INSIDE - CCSPAccspa.org/publications/2009formulator.pdf · Al-Karim Hamir Zep Manufacturing Company...

20
The Annual Magazine of the Canadian Consumer Specialty Products Association (CCSPA) INSIDE: Ontario Government Policies — Impact On Industry The Industry Challenge Program and the Chemicals Management Plan Waste Diversion — The Ontario Landscape PM40787580 AND MORE… FORMULATOR FORMULATOR FORMULATOR The The March 2008 March 2009

Transcript of INSIDE - CCSPAccspa.org/publications/2009formulator.pdf · Al-Karim Hamir Zep Manufacturing Company...

The Annual Magazine of the Canadian Consumer Specialty Products Association (CCSPA)

INSIDE:Ontario Government Policies — Impact On Industry

The Industry Challenge Program and the Chemicals Management Plan

Waste Diversion — The Ontario Landscape

PM40787580AND MORE…

FORMULATORFORMULATORFORMULATORTheTheMarch2008March2009

Leaders in Canadian regulatory and compliance issues.TSG has an extensive knowledge of the Canadian regulatory system, having developed strong working relationships with the staff within PMRA, CFIA, TPD and Environment Canada. Through our experience and technical expertise, we assist those that need to make sense of the Canadian regulatory system and obtain the required approvals to market your products in Canada, quickly and efficiently.

TSG Canada’s services include:Registration of pesticides for consumer, commercial, and agricultural useRegistration of DisinfectantsNotification of CosmeticsNew Substance Notifications - as required by CEPAWHMIS compliant MSDS

TSG’s global services include:US - TSCA, state and federal registration, Proposition 65Europe - REACH, biocides and plant protectionAsia - Regulatory compliance and market entry assistanceSouth America - Regulatory compliance aid

NEED HELPIN SEEINGTHE BIGGERPICTURE?LET GUIDE YOU THROUGHTHE REGULATORY MAZE

California

712 5th Street, Suite A

Davis, CA 95616

T 530 757 1298 F 530 757 1299

Washington, DC

1150 18th Street, NW, Suite 1000

Washington, DC 20036

T 202 223 4392 F 202 872 0745

Canada

63 Cayuga Court

London ON N5V 2W9

T 519 936 2775 F 519 936 2778

For fur ther information, please visit: www.TSGCanada.ca or www.TSGUSA.com

March2009

Canadian Publication Agreement #40787580

The Annual Magazine of the Canadian Consumer Specialty Products Association

The FORMULATORCanadian Consumer Specialty Products Association (CCSPA) 130 Albert Street, Suite 800 Ottawa, ON K1P 5G4 Tel: (613) 232-6616 Fax: (613) 233-6350 Email: [email protected]: www.ccspa.orgwww.healthycleaning101.org

BOARD OF DIRECTORS

ChairBrian PrendergastRecochem Inc.

1st Vice ChairDarrin NobleHome Hardware

2nd Vice ChairLee BansilProcter & Gamble Inc.

Treasurer Rene BrabenderStepan Canada Inc.

SecretaryBill FitzPatrick Ecolab Co.

DirectorsAndré AzarLavo Inc.

Bob FalconiSure-Gro Inc.

Al-Karim HamirZep Manufacturing Company of Canada

Paul HughesUnilever Canada, HPC

Jim HunkingAmway Canada Corporation

Mark MaloThe Clorox Company of Canada, Ltd.

John PeoplesS.C. Johnson and Son, Limited

Alan ThompsonReckitt Benckiser (Canada) Inc.

CSPA DirectorChris CathcartConsumer Specialty Products Association

Soap & Detergent DirectorErnie RosenbergThe Soap and Detergent Association

PresidentShannon Coombs

CONTENTSMessage from the President ..........................................................................4Message from the Minister of Health..............................................................52009 CCSPA Board of Directors .....................................................................62009 CCSPA Staff ...........................................................................................7

FEATURESOntario Government Policies — Impact on Industry ......................................8By Stephen Rathlou

Industry Challenge Program — Naphthalene: an Industry Look at the Chemicals Management Plan ..........10By Robin Le Sage

Waste DIVERSION: The Ontario Landscape .................................................12By Anne McConnell

CPCHE Calls For Federal Action on Toxic Chemicals in Consumer Products ...13By Erica Phipps

Our Health is in Our Hands .........................................................................15By Joni Campbell

Consumer Ingredient Communication Initiative ..........................................16By Shannon Coombs, Chris Cathcart and Ernie Rosenberg

Cover photo by Chera Jelley

PublisherRobert Thompson

EditorDan Kenning

Sales ManagerSharon Komoski

Sales ExecutivesHayden Dookheran

Tara LashFrank Scott

Production Team LeaderAdrienne N. Wilson

Graphic Design Specialists Krista Zimmermann

Published by:

5255 Yonge Street, Suite 1000 Toronto, ON M2N 6P4

Toll Free: (866) 216-0860 ext. 229 [email protected]

1 Wesley Avenue, Suite 301 Winnipeg, MB R3C 4C6

Toll Free: (866) 201-3096 Fax: (204) 480-4420

Website: www.mediaedgepublishing.com

PresidentKevin Brown

Senior Vice-PresidentRobert Thompson

Branch ManagerNancie Privé

Please return undeliverables to:

Canadian Consumer Specialty Products Association (CCSPA)

130 Albert Street, Suite 800 Ottawa, ON K1P 5G4 Tel: (613) 232-6616 Fax: (613) 233-6350

E-mail: [email protected] Websites: www.ccspa.org

www.healthycleaning101.org

All rights reserved. The contents of this publication may not be reproduced by any means, in whole or in part, without the prior written consent of the association.

While the information in this publication has been compiled from sources deemed to be

reliable, the opinions expressed by the authors are not necessarily those of the CCSPA.

