Canada Gazette, Part I, Volume 152, Number 47: Proposed notice requiring the preparation and implementation of pollution prevention plans with respect to triclosan in certain products
November 24, 2018
DEPARTMENT OF THE ENVIRONMENT
CANADIAN ENVIRONMENTAL PROTECTION ACT, 1999
Proposed notice requiring the preparation and implementation of pollution prevention plans with respect to triclosan in certain products
Pursuant to section 91 of the Canadian Environmental Protection Act, 1999 (the "Act"), the Minister of the Environment proposes to publish the annexed Notice under subsection 56(1) of the Act. This proposed Notice (the "Notice") initiates a 60-day comment period, and after the review of the comments received, the Minister intends to publish, in the Canada Gazette, Part I, a Final Notice requiring the preparation and implementation of pollution prevention plans with respect to triclosan in certain products, which is specified on the List of Toxic Substances in Schedule 1 of the Act.
The Final Notice will apply to any person or class of persons who manufactures or imports triclosan-containing products that are cosmetics, natural health products or drugs.
More information on pollution prevention planning can be found in the Pollution Prevention Planning Provisions of Part 4 of the Canadian Environmental Protection Act, 1999: Guidelines for Implementation. These guidelines and other information relating to pollution prevention and pollution prevention planning can also be found on the "Pollution Prevention Planning Notices" section of the Government of Canada website.
Marc D'Iorio
Director General
Industrial Sectors, Chemicals and Waste Directorate
On behalf of the Minister of the Environment
PROPOSED NOTICE REQUIRING THE PREPARATION AND IMPLEMENTATION OF POLLUTION PREVENTION PLANS WITH RESPECT TO TRICLOSAN IN CERTAIN PRODUCTS
Notice is hereby given that, pursuant to the provisions of subsection 56(1) of Part 4 of the Act, the Minister of the Environment requires any person or class of persons described in section 2 of the Notice to prepare and implement a pollution prevention plan with respect to triclosan in certain products, which is specified on the List of Toxic Substances in Schedule 1 of the Act.
1 Definitions
The definitions in this section apply to this Notice.
- "Act" means the Canadian Environmental Protection Act, 1999 (CEPA).
- "Base year" is the reference year against which triclosan quantity target reductions are measured.
- "CAS RN" means Chemical Abstracts Service Registry Number.footnote 1
- "Cosmetic" includes any substance manufactured, sold or represented for use in cleansing, improving or altering the complexion, skin, hair or teeth, and includes deodorants and perfumes.
- "Drug" includes any substance manufactured, sold or represented for use in
- (a) the diagnosis, treatment, mitigation or prevention of a disease, disorder or abnormal physical state, or its symptoms, in human beings or animals;
- (b) restoring, correcting or modifying organic functions in human beings or animals; or
- (c) disinfection of premises in which food is manufactured, prepared or kept.
- "Minister" means the Minister of the Environment.
- "Natural health product" means a substance set out in Schedule 1 of the 2003 Natural Health Products Regulations (the Regulations) or a combination of substances in which all the medicinal ingredients are substances set out in Schedule 1 of the Regulations, a homeopathic medicine or a traditional medicine, that is manufactured, sold or represented for use in
- (a) the diagnosis, treatment, mitigation or prevention of a disease, disorder or abnormal physical state or its symptoms in humans;
- (b) restoring or correcting organic functions in humans; or
- (c) modifying organic functions in humans, such as modifying those functions in a manner that maintains or promotes health.
However, a natural health product does not include a substance set out in Schedule 2 of the Regulations, any combination of substances that includes a substance set out in Schedule 2 of the Regulations or a homeopathic medicine or a traditional medicine that is or includes a substance set out in Schedule 2 of the Regulations.
- "Notice" means the Notice requiring the preparation and implementation of pollution prevention plans with respect to triclosan in certain products.
- "Plan" means a pollution prevention plan.
- "Pollution prevention", as defined in section 3 of the Act, means the use of processes, practices, materials, products, substances or energy that avoid or minimize the creation of pollutants and waste and reduce the overall risk to the environment or human health.
- "Triclosan" means 5-chloro-2-(2,4-dichlorophenoxy) phenol; CAS RN 3380-34-5.
