert interpretation, guidance, and compliance with respect to the REACH guidelines. Reach compliance consulting services consist of: hazard and risk assessment, fulfilling data requirements, and handling administrative responsibilities associated with the REACH regulation. Visit the Nexreg website for more information on REACH consulting services.

A summary on MSDS Authoring, Reformatting and Translation

A material safety data sheet (MSDS) is a document designed to provide employees with the necessary information to safely use a chemical or mixture. Every chemical or mixture that is available or used in an industrial or institutional setting must have an accompanied MSDS stating the hazards associated with the product.

MSDS authoring can be complicated because every country/jurisdiction has its own regulations specifying what information must be disclosed on the document. MSDS categories include E.U. (SDS), NAFTA (U.S., Canada and Mexico), OSHA/WHMIS (U.S. and Canada), OSHA (U.S.) and WHMIS (Canada). Many important statements are included in an MSDS, including: chemical product and company identification, the composition of the ingredients, hazards identified, first aid and firefighting measures and regulatory statements. This data is typically presented in a 16-section format, but can vary from a one-page format to over 10 pages, depending on the creator of the MSDS.

MSDS reformatting is the process of taking an MSDS that is compliant in one jurisdiction, such as the United States, and re-authoring it so it is compliant in another, such as Canada.

Translating MSDSs is usually not advisable, as it can lead to non-compliant documents and it is also often not cost-effective. For example, you cannot simply take a U.S. compliant MSDS and translate it into Danish and have a document which is compliant in Denmark. Rather than translating a MSDS into the desired language, MSDSs should be re-formatted to ensure that they are compliant in the desired jurisdiction.