THE CCSPA FORMULATOR • 2009 3

Canadians of the ingredients of such household products as cleaning solutions and polishes. The initia-tive provides accountability and transparency and this organiza-tion and your member compa-nies are to be commended for this leadership. So through President Shannon Coombs, I want to thank all of you for your dedicated efforts in this regard. Thank you again for hosting us. Give yourselves a hand!”

It was a very proud moment for me, as a representative of this industry, and for all CCSPA members in attendance. Our proactive lead-ership as the premier consumer products industry association was being recognized and appre-ciated. Many of our government regulators and partners, such as the Canadian Cancer Society, commended our industry on the initiative.

In 2008, we also celebrated our 50th anniversary. At our Annual Conference in beau-tiful Prince Edward Island, we hosted exceptional speakers from the Canadian and U.S. govern-ments, the Premier and the Treasurer of PEI, and our asso-ciation counterparts from around the world. It was a well-attended event with great food and a great venue – wonderful memories for all participants.

In this year’s magazine, Stephen Rathlou highlights Ontario’s many regulatory initiatives and the chal-lenges for industry in managing their complexities and costs. Robin Le Sage provides an excel-lent 101 on how to ensure your voice is heard with respect to managing the Federal Government Chemicals Management Plan’s Industry Challenge Program. Anne McConnell offers an overview

on the overhaul of the blue box program - another recent initiative in Ontario.

The Formulator 2008 told us about the joint efforts of the many stake-holders in 2007 who dialogued about children’s environmental health. The Formulator 2009 summarizes the final document and recommendations.

Find out about our William Won’t You Wash Your Hands? initia-tive from the Canadian Institute of Child Health — a partnership that has been very rewarding both professionally and personally for me. Their volunteers and staff are wonderful to work with and so dedicated to their cause. We are also very pleased to include again this year a letter from the Minister of Health, who thanks CCSPA saying “over the years your insights on a range of important files, including consumer products safety and the Chemical Management Plan, have helped shape policies, programs and regulations and contributed significantly to building a better safer Canada.”

I would like to thank my staff, our member volunteers and the CCSPA Board of Directors for their ongoing help and support this year. Working as a team, we survived and thrived in 2008. We now have a minority government in power in Ottawa and a majority government in power in Ontario. Chemicals are the focus of bans, reductions and attacks and our industry is facing a global economic decline. We have another exciting and challenging year ahead of us!

Shannon CoombsPresident, CCSPA

Last year was a tremen-dous year for CCSPA. Prime Minister Stephen Harper;

Health Minister Tony Clement, and Agriculture & Agri-food Minister Gerry Ritz announced the introduction of a bill to create the new Canada Consumer Product Safety Act and proposed amend-ments to the Food and Drugs Act at the Annual CCSPA/Federal Government Interface on April 8, 2008. It was an honour to have the Prime Minister there, espe-cially since it was the first industry venue he had attended. The Prime Minister was most gracious and commended our industry on our proactive April 2, 2008, Consumer In g re d i e n t Co m m u n i c a t i o n Initiative. He stated,

“…and a special thank you to our host today, the Canadian Consumer Specialty Products Association. For 50 years, this organization has been at the forefront of advocating for consumer safety. Just last week, for instance, the CCSPA announced an industry led initiative to inform

MESSAGE FROM THE PRESIDENT

4 THE CCSPA FORMULATOR • 2009

I would like to thank the CanadianConsumer Specialty Products Associationfor your continued help to our Governmentin developing regulations and programsthat benefit the health of Canadians, theenvironment and the economy.

In my view, it is more important than evertoday for governments to listen tostakeholder needs and views which informboth policy development and decisionmaking.

Over the years your insights on a range ofimportant files, including consumerproducts safety and the ChemicalManagement Plan, have helped shapepolicies, programs and regulations andcontributed significantly to building abetter safer Canada.

Protecting the Health and Safety ofCanadians is paramount to thisGovernment. As you are no doubt awarewe are busy improving areas of our healthsystem to help ensure that our consumer,food, and health products remain safe andreliable. Our Government allocated $113million in Budget 2008 towards achievingthis goal.

As Health Minister, I thank theAssociation for the work it hasaccomplished to date and look forward tofurther insights and collaboration in thedays to come.

Je remercie l’Association canadienne de produits deconsommation spécialisés pour l’aide apportée augouvernement dans l’élaboration de règlements et deprogrammes avantageux pour la santé des Canadiens,l’environnement et l’économie.

Selon moi, il importe aujourd’hui plus que jamaisauparavant que les gouvernements soient à l’écoutedes besoins et des opinions des intervenants quiéclairent à la fois l’élaboration des grandesorientations et les prises de décisions.

Au fil des années, vos observations sur un largeéventail de dossiers importants, dont, entre autres, lasûreté des produits de consommation et le Plan degestion des produits chimiques, ont facilité ladéfinition des politiques, des programmes et desrèglements et contribué notablement à bâtir unCanada meilleur et plus sécuritaire. Notre gouvernement accorde une grande importanceà la protection de la santé et de la sécurité de lapopulation. Comme vous le savez sans doute, nousnous employons actuellement à améliorer certainssecteurs de notre système de santé afin que nosproduits de consommation, nos aliments et nosproduits de santé demeurent fiables et de qualité.Notre gouvernement a alloué un montant de113 millions de dollars dans le budget de 2008 pouratteindre cet objectif.

En tant que ministre de la santé, je remerciel’Association pour son travail et compte sur sacollaboration et ses précieuses observations au coursdes jours qui viennent.

Leona AglukkaqMinister of Health / Ministre de la Santé

Government of Canada / Gouvernement du Canada

THE CCSPA FORMULATOR • 2009 5

CCSPA BOARD OF DIRECTORS 2009Chair

Brian PrendergastSenior Vice President Consumer Division

Recochem Inc.

1st Vice Chair

Darrin NobleGeneral ManagerHome Hardware

Paint & Home Products Division

2nd Vice Chair

Lee BansilExternal Relations Officer -

CanadaProcter & Gamble Inc.