2 Person or class of persons required to prepare and implement a plan
- (1) The Notice applies to any person or class of persons who, on the date of publication of the Final Notice and anytime thereafter,
- (a) uses 100 kg or more of triclosan in a calendar year in the manufacture of cosmetics, natural health products or drugs; or
- (b) imports 100 kg or more of triclosan in a calendar year contained in cosmetics, natural health products or drugs.
- (2) The Notice does not apply to quantities of triclosan used to manufacture products that are exclusively destined for export or in products that are in transit through Canada.
- (3) The Notice applies to any person or class of persons who is the successor or assign of the persons identified in subsection 2(1).
3 Activities for which the plan is to be prepared
The Minister requires any person or class of persons identified in section 2 to prepare and implement a plan in relation to the following activities:
- (1) Manufacture of cosmetics, natural health products or drugs that contain triclosan; or
- (2) Importation of cosmetics, natural health products or drugs that contain triclosan.
4 Factors to consider in preparing the plan
The Minister requires any person or class of persons identified in section 2 to consider the following factors when preparing their plan:
- (1) Triclosan is toxic under paragraph 64(a) of the Act and was added to the List of Toxic Substances in Schedule 1 of the Act on June 22, 2018. According to the screening assessment published on November 26, 2016, triclosan is entering or may enter the environment in a quantity or concentration or under conditions that have or may have an immediate or long-term harmful effect on the environment or its biological diversity.footnote 2
- (2) The risk management objective for triclosan is to reduce the quantity of triclosan released to the aquatic environment as a result of the use by consumers of triclosan-containing products that are imported into or manufactured in Canada.
- (3) Any person or class of persons subject to the Final Notice on the date of its publication must endeavour to achieve and maintain a minimum reduction of 30% of the total mass of triclosan that, in a year, is used to manufacture products or that is contained in certain products that are imported into Canada from the base year level. The base year is the calendar year the person becomes subject to the Notice, or at the election of the person, any year prior to, but no earlier than, 2011.
- (4) Any person or class of persons subject to the Final Notice after the date of its publication must endeavour to achieve and maintain a minimum reduction of 95% of the total mass of triclosan that, in a year, is used to manufacture products or that is contained in certain products that are imported into Canada from the base year level. The base year is the 12-month period from the date the person becomes subject to the Notice.
- (5) A person or class of persons subject to the Final Notice must consider the use of alternative substances to triclosan that would reduce or minimize harmful effects to the environment and to human health while complying with all other relevant existing legislation. Considerations of any alternatives should include the following:
- (a) "[T]he combined exposure from [triclosan's] transformation product, methyl-triclosan, and from chemicals such as triclocarban that have similar mode of action and use patterns, could also contribute to the potential for harm." footnote 3
- (b) "[E]vidence indicates that methyl-triclosan is likely to be both more persistent and more bioaccumulative than triclosan." footnote 4
- (c) Phenol, 2-phenoxy-, trichloro deriv. (CAS RN 64111-81-5), also known as trichloro-2-hydroxydiphenyl ether or triclosan, refers to structural isomers of triclosan. The substance is considered to be inherently toxic to non-human organisms and to meet the criteria for both persistence and bioaccumulation footnote 5 as set out in the Persistence and Bioaccumulation Regulations. Due to its hazardous properties, this substance is subject to a Significant New Activity Order under CEPA.
- (d) Refer to Health Canada's Cosmetic Ingredient Hotlist, which is used to communicate that certain substances may be prohibited or restricted for use in cosmetics (e.g. methylisothiazolinone and methylisothiazolinone/methylchloroisothiazolinone).
- (e) Consideration should be given to conducting an assessment of hazards and potential risks of any alternative.
- (6) In preparing a plan, a person or class of persons subject to the Final Notice should give priority to pollution prevention activities.
5 Content of the plan
A person or class of persons identified in section 2 of the Notice is to determine the appropriate content of that person's plan; however, the plan must meet all the requirements of the Notice. The plan must also contain the information required to file the Declaration of Preparation referred to in section 8 of the Notice and have the capacity to generate the information required to file the Declaration of Implementation referred to in section 10 of the Notice.