Treasurer

Rene BrabenderGeneral Manager

Stepan Canada Inc.

Secretary

Bill FitzPatrick Regional Manager, Canada Pest Elimination Division

Ecolab Co.

Director

André AzarDeputy to the President

Lavo Inc.

Director

Bob FalconiExecutive Vice President

Sure-Gro Inc.

Director

Al-Karim HamirVP, Total Supply Management

Zep Manufacturing Company of Canada

Director

Paul HughesLead Technical ManagerUnilever Canada, HPC

Director

Jim HunkingManaging Director

Canada & CaribbeanAmway Canada

Corporation

Director

Mark MaloVice President

& General ManagerThe Clorox Company

of Canada, Ltd.

Director

John PeoplesPresident & General Manager

S.C. Johnson and Son, Limited

Director

Alan ThompsonGeneral Manager

Reckitt Benckiser (Canada) Inc.

CSPA Director

Chris CathcartPresident

Consumer Specialty Products Association

Soap & Detergent Director

Ernie RosenbergPresident & CEO

The Soap and Detergent Association

President

Shannon CoombsCanadian Consumer Specialty

Products Association

6 THE CCSPA FORMULATOR • 2009

CCSPA STAFF 2009

SHANNON COOMBS, PRESIDENT Shannon has an Honours Degree in Political Science from Carleton University as well as extensive experience in government and political arenas. Prior to joining the association, she worked for the Canadian Federation of Agriculture and Agriculture Canada. Her responsibilities at CCSPA include overall management and implementation of effective government relations and regulatory strategies on critical issues for members, coalition building and member recruitment. She is also the spokesperson for the industry.

NANCY HITCHINS, DIRECTOR, ADMINISTRATION & MEMBER SERVICESAs Director, Administration & Member Services, Nancy is responsible for all aspects of office management and administration and the co-ordination of all CCSPA events and member communications. She joined the association in 1995 as Executive Assistant to the President. Originally from Newfoundland, she worked in the Faculties of Education and Medicine at Memorial University and as Executive Assistant to the former premier Frank D. Moores. She has a Diploma in Secretarial Science and in 1987, transferred to Ottawa to work for GCI (Government Consultants International Inc.) as Executive Assistant to the Chairman.

CHERA JELLEY, DIRECTOR, POLICYOriginally from Prince Edward Island, Chera moved to Ottawa in 1990 with her family. Chera has an Honours BA in Law – Concentration in Law, Policy and Government with a minor in Political Science from Carleton University. Prior to joining the association, she worked on Parliament Hill for three different Members of Parliament, including the Leader of the Opposition. Her responsibilities at CCSPA include negotiation, stakeholder representation and regulatory and government relations support for all pesticide issues and antimicrobial issues, as well as assisting the President with increasing CCSPA’s profile on Parliament Hill.

THE CCSPA FORMULATOR • 2009 7

The Canadian Consumer Specialty Products Association’s more

than 40 members are amply endowed with scientific and regulatory staff. These professionals are constantly poised to take up the latest call by our federal govern-ment — whether that is to meet the demands of the Chemicals Management Plan, the review of the Cana-dian Environmental Protec-tion Act, or the new Canada Consumer Product Safety Act.

Additional professionals are available to react to pesti-cide bans in Alberta and Ontario, consult on transporta-tion regulations, or the most recent regulations dealing with hazardous wastes and product packaging. CCSPA’s members keep these resources in reserve with relative ease; because, quite frankly, we make excessive profits that seem to be unaffected by the same economic hard-ships that affect our governments.

At least, this seems to be the popular perception of our industry at all levels of government, both political and bureaucratic. No wonder they think nothing of springing any number of new laws and regulations on us at the same time!

I feel very lucky that I work for a company that can find the resources to maintain a regulatory affairs function — one that goes beyond basic compliance. Like other leading companies, they understand the need to work with the regulators and to be there when issues arise. They appreciate that, in balance, they can use resources

to provide good information to government or, alterna-tively, require even more resources to cope with badly conceived regulations after the fact.

However, “amply endowed”? I think not. Excessive profits? Our members conduct business in a healthy, competitive environment that keeps all of us fiscally lean. We are not insulated from the faltering economy — an economy to which we have significantly contributed, including exports approaching $600 million. Today, companies are tightening the purse strings and rational-izing costs that are not directly related to keeping product flowing; but, we do not want to resort to false economy. It is crucial that we continue to invest in the future through our own participation in regulatory issues and through our trade association.

Lately, it seems that one or another politician or party feels compelled to demonstrate their concern for the environment or public safety by commencing rash initiatives and pushing implementation at breakneck speed. Today, in Ontario alone, we are trying to manage the “new General Regulation under the Pesticides Act, 1990 to implement the Cosmetic Pesticide Ban Act, 2008”, the Toxics Reduction Strategy, the Blue Box Program Plan (BBPP) Review, the implementation of the Municipal Hazardous and Special Waste (MHSW) Program, the Waste Diversion Act Review, and a program to promote “green chemistry.” In many instances, consultation by Ontario has been done grudgingly, after considerable effort by our members, the CCSPA and other associa-tions. There is an attitude that our industry cannot be trusted to deliver on programs without the threat of penalties. Regulations are being based on EPR (Extended Producer Responsibility) that heaps the entire onus for our products on us by relieving consumers, government and retailers from any responsibility at all. The costs of

by Stephen RathlouSenior Manager

Regulatory Affairs S.C. Johnson and Son, Limited

ONTARIO GOVERNMENT P O L I C I E SImpact on Industry

8 THE CCSPA FORMULATOR • 2009

the packaging stewardship program (BBPP) are poised to double to $160 million, annually. The costs of the MHSW Program will dwarf those for packaging.