6 Use of a plan prepared or implemented for another purpose
Under subsection 57(1) of the Act, a person or class of persons may use a pollution prevention plan prepared or implemented for another purpose to satisfy the requirements of this Notice. Under subsection 57(2) of the Act, where a person uses a plan that does not meet all the requirements of the Notice, the person must either amend the plan so that it meets all of those requirements or prepare an additional plan that meets the remainder of those requirements. A person using existing plans must still file the Declaration of Preparation referred to in section 8 of the Notice, the Declaration of Implementation referred to in section 10 of the Notice, and, if applicable, any amended declarations referred to in section 11 of the Notice.
7 Period to prepare the plan
- (1) The Minister requires any person or class of persons subject to the Final Notice on the date of its publication to prepare a plan no later than 12 months from the date of publication of the Final Notice.
- (2) The Minister requires any person or class of persons who become subject to the Final Notice after the date of its publication to prepare a plan no later than 12 months from the date of becoming subject to the Notice.
8 Deadline to submit the Declaration of Preparation
Under subsection 58(1) of the Act, any person or class of persons identified in section 2 of the Notice must, within 30 days after the end of the period given to prepare the plan as specified in section 7 or 13, file a written "Declaration that a Pollution Prevention Plan Has Been Prepared and Is Being Implemented." This Declaration should be submitted to the Minister using the online form that contains the information set out in Schedule 1 of the Notice.
9 Period to implement the plan
- (1) The Minister requires any person or class of persons subject to the Final Notice on the date of its publication to implement a plan no later than 36 months from the date of publication of the Final Notice.
- (2) The Minister requires any person or class of persons who become subject to the Final Notice after the date of its publication to implement a plan no later than 18 months from the date they become subject.
10 Deadline to submit the Declaration of Implementation
Under subsection 58(2) of the Act, any person or class of persons identified in section 2 of the Notice must, within 30 days after the end of the period given to implement the plan as specified in section 9 or 13, file a written "Declaration that a Pollution Prevention Plan Has Been Implemented." This Declaration should be submitted to the Minister, using the online form that contains the information set out in Schedule 5 of the Notice.
11 Filing of amended Declarations
Subsection 58(3) of the Act requires any person or class of persons specified in section 2 of the Notice to file an amended Declaration of Preparation or an amended Declaration of Implementation if, at any time after the filing, the information submitted has become false or misleading. This Declaration must be submitted to the Minister within 30 days of becoming aware that the information became false or misleading. It should be submitted to the Minister using the appropriate form referred to in section 8 or 10 of the Notice.
12 Requirement to keep the plan and record keeping
Section 59 of the Act requires any person or class of persons identified in section 2 of the Notice to keep a copy of the plan at the place in Canada in relation to which the plan is prepared, which is the physical address identified in the schedules.
Any person or class of persons identified in section 2 of the Notice must keep the plan and any records pertaining to the plan while engaged in the manufacture and import of certain triclosan-containing products and for five years after they have ceased these activities.
13 Extension of time
Under subsection 56(3) of the Act, the Minister may extend the period to prepare a plan or the period to implement a plan beyond the periods referred to in sections 7 and 9 if the Minister is of the opinion that such an extension is necessary. A person should submit a written "Request for Time Extension" using the online form that contains the information set out in Schedule 3 of the Notice. The request must be submitted 60 days before the expiry of
- (1) the period to prepare the plan as referred to in section 7;
- (2) the period to implement the plan as referred to in section 9; or
- (3) any extended period.
14 Application for waiver of factors to consider
Under subsection 56(5) of the Act, the Minister may waive the requirement for a person or class of persons to consider a factor in preparing the plan specified in section 4 if the Minister is of the opinion that it is neither reasonable nor practicable to consider such a factor. The decision to grant a waiver will be based on the reasons provided by that person or class of persons in a "Request for Waiver of the Requirement to Consider a Factor or Factors." This request should be submitted within 60 days before the expiry of the period to prepare the plan as referred to in section 7 or before the expiry of any extended period using the online form that contains the information set out in Schedule 2 of the Notice.
15 Public Disclosure of Information and forms
The Minister intends to publish information submitted in schedules 1 and 5 in response to this Notice in the Pollution prevention planning notices section of the Government of Canada's website.
Under section 313 of the Act, all persons submitting information to the Minister are entitled to submit a written request that specific information be treated as confidential. Persons submitting such a request should also include the reasons for that request.
The Notice includes the following forms:
- Schedule 1: Declaration That a Pollution Prevention Plan Has Been Prepared and Is Being Implemented — Pollution Prevention Planning Notice with Respect to Triclosan in Certain Products (Subsection 58(1) of CEPA);
- Schedule 2: Request for Waiver of the Requirement to Consider a Factor or Factors — Pollution Prevention Planning Notice with Respect to Triclosan in Certain Products (Subsection 56(5) of CEPA);
- Schedule 3: Request for Time Extension — Pollution Prevention Planning Notice with Respect to Triclosan in Certain Products (Subsection 56(3) of CEPA);
- Schedule 4: Interim Progress Reports are not required for this Notice; and
- Schedule 5: Declaration That a Pollution Prevention Plan Has Been Implemented — Pollution Prevention Planning Notice with Respect to Triclosan in Certain Products (Subsection 58(2) of CEPA).
Forms referred to in the Notice (schedules 1, 2, 3 and 5) will be published as part of the Notice and should be filled out electronically using the Pollution Prevention Planning Online Reporting tool in Environment and Climate Change Canada's Single Window.
16 Performance measurement and evaluation of the Notice
Performance measurement of the Notice will be conducted after every reporting cycle to evaluate the effectiveness of the Notice in meeting its intended objectives. Performance reports summarizing the overall results to date will be posted online.
The Minister will evaluate the effectiveness of the Notice with respect to the risk management objective set out in subsection 4(2) of the Notice. This may include a data-gathering initiative after the implementation of the plans to verify use patterns and quantities of triclosan.
The Minister will determine whether other measures are needed to further prevent or reduce negative impacts of triclosan on the environment.
17 Resources
Guidance on preparing pollution prevention plans may be obtained from
- the Pollution prevention planning notices section of the Government of Canada's website.
Additional information and guidance on pollution prevention can be found in
- the Pollution prevention section of the Government of Canada's website; and
- the Pollution prevention resource finder of the Government of Canada's website.
For further inquiries regarding pollution prevision (P2) planning and practices, please email ec.planp2-P2Plan.EC@canada.ca.
18 Notice Reference Code: P2Triclosan
For administrative purposes, all communication with Environment and Climate Change Canada concerning the Notice should refer to the following Notice Reference Code: P2Triclosan.
19 Environment and Climate Change Canada contact information
For technical questions or comments about this proposed Notice, please contact or send queries to
Products Division
Environment and Climate Change Canada
351 Saint-Joseph Boulevard
Gatineau, Quebec
K1A 0H3
Fax: 819-938-4480 or 1-888-391-3695
Email: ec.produits-products.ec@canada.ca
For more information about pollution prevention planning or online reporting, please contact
Innovative Measures Section
Regulatory Innovation and Management Systems
Environment and Climate Change Canada
351 Saint-Joseph Boulevard, 20th Floor
Gatineau, Quebec
K1A 0H3
Telephone (toll-free): 1-844-580-3637
Fax: 819-420-7386 or toll-free: 1-844-580-3638
Email: ec.planp2-p2plan.ec@canada.ca
EXPLANATORY NOTE
(This note is not part of the Notice.)
Compliance with the Canadian Environmental Protection Act, 1999 (hereinafter referred to as the "Act") is mandatory pursuant to subsections 272(1) and 272.1(1) of the Act. Subsections 272(2), (3) and (4) and 272.1(2), (3) and (4) of the Act set the penalties for persons who commit an offence under the Act. Offences include the offence of failing to comply with an obligation arising from the Act and the offence of providing false or misleading information. Penalties for offences can result, upon conviction (either summary conviction or indictment), in fines of not more than $12 million, imprisonment for a term of not more than three years, or both.
The current text of the Act, including the most recent amendments, is available on the Department of Justice Canada website.
The Act is enforced in accordance with the Canadian Environmental Protection Act: compliance and enforcement policy.
Suspected violations under the Act can be reported to the Enforcement Branch by email at ec.enviroinfo.ec@canada.ca.