Ontario is only one player in this melee; although it prides itself on being a leader in Canada, if not the world — “California North.” The burden of regulatory change in Ontario is heaped on that of other provinces and the federal government. Our budgets for travel, accom-modation and consultants are being sucked into a black hole.

How do we cope? Well, we have to give priority to those issues that we have the capacity to tackle and that have the greatest potential impact. This means that there are other issues — still serious — that we are unable to address. In many cases, our industry, co-ordinated by CCSPA, can split the work to participate on more than one front. This requires a level of trust that our profes-sional colleagues are looking after the interests of the whole. There was never a time when co-operation and collaboration have been more important.

CCSPA continues to be a critical resource, meeting with the regulators and politicians, opening doors for our members, demanding consultative processes and lever-aging the collective voice of us all.

The downside is that government “consultations” are getting fewer attendees. Some companies are seriously reconsidering decisions to launch new innovative prod-ucts here or make much needed investments because of regulatory burden and uncertainty. Increasingly, compa-nies — especially those outside of a trade association — are coming to the table only when it is obvious that an issue will have a significant impact. By that time, the train has left the station; and the conflicts that develop out of attempts to reverse key decisions are time consuming, costly and damaging to government relations.

Is there a solution? A co-ordinated regulatory plan by government that respects the reality of industry’s capacity to cope would help. But how do we get co-ordi-nation between governments? How do we compel partisan groups that are focussed solely on their own agendas to co-operate like mature adults? I think that the unfortunate answer is that we are left to make the very best of the resources that we have — our members and our CCSPA staff. We need to maintain these resources, understanding that they are both an immediate need and an investment in the future, with long-term but valu-able returns. And we will need to work co-operatively to cover as many bases as possible. Governments will have to cope with dysfunctional consultations; and, maybe, they will realize the need to improve their processes.

Since 1976, primary in Household andCosmetic fragrances. Modern Gas Chromatography equipmentenables us to maintain constant quality fragrances. High inventory of raw materials strengthens ourstability and reliability. For the finest in “Fragrances with the French Accent.”

Fleurarôme Limitée, 585 Industrial blvd, St-Eustache, QC J7R 6C3 Tel.: 450-491-3000 Fax: 450-491-2079 Toll free: 1-800-361-4093 [email protected] www.fleurarome.com

Rep.: B. FafaliosTel.: 416-574-0660Fax: [email protected]

Ontario

C.F.M.A.

MEMBER

COMPAGNIE PARENTO LIMITED has over 75 years of experience in fragrance creation. We specialize in applications such as personal care, household care, cosmetics, and I&I. We now offer a line of 100% Natural Essential Oils blends. Consult with us on your next project and see how our passion is helping our customers succeed. We pride ourselves on providing friendly, fast, reliable service.

16 Curity Avenue • Toronto • Ontario • Canada • M4B 1X7Tel: (416) 751-5100 • Fax: (416) 751-5141

www.parentoltd.com

THE CCSPA FORMULATOR • 2009 9

a categorization and screening of the 23,000 chemicals found on the Domestic Substance List (DSL). At the time, the government felt it had limited information on the chem-istry and potential health and environmental effects of several of these chemicals that had been on the market for many years. In the end, only 500 substances were categorized as high priority; and of those, 193 were earmarked for further action. The government launched the Chemicals Manage-ment Plan (CMP) to further assess these 193 chemicals.

The first part of the Industry Chal-lenge includes three elements: a substance profile, a mandatory survey and a questionnaire. The mandatory survey and the ques-tionnaire gather information on the enterprise, chemical iden-tity, import-export, use pattern, consumer use, manufacturing process, chemical manage-ment strategy, waste, landfill and recycling.

The substance profile reports on the state of the science on your substance as far as the govern-ment is concerned. The profile also explains your substance categorization based on its Persis-tence, Bioaccumulation, Inherent Toxicity and Greatest Poten-

Recochem, like most ventures, began as a family business in the 1950s,

supplying naphthalene-based products to fur companies. In the late 1960s, Recochem built a plant in Napierville specializing in the distillation of naphthalene from coal tar. Today, Recochem has diversified and now offers a large array of automotive main-tenance products, such as wind-shield washer fluid, antifreeze/coolant and a selection of solvents and cleaners for the homeowner. Recochem is a founding member of the CCSPA.

Several years ago, Health Canada and Environment Canada began

by Robin Le SageCompliance

and Technical Information Manager

Recochem Inc.

tial for Exposure by referencing the studies used to arrive at the conclusions on the environmental and the human health side. The conclusions are based on scientific evidence, but also on the precau-tionary principal when the science is absent or not black and white — so read the document carefully.

Naphthalene was one of 15 chemi-cals included in Batch 1, released in February 2007. Following the publication of the substance profile, the program allows four months for chemical manufac-turers and stewards to provide comments or additional scientific information. You can request an extension of up to two months. Recochem provided the latest science that was available, most of it contradicting the information provided in the profile. Following the four-month comment period, the government reviewers have six months to assess the new information that was provided on your chemical.

At the end of the six-month review period, a Draft Screening Assessment for the substance is published in the Canada Gazette. Currently, naphthalene is regu-lated under the CEPA’s (Canadian Environmental Protection Act) Domestic Substances List and

INDUSTRY CHALLENGE

PROGRAMNAPHTHALENE:

an Industry Look at the Chemicals Management Plan

10 THE CCSPA FORMULATOR • 2009

person, to Health Canada’s repre-sentatives. We also met with the Pest Management Regulatory Agency (PMRA) separately.

Recochem felt the PMRA should have been playing a leading role in this assessment since they have the experience and the knowledge of naphthalene when it comes to human contact, mainly via moth-balls. Fortuitously, at about the same time, the U.S. Environmental Protection Agency’s (EPA) re-eval-uation of naphthalene in moth-balls was very favourable.