NOTE: Please note that this proposed schedule has been prepared for stakeholder review. Do not fill out this form as it is for consultation only.
Proposed Schedule 1: Declaration That a Pollution Prevention Plan Has Been Prepared and Is Being Implemented — Pollution Prevention Planning Notice with Respect to Triclosan in Certain Products (Subsection 58(1) of CEPA)
Notice Reference Code: P2Triclosan
Contacts
Company
Company Name: ______________________________________________________________________
Canadian Federal Business Number: ______________________
Physical Address
Unit: _______
Street Number: _______
Street Name: ____________________________________________
Street Type: ____________________________________________
Street Direction: __________________
City: _________________________________________
Province/Territory: ________________________
Postal Code: ______________
Country: _____________________________________________________
Mailing Address
Same as Physical Address □
Unit: _______
Street Number: _______
Street Name: ____________________________________________
Street Type: ____________________________________________
Street Direction: __________________
City: _________________________________________
Province/Territory: ________________________
Postal Code: ______________
Country: _____________________________________________________
National Pollutant Release Inventory (NPRI) ID: ______________________
Six-digit North American Industry Classification System (NAICS) code: _________________________________
Technical Contact
Name: ______________________________
Position/Job Title: __________________________________
Mailing Address: ______________________________________________________________________
__________________________________________________________________________________
Telephone Number: _____________________________
Fax Number: _____________________________
Email: _____________________________________________________________________________
General Contact
Same as Technical Contact □
Name: ______________________________
Position/Job Title: __________________________________
Mailing Address: ______________________________________________________________________
__________________________________________________________________________________
Telephone Number: ______________________________
Fax Number: _____________________________
Email: _____________________________________________________________________________
Use of Existing Plans
Prior to this Notice, did you have a Pollution Prevention (P2) Plan? ☐ Yes ☐ No
If yes, was the P2 Plan previously prepared
- ☐ on a voluntary basis?
- ☐ for another government or under another Act of Parliament? Identify the other government requirement(s) or Act of Parliament: ____________________________________________________________________
- ☐ for other reasons? Please specify: _______________________________________________________
Did you use that P2 Plan (all or in part) to meet the requirements of this Notice? ☐ Yes ☐ No
Baseline Information
Base Year
If you are subject to the Notice on the date of publication, this Declaration requires reporting of data from a Base Year (January 1 to December 31), which can be no earlier than 2011.
Indicate the Base Year: _____________________________________________
If you become subject to the Notice after the date of publication, this Declaration requires reporting of data from a Base Year. The Base Year is the 12-months period after the date you became subject to the Notice.
Indicate the Base Year:
_____________________________________________
(YYYY/MM/DD to YYYY/MM/DD)
All information provided in this Declaration will refer to this Base Year.
Manufacture and Import Information
Did you manufacture triclosan-containing products that are cosmetics, natural health products or drugs during the Base Year? ☐ Yes ☐ No
-
If yes, indicate the total quantity of triclosan, in kilograms, used to manufacture these products during the Base Year: _________________________________________________________________________
-
Which product type(s) was triclosan used in (select all that apply):
- ☐ Cosmetic
- ☐ Natural Health Product
- ☐ Drug
Did you import triclosan-containing products that are cosmetics, natural health products or drugs during the Base Year? ☐ Yes ☐ No
- If yes, indicate the total quantity of triclosan, in kilograms, imported in these products during the Base Year: _________
- Which triclosan-containing product type(s) was imported (select all that apply):
- ☐ Cosmetic
- ☐ Natural Health Product
- ☐ Drug
Anticipated Actions to Reduce Triclosan
This part must be completed for each anticipated action identified in this P2 Plan.
Anticipated Action
Action No. ___
Describe the anticipated action to be taken to reduce triclosan quantities. Clearly identify which product(s) or type(s) of
product(s) this action relates to: ____________________________________________________________
Types of Pollution Prevention Methods (select all that apply)
- ☐ Product substitution
- ☐ Spill and leak protection
- ☐ Product design or reformulation
- ☐ Good operating practices or training
- ☐ Use of alternative substance
- ☐ On-site reuse, recycling or recovery
- ☐ Inventory management or purchasing techniques
- ☐ Other (please specify): _______________________
What is the current status of this Action?