The final Screening Assessment was published in the Canada Gazette in early July 2008. Naph-thalene was placed on the “Toxic” list, to be further managed by the PMRA. The Canadian re-evalu-ation of naphthalene is likely to reflect the U.S. EPA. Declared toxic by Health Canada but authorized for use by the PMRA. Confused? We fear other Canadians will be also. The “Toxic” list is a stigma on any substance; but at least the substance will be managed by the group that has a better under-standing of the usage, the expo-sure and the risk.

I feel it is important to conclude by reiterating the following recom-mendations in the eventuality that one of your substances is listed on one of the future Batches of the Chemicals Management Plan:

1. Call the CCSPA immediately; we found their help invaluable in preparing our meeting and response to the government.

2. Assemble your best team of scientists to defend your scientific evidence; it’s probably the only chance you will have.

3. Request an audience with the government. This way your message will not get lost in a pile of documents and you can cover more ground face to face than by playing memo tag.

4. Seek the involvement of other governmental departments if your chemical is managed by different departments.

5. Finally, be bold, honest and forthright in supporting a program that should benefit all Canadians including the industry.

Health Canada’s Pest Control Prod-ucts Act and was slated for review under the Industry Challenge Program in Batch 1.

Naphthalene’s Draft Screening Assessment was published in mid-January 2008. Be ready for surprises! Whatever conclu-sion you were expecting based on the information you supplied will most likely not materialize. The Draft Screening Assessment paints a grimmer picture of your substances than the Substance Profile. We were informed that the Draft Screening Assessment is not meant to be an in-depth review.

In the case of naphthalene, the profile indicated evidences of possible carcinogenicity. By the time the Draft Screening Assess-ment was published, it had then become “genotoxic.” At Health Canada, a “genotoxic” decision on your substance is a free pass to a CEPA Toxic designation thanks to the precautionary principle.

The Draft Screening Assessment for naphthalene included an exhaus-tive literature review covering 15 pages. Surprisingly, none of the new studies we had supplied made the cut. Once the Draft Screening Assessment is published, there is a 60-day comment period. You need to make use of this comment period; it is your last recourse to attempt to set the record straight.

The minute your substance is under government scrutiny, we strongly suggest you call the CCSPA. You have everything to gain by getting some political coaching from our industry asso-ciation. CCSPA has the knowledge and experience with government policies and already knows who you need to talk and meet with.

Recochem assembled a science team to meet with Health Canada and presented its evidence, in

Lowest cost, simplest,fastest,

governmentapproved

availableworldwide!

CORROSITEX

1-800-246-8487 • 949-851-8356 • Fax: [email protected] • www.invitrointl.com

in vitrocorrosives test ...

THE CCSPA FORMULATOR • 2009 11

consumer pays the cost either way. The only difference is when they pay — at time of purchase or through a municipal tax bill. This debate raises important questions:

1. Is EPR necessary to achieve increased diversion?The answer is clearly no. The current shared approach has led to continu-ously increased blue box diversion rates over the first five years of the program and at relatively low cost. While still benefiting from contin-uous improvement, this new program is working.

In a shared model, brand owners contribute to waste handling, educa-tion and research costs, and run a funding process that requires all brand owners to pay while rewarding municipal cost efficiencies. Munici-palities effectively run and develop the infrastructure, provide a public service, and educate consumers to reduce, reuse and recycle. Engaging the consumer encourages conscious consumer choice at all points in the life cycle. Consumers are empowered to purchase less packaging, recycle to the maximum and reduce litter.

2. Will EPR in Ontario lead to the design of more efficient packaging?It seems unlikely. There are many factors that go into package design. End-of-life footprint is but one measure in the life cycle. It has been cited that EPR programs in the European Union have led to design change in prod-ucts such as electronics. However, the EU has an enormous advantage over Ontario. The EU can establish a single playing field for many countries and hundreds of millions of consumers in the trading block. These economies of scale enable efficiencies that are not available in Ontario.

There was a time when the word “diversion” conjured up pleasant pastimes. Most recently, it brings

to mind waste management programs in the province of Ontario, under the Waste Diversion Act (WDA). The goal of the Act is to divert materials from land-fill and to recover resources.

The Waste Diversion Act embraces a shared responsibility approach. Regu-lations under the WDA, such as the Blue Box Program Plan, require brand owners to pay 50 per cent of the cost of managing the end of life solution for their packages. Municipal taxes pay the other 50 per cent. The more packaging material generated and the harder to recycle, the more the brand owner pays.

The WDA is being reviewed with an eye toward “zero waste” and a vision of 100 per cent diversion. The review introduces another suggestion — to move away from shared approaches and toward an Extended Producer Responsibility (EPR) “industry pays all” system.

Most can agree that more cost-efficient diversion and recovery of resources makes sense. Many do not agree with EPR. Municipalities like the idea of off-loading the tax burden but prefer to retain control of waste management. Brand owners prefer to share cost and responsibility, but if required to pay 100 per cent, want to assume full control of waste management.

The role of the consumer is often over-looked in this tug of war. In reality, the

by Anne McConnellRegulatory and Environ-

mental Affairs Consultant

Is the real question “which model is most likely to deliver against the envi-ronmental and economic goals of society?” In this case, a “what can we do together” approach seems most likely to achieve progress.

The responsibility of CCSPA and other stakeholders is to uphold the environ-mental, economic and social pillars of sustainability. This is achieved by engaging responsibly to develop effective public policy and regulatory strategies. Sound advocacy helps to navigate the issues and shape effec-tive solutions, based on technical, consumer and business knowledge. With all stakeholders entering into solid discussion, there may be more common ground than first appears.

CCSPA and other industry members have substantially contributed to increased waste diversion results and will no doubt continue to do so. How will the industry respond to the increasing demand for “less packaging”?

As one example, the detergent industry has taken meaningful visible steps through the recent conversion to concentrated laundry detergent packaging. The broader question will be answered as additional success stories are developed and shared with consumers, government and other stakeholders.