- ☐ Planned
- ☐ In Progress
- ☐ Completed
Anticipated Quantity Reductions to be Achieved for this Action
Report the anticipated quantity change in kilograms to be achieved in annual use or import of the substance relative to the Base Year: _________
Note: Indicate a decrease with a negative sign ("-") and an increase with a positive sign ("+") in front of the reported quantity.
Planned Completion Date:
_____________________________
(YYYY/MM/DD)
Total Anticipated Results
The information below summarizes the total anticipated change to be achieved by implementing ALL actions identified in the previous section.
Note: Indicate a decrease with a negative sign ("-") and an increase with a positive sign ("+") in front of the reported quantity.
If you manufacture triclosan-containing products that are cosmetics, natural health products or drugs, indicate the total anticipated change in quantity of triclosan used in the manufacture of these products.
- Total anticipated change, in kilograms, relative to the Base Year: ________________
- Total anticipated change, in percentage, relative to the Base Year: __________________
If you import triclosan-containing products that are cosmetics, natural health products or drugs, indicate the total anticipated change in quantity of triclosan imported in these products.
- Total anticipated change, in kilograms, relative to the Base Year: _______________
- Total anticipated change, in percentage, relative to the Base Year: __________________
Maintaining Reductions and Tracking Results
Describe the anticipated method used to track progress in implementing the P2 Plan and how you propose to maintain the
reductions: ____________________________________________________________________________
___________________________________________________________________________________
Objective of the Notice
Were you subject to the Final Notice on the date of its publication? ☐ Yes ☐ No
- If yes, do you anticipate achieving and maintaining a minimum reduction of 30%?
- ☐ Yes ☐ No
- If no, explain why you do not anticipate that this Plan will meet the objective: ____________________________
- _________________________________________________________________________________
Were you subject to the Final Notice after the date of its publication? ☐ Yes ☐ No
- If yes, do you anticipate achieving and maintaining a minimum reduction of 95%?
- ☐ Yes ☐ No
- If no, explain why you do not anticipate that this Plan will meet the objective: ___________________________
_________________________________________________________________________________
Other Factors to Consider
Describe how the following factors to consider, under section 4 of the Notice, were taken into account when preparing the P2 Plan, except if a waiver has been granted by the Minister.
Alternatives to Triclosan
Do you plan to use any alternative substances to triclosan? ☐ Yes ☐ No
- If yes, provide the following information:
- Chemical name of the alternative substance(s): ___________________________________________
- Common name or trade name: ____________________________________________________________
- CAS Number(s): _____________________________________________________________________
- Anticipated quantity of the alternative substance(s) to be used in the Implementation Year: __________________
- Anticipated maximum quantity of the alternative substance(s) to be used following the Implementation Year:________
Have you conducted an assessment of hazards and potential risks of the alternative substance(s) for which you plan to use in your products?
- ☐ Yes ☐ No ☐ Not applicable
- If yes, please describe the assessment and its conclusion for each of the alternative substances for which you plan to use:
- _________________________________________________________________________________
_________________________________________________________________________________
Certification
☐ I hereby certify that a P2 Plan in respect of triclosan has been prepared and is being implemented and that the information provided in this Declaration is true, accurate and complete.
Name: ____________________________________
Title/Position: _______________________________
Email: ____________________________________
Date: _____________________________________
General Comments: _____________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________
NOTE: Please note that this proposed schedule has been prepared for stakeholder review. Do not fill out this form as it is for consultation only.