Developing cost-effective, innovative, consumer-preferred solutions will surely achieve more than any regula-tion will. And through these devel-opments, waste diversion can be a pleasant and worthwhile pastime!

Anne McConnell provides environmental and regulatory

consulting services. She helps organizations advance strategic solu-

tions, innovation and sustainability through technical, stakeholder and advocacy expertise. (416-226-2824,

[email protected])

The Onta r io Landscape

Waste DIVERSION

12 THE CCSPA FORMULATOR • 2009

protection to better protect chil-dren from the health risks posed by toxic chemicals and pollutants.

Addressing toxic substances in consumer products is among the priorities set forth in the CPCHE Vision and Strategy. Research shows that many contaminants found indoors — where today’s children spend more than 90 per cent of their time — are derived from consumer products. The polybrominated flame retardants found in TVs and computers, the phthalates found in soft vinyl toys and many personal care products, the lead that is still showing up in toys, keychains and costume jewelry, and bisphenol A (BPA), the plastic additive found in the lining of food cans and in many rigid plastic containers, are among the chemicals targeted by CPCHE for urgent action.

CPCHE is recommending that the federal government improve its regulation of chemicals and secure the legislative power to issue mandatory recalls of products when problems are discovered. The partners are also calling on the

In December 2008, the Cana-dian Partnership for Chil-dren’s Health and Environ-

ment (CPCHE), a partnership of 11 environmental, public health, medical and child care groups, released a comprehensive call to action to advance the protec-tion of children’s environmental health in Canada. Entitled First Steps in Lifelong Health: A Vision and Strategy for Children’s Health and Environment in Canada, the document outlines actions needed in the areas of (1) research, (2) law and policy, and (3) on-the-ground

government to empower parents with information via labeling and other means.

“Children are more vulnerable than adults to environmental contaminants because their bodies are undergoing rapid development and their behaviours — such as crawling on the floor and putting things in their mouths — put them in contact with contaminants found in the home, including many that are in ordinary house dust,” says Dr. Lynn Marshall, a physician with the Environmental Health Clinic at Women’s College Hospital, a CPCHE partner.

Because many of the thousands of chemicals in commerce today have not been tested for their potential to adversely affect the developing fetus and child, CPCHE advocates for a precautionary approach to chemicals manage-ment. At the same time, CPCHE is calling for a greater investment in research on how chronic expo-sure to environmental contami-nants may be contributing to worrisome trends in child health, including rising rates of asthma,

Canadian Partnership for Children’s Health

and Environment

by Erica PhippsPartnership Director

CPCHE

Calls for Federal Action on Toxic Chemicals

in Consumer Products

THE CCSPA FORMULATOR • 2009 13

lator, “A valuable stakeholder network has been formed through this year-long National Policy Consultation. This has already led to opportunities for ongoing dialogue and collaboration.” Upon the release of the Vision and Strategy in December 2008, Richard Paton, President of CCPA, stated, “We’re proud to have partic-ipated in the CPCHE’s National Policy Consultation. The Vision and Strategy is a culmination of this process, and its emphasis on gathering scientific evidence and establishing productive dialogue with decision-makers hits the right mark.” From CPCHE’s perspec-

learning disabilities and other developmental challenges.

The Vision and Strategy was formed by a multistakeholder National Policy Consultation (NPC) convened by CPCHE, with Pollution Probe as the lead partner, in six cities across Canada in 2007. Representatives of CCSPA, the Canadian Chemical Producers’ Association (CCPA), other industry groups, and companies were active participants. Anne McConnell, who represented CCSPA on the advisory committee for the NPC, commented in an article she wrote for the 2008 edition of The Formu-

tive, industry’s involvement in the NPC was both beneficial and constructive.

Public attention to environ-mental health issues, including the potential risks posed by toxic substances, has never been higher. CPCHE is committed to building a strong policy framework in Canada that will proactively reduce toxic chemical exposures, particularly during the exqui-sitely vulnerable stages of fetal and child development. CPCHE partners are also committed to working with other stakeholders to get evidence-informed informa-tion out to parents and families to enable informed decisions and to ensure that each child’s first steps are along a path to lifelong health.

First Steps in Lifelong Health: A Vision and Strategy for Children’s Health and Environment and the final Report of the National Policy Consultation on Chil-dren’s Health and Environment are both available on the CPCHE website, in English and French, at healthyenvironmentforkids.ca. C o n t a c t E r i c a P h i p p s a t e r i c a @ h e a l t h y e n v i r o n m e n t forkids.ca.

Figure 1: An Integrated Strategy

Modernizelaws/

regulations tobe child -protective

Codifyprecaution

Legislate andpromote publicright-to-know

Implementand enforceexisting laws

Createprevention-

orientedconsumer

productlegislation

Evaluate andreport results

Provide globalleadership/

collaboration

Equiptomorrow’s

leaders

Strengthenenvironmentalhealth capacity

within communityhealth and

clinical careMainstream

understandingof environmental

health amongprofessionals, front-

line workers andthe public

Foster publicinvolvement

Increasesurveillance,tracking and

biomonitoring

Expand scienceand research

capacity

Establish along-termnationalresearchagenda

Research On-the-groundProtection

Law andPolicy

CoordinationCoordinationCoordinationCoordinationCoordinationandandandandand

infinfinfinfinformationormationormationormationormationeeeeexxxxxccccchangehangehangehangehange

Canadian

Regulatory Consultants

Regulatory Compliance Experts

For Manufacturers or Importers of Products in Canada Authoring Safety Data Sheets (latest jurisdictional formats)

Registration Specialists for Pesticides, Drugs, Natural Health Products, Cosmetics

and CEPA - New Substance Notification Additional Services

Establishment & Site License Assistance Performance Testing Detergents and Floor Finishes