Proposed Schedule 2: Request for Waiver of the Requirement to Consider a Factor or Factors — Pollution Prevention Planning Notice with Respect to Triclosan in Certain Products (Subsection 56(5) of CEPA)
Notice Reference Code: P2Triclosan
Contacts
Company
Company Name: ______________________________________________________________________
Canadian Federal Business Number: ______________________
Physical Address
Unit: _______
Street Number: _______
Street Name: ____________________________________________
Street Type: ____________________________________________
Street Direction: __________________
City: _________________________________________
Province/Territory: ________________________
Postal Code: ______________
Country: _____________________________________________________
Mailing Address
Same as Physical Address ☐
Unit: _______
Street Number: _______
Street Name: ____________________________________________
Street Type: ____________________________________________
Street Direction: __________________
City: _________________________________________
Province/Territory: ________________________
Postal Code: ______________
Country: _____________________________________________________
National Pollutant Release Inventory (NPRI) ID: _________________________________________________
Six-digit North American Industry Classification System (NAICS) code: _________________________________
Technical Contact
Name: ______________________________
Position/Job Title: __________________________________
Mailing Address: _______________________________________________________________________
__________________________________________________________________________________
Telephone Number: ______________________________
Fax Number: _____________________________
Email: _____________________________________________________________________________
General Contact
Same as Technical Contact ☐
Name: ______________________________
Position/Job Title: __________________________________
Mailing Address: _______________________________________________________________________
__________________________________________________________________________________
Telephone Number: _____________________________
Fax Number: _____________________________
Email: _____________________________________________________________________________
Factor(s) to Consider for Which a Waiver Is Being Requested
Identify for which factor(s) to consider listed in the Notice a waiver is being requested.
__________________________________________________________________________________
Rationale for Request
Explain why it would not be reasonable or practicable to consider each factor for which a waiver is being requested.
__________________________________________________________________________________
Explain how the outcome of the Pollution Prevention Plan will be affected if this or these factor(s) to consider is (are) not taken into account.
__________________________________________________________________________________
Identify which, if any, additional factor(s) you propose to consider in preparing the Pollution Prevention Plan (optional).
__________________________________________________________________________________
Certification
☐ I hereby certify that the information provided in this Request is true, accurate and complete.
Name: __________________________________________________
Title/Position: ________________________________________
Email: _________________________________________________
Date: __________________________________________________
General Comments: ______________________________________
NOTE: Please note that this proposed schedule has been prepared for stakeholder review. Do not fill out this form as it is for consultation only.
Proposed Schedule 3: Request for Time Extension — Pollution Prevention Planning Notice with Respect to Triclosan in Certain Products (Subsection 56(3) of CEPA)
Notice Reference Code: P2Triclosan
Contacts
Company
Company Name: ______________________________________________________________________
Canadian Federal Business Number: ______________________
Physical Address
Unit: _______
Street Number: _______
Street Name: ____________________________________________
Street Type: ____________________________________________
Street Direction: __________________
City: _________________________________________
Province/Territory: ________________________
Postal Code: ______________
Country: _____________________________________________________
Mailing Address
Same as Physical Address ☐
Unit: _______
Street Number: _______
Street Name: ____________________________________________
Street Type: ____________________________________________
Street Direction: __________________
City: _________________________________________
Province/Territory: ________________________
Postal Code: ______________
Country: _____________________________________________________
National Pollutant Release Inventory (NPRI) ID: _________________________________________________
Six-digit North American Industry Classification System (NAICS) code: _________________________________
Technical Contact
Name: ______________________________
Position/Job Title: __________________________________
Mailing Address: ________________________________________________________________________________________________________________
Telephone Number: _____________________________
Fax Number: _____________________________
Email: _____________________________________________________________________________
General Contact
Same as Technical Contact ☐
Name: ______________________________
Position/Job Title: __________________________________
Mailing Address: _______________________________________________________________________
__________________________________________________________________________________
Telephone Number: _____________________________
Fax Number: _____________________________
Email: _____________________________________________________________________________
Request for Time Extension
Identify for which of the following a time extension is being requested (choose one):
- ☐ to prepare the Pollution Prevention Plan
- ☐ to implement the Pollution Prevention Plan
Are you requesting to extend a time extension already granted by Environment and Climate Change Canada? ☐ Yes ☐ No
We request that the date be extended to __________________________ (specify exact date — YYYY/MM/DD).
Rationale for Request
Explain why additional time is needed to prepare or implement the Pollution Prevention Plan.
__________________________________________________________________________________
Certification
☐ I hereby certify that the information provided in this Request is true, accurate and complete.
Name: ___________________________________________________
Title/Position: _____________________________________________
Email: ___________________________________________________
Date: ____________________________________________________
General Comments: ________________________________________
NOTE: Please note that this proposed schedule has been prepared for stakeholder review. Do not fill out this form as it is for consultation only.