Meets CGSB Laboratory Acceptance Program Requirements

100 Collip Circle, Suite 220 London ON N6G 4X8

Tel: 519.858.5021 Fax 519.858.5026 Website: www.delltech.com

_______________________________________

Experts in US Registration ofAntimicrobial Pesticides

Regulatory Assistance EPA/FDA Liaison

Laboratory Testing InterpretationGLP/GMP

Technical SupportSubmission Development

Over 60 years of ExperienceRhonda Jones Sally Hayes

Bob MacDonald Ann CozadDeanna Gilbreath

P.O. Box 1014 Columbia City, IN 46725

P: 260-244-6270 F: 260-244-6273www.srcconsultants.com

Experts in US Registration of Antimicrobial Pesticides

Regulatory StrategyProduct Registration

Efficacy Protocol DevelopmentLaboratory Data Interpretation

GLP/GMP Audits/TrainingEPA/FDA Liaison

Over 80 years of Experience

Sally Hayes Rhonda Jones Bob MacDonald David Swain

P.O. Box 1014Columbia City, IN 46725

260-244-6270www.srcconsultants.com

14 THE CCSPA FORMULATOR • 2009

Dr. Robin Walker, Vice-President, Medicine, IWK Health Centre, Halifax, Nova Scotia, and member, CICH Board of Directors;

Ms. Rinda Hartner, infirmière clinicienne en santé scolaire, Montréal, Québec ;

Ms. Leslie Kopf-Johnson, Coordinator, Early Childhood Education Program, Algonquin College, Ottawa, Ontario;

Ms. Leah Feist, Child Health Consultant, Alberta Health Services, Edmonton, Alberta;

Mrs. Eleonore Benesch, Early Childhood Educator, and member, CICH Board of Directors, Ottawa, Ontario;

Dr. Donald E. Low, Microbiologist-in-Chief, University Health Network/Mount Sinai Hospital, Toronto, Ontario;

Ms. Lisa Lamarre-O’Gorman, Manager, Early Learning Centre, Ottawa, Ontario;

Ms. Maria-Graciela Hollm-Delgado, Infectious Disease Epidemiologist, Faculty of Public Health, Université de Montréal, Montréal, Québec; and

Mrs. Janice Sonnen, Executive Director, Canadian Institute of Child Health, Ottawa, Ontario.

The group reviewed the compo-nents of the kit and made recom-mendations on changes in wording and standard hygiene practices. This information has subsequently been worked back into the kit’s materials

Children need to be taught how and when to wash their hands. This is the key

message in a national campaign being launched in April by the Cana-dian Institute of Child Health (CICH) in partnership with the Canadian Consumer Specialty Products Asso-ciation (CCSPA), Reckitt Benckiser and the Public Health Agency of Canada (PHAC).

At the heart of the campaign is a resource kit that can be used by parents, caregivers and educators to teach young children good hand-washing practices. The kit, entitled “William, Won’t You Wash Your Hands?”, was first developed by CICH in 1990 with funding from Health and Welfare Canada. Since that time, it has been rolled out to a variety of early learning and care programs across the country. The kit is founded on the belief that it is essential to teach children good handwashing practices early in life and that these good health habits will stay with chil-dren and contribute to reducing the spread of infection and illness.

After almost 20 years of use, CICH recognized the need to update the kit’s information and resources and approached CCSPA for support. Thanks to the creative energy of CCSPA President Shannon Coombs, a collaborative agreement was devel-oped with CCSPA, Reckitt Benckiser and PHAC to provide resources for updating, printing and distribution of the kit.

The first component of the project involved pulling together a multidis-ciplinary National Advisory Group, which has generously provided expert advice on updating the information in the kit. This group is comprised of:

ensuring that timely, evidence-based advice is included.

The kit is comprised of five compo-nents that come together neatly in a kit envelope:

• achildren’sstorybookentitled“William, Won’t You Wash Your Hands?”, chronicling the adven-tures of a rascally boy named William who is resistant to washing his hands. Throughout the course of this charming story, William learns how important it is to wash his hands as well as the proper handwashing technique

• twopostersthatcoverthestepspreschoolers should follow to wash hands and show actions children can take to help stop the spread of infection (i.e., coughing or sneezing into their elbow and blowing noses on a tissue)

• aresourcebookletwithacomprehensive collection of games, poems, songs and activities that can reinforce the handwashing message

• tworesourcesheetsforstaffthatprovide additional information on infection control within an early learning and care program and handwashing advice

An official re-launch of the kit and a media campaign is planned for April. CICH hopes to distribute the kit, free of charge, to a number of early learning and care programs across Canada.

For more information on the campaign or the kit, please contact Janice Sonnen, CICH Executive Director, at [email protected].

by Joni Campbell, Project Consultant

National Campaign Teaches Children about the Importance of Handwashing

Our Health is in Our Hands

THE CCSPA FORMULATOR • 2009 15

In recent years, we have seen increased interest among some consumer groups for product manufacturers to provide consumers more

information about the ingredients in consumer products. We, on the product manufacturing end, have responded with a proactive voluntary ingre-dient communication initiative for Canada and the United States that provides a framework for communicating the ingredients in our products.

Member companies of the Canadian Consumer Specialty Products Association (CCSPA), the Consumer Specialty Products Association (CSPA), and The Soap and Detergent Association (SDA) have adopted the initiative for four product cate-gories — air care, automotive care, cleaning, and polishes and floor maintenance products. This industry-led initiative will help consumers make more informed choices about the products they use in and around their homes.

Products in these categories sold in Canada and the U.S. are regulated under the current system

of risk evaluation and risk-based labelling for consumer products. These regulations require that the point-of-purchase label inform consumers about the product’s potential hazards, appropriate handling and storage information, and applicable first aid information. We support these regulations because they help consumers protect themselves and their family. We are taking this proactive step beyond what the regulations require to address our changing marketplace.