Proposed Schedule 5: Declaration That a Pollution Prevention Plan Has Been Implemented — Pollution Prevention Planning Notice with Respect to Triclosan in Certain Products (Subsection 58(2) of CEPA)
Notice Reference Code: P2Triclosan
Contacts
Company
Company Name: _______________________________________________________________________
Canadian Federal Business Number: ___________________
Physical Address
Unit: _______
Street Number: _______
Street Name: ___________________________________________
Street Type: _________________________________
Street Direction: _____________________________
City: __________________________________
Province/Territory: _______________________________
Postal Code: _______________
Country: ___________________________________________________
Mailing Address
Same as Physical Address ☐
Unit: _______
Street Number: _______
Street Name: ___________________________________________
Street Type: _________________________________
Street Direction: _____________________________
City: __________________________________
Province/Territory: _______________________________
Postal Code: _______________
Country: ___________________________________________________
National Pollutant Release Inventory (NPRI) ID:__________________________________________________
Six-digit North American Industry Classification System (NAICS) code: _________________________________
Technical Contact
Name: ______________________________
Position/Job Title: __________________________________
Mailing Address: ______________________________________________________________________
__________________________________________________________________________________
Telephone Number: _____________________________
Fax Number: _____________________________
Email: _____________________________________________________________________________
General Contact
Same as Technical Contact □
Name: ______________________________
Position/Job Title: __________________________________
Mailing Address: ______________________________________________________________________
__________________________________________________________________________________
Telephone Number: _____________________________
Fax Number: _____________________________
Email: _____________________________________________________________________________
Implementation Information
Implementation Year
If you are subject to the Final Notice on the date of publication, this Declaration requires reporting of data from the Implementation Year (from January 1 to December 31), which can be no later than 36 months from the date of publication of the Final Notice.
Indicate your Implementation Year: ______________________
If you become subject to the Final Notice after the date of publication, this Declaration requires reporting of data from the Implementation Year, which can be no later than 18 months from the date you are subject.
Indicate your Implementation Year:
_____________________________________
(YYYY/MM/DD to YYYY/MM/DD)
Are you reporting data for an Implementation Year other than described above? ☐ Yes ☐ No
- If yes, indicate the new Implementation Year ___________ (select all that apply):
- ☐ You have been granted a time extension to implement a Pollution Prevention Plan
- ☐ Other (please specify): _______________________
All information provided in this Declaration will refer to the Implementation Year.
Manufacture and Import Information
Did you manufacture triclosan-containing products that are cosmetics, natural health products or drugs during the Implementation Year? ☐ Yes ☐ No
- If yes, indicate the total quantity of triclosan, in kilograms, used to manufacture these products during the Implementation Year: ______________________________________
- Which product type(s) was triclosan used in (select all that apply):
- ☐ Cosmetic
- ☐ Natural Health Product
- ☐ Drug
Did you import triclosan-containing products that are cosmetics, natural health products or drugs during the Implementation Year? ☐ Yes ☐ No
- If yes, indicate the total quantity of triclosan, in kilograms, imported in these products during the Implementation Year: __________________________________________
- Which triclosan-containing product type(s) was imported (select all that apply):
- ☐ Cosmetic
- ☐ Natural Health Product
- ☐ Drug
Actions Taken and Results Achieved
This part must be completed for each action taken that was previously reported in your last submitted schedule.
Also report and describe any action taken that was not previously reported.
Action No. ___
Describe the action taken to reduce triclosan quantities. Clearly identify which product(s) or type(s) of product(s) this action relates to: _______________________________________________________________________
Types of Pollution Prevention Methods (select all that apply)
- ☐ Product substitution
- ☐ Spill and leak protection
- ☐ Product design or reformulation
- ☐ Good operating practices or training
- ☐ Use of alternative substance
- ☐ On-site reuse, recycling or recovery
- ☐ Inventory management or purchasing techniques
- ☐ Other (please specify): _______________________
What is the current status of this Action?
- ☐ Completed
- ☐ Discontinued
If the action was "Discontinued," please provide the reason why: _______________________________________
Quantity Reduction Achieved for this Action
Report the quantity change achieved in kilograms in annual use or import of the substance relative to the Base Year: _______________________________________________
Note: Indicate a decrease with a negative sign ("-") and an increase with