Consumers recognize that the products made by our members provide numerous benefits, and there is a desire to have more information available to assist consumers with their purchasing deci-sions. Our industry is responding and participating companies will implement the voluntary initia-tive by January 1, 2010. These companies will list product ingredients in one or more of the following ways: on the product label; on the manufacturer’s, distributor’s, or importer’s website; via a toll-free telephone number; or through some other non-electronic means.

CONSUMER INGREDIENT COMMUNICATION INITIATIVE:A North American Approach

by Shannon CoombsPresident, Canadian Consumer Specialty Products Association

by Christopher CathcartPresident, Consumer Specialty

Products Association

by Ernie RosenbergPresident, The Soap and

Detergent Association

16 THE CCSPA FORMULATOR • 2009

The initiative is largely based upon the labelling conventions already in use today in Canada and the U.S. for food, drugs and cosmetics, which are familiar to consumers.

The initiative builds upon the comprehensive mandatory labelling systems currently in place in Canada and the U.S. Additionally, it builds upon the work that is ongoing in both Canada and in the U.S. with respect to the Canadian world-leading Chemicals Management Plan and the U.S. Chem-ical Assessment and Management Program. Both governments and our industry are committed to ensuring the safety of chemicals and working towards greater collaboration with respect to sharing data and information to ultimately protect our citizens and their environment.

We look forward to working with consumers and the retail community over the coming months to help ensure this program is a success. As we all work together, our goal should be to continue to provide quality products to the public that safely meet consumer needs.

Modified from an article by the authors that appeared in Sustainability, a publication of the Retail Industry Leaders Association.

Specifics on the initiative can be found on the three association websites:

The Canadian Consumer Specialty Products Association is a national trade association representing Canada’s consumer, industrial and institutional specialty prod-ucts industry. Its mission is to enhance the ability of its 46 member companies to conduct business fairly, ethi-cally and effectively by fostering industry co-operation, providing a national voice for communications and developing effective partnerships with governments, other stakeholders and the public. For more information, please visit http://www.healthycleaning101.org/english/ pressreleaseapr0208.pdf.

The Consumer Specialty Products Association (CSPA) is the premier trade association representing the interests of approximately 250 companies engaged in the manu-facture, formulation, distribution and sale of approxi-mately $80 billion annually in the U.S. of hundreds of familiar consumer products that provide households, institutions and industrial customers with products that help provide a cleaner and healthier environment. Our products include disinfectants that kill germs in homes, hospitals and restaurants; candles, fragrances and air fresheners that eliminate odours; pest management products for home and garden; cleaning products for

use throughout the home; products used to protect and improve the performance and appearance of automo-biles; and a host of other products used every day. Through its product stewardship program Product Care®, scientific and business-to-business endeavours, CSPA provides its members a platform to effectively address issues regarding the health, safety, sustainability and environ-mental impacts of its products. For more information, please visit www.cspa.org.

The Soap and Detergent Association (SDA), the Home of the U.S. Cleaning Product and Oleochemical Industries®, is a 100-plus member trade association representing the $30 billion U.S. cleaning products market. SDA members include the formulators of soaps, detergents and general cleaning products used in household, commercial, indus-trial and institutional settings; companies that supply ingredients and finished packaging for these products; and oleochemical producers. SDA and its members are dedi-cated to improving health and the quality of life through sustainable cleaning products and practices. SDA’s mission is to support the sustainability of the cleaning product and oleochemical industries through research, education, outreach and science-based advocacy. For more informa-tion, please visit www.cleaning101.com.

THE CCSPA FORMULATOR • 2009 17

Index to Advertisers Compagnie Parento Ltd. ............................................. 9www.parentoltd.com

Dell Tech Laboratories Ltd. ....................................... 14www.delltech.com

Diversified CPC International .................................. 17www.diversifiedcpc.com

Fleurarôme Ltée. .......................................................... 9www.fleurarome.com

InVitro International ............Outside Back Cover & 11www.invitrointl.com

Scientific & Regulatory Consultants, Inc. ................ 14www.srcconsultants.com

Technology Sciences Group ...........Inside Front Coverwww.tsgusa.com/www.tsgcanada.ca

FORMULATORFORMULATORThe Annual Magazine of the Canadian Consumer Specialty Products Association

For more information please visit us at:

www.ccspa.org or

www.healthycleaning101.org

18 THE CCSPA FORMULATOR • 2009

Toronto 1.866.216.0860

Winnipeg 1.866.201.3096

Gainesville 1.877.234.1863 www.med iaedgepub l i sh ing .com

Give yourself the EDGE

IT’S YOUR MESSAGE.

A fter twenty years in the association-

publishing field, Kevin Brown and I decided

six years ago to establish MediaEdge Publishing.

We wanted to use our skills, knowledge and love

of publishing to build a business with a focus on

providing exemplary customer service and leading

edge association communication solutions.

Today, MediaEdge is the leader in quality custom

publishing for associations. We treat every

client like our only client, and their agenda is

our agenda. These have remained our guiding

principles since we first opened our doors.

Customer service is our number one priority.

Robert Thompson Senior Vice-President Toronto 1.866.216.0860 ext. 229 Fax: 416.512.8344

GIVE IT THE EDGE.

SafetySavings

Speed

I N V I T R OINTERNATIONAL

www.invitrointl.com Fax: 949-851-4985

949-851-83561-800-246-8487

The Future In TestingFor eye and skin irritationThe Irritection Assay SystemInVitro International has spent more than 2 decades developingthe future in non-animal testing. We now offer the lowest cost,fastest, most straightforward, accurate in vitro assays of theirkind. Whether developing and comparing formulations withcompetitive products, or testing raw materials or final product,our Irritection Assay System (dermal or ocular irritation testing) can help you with fast, reliable, reproducible results. For cosmetics, personal care products, surfactants and selected chemicals, studies show IAS test results correlate as high as 90% when compared with animal results.

To find out more about Irritection testing for your business,please visit our website or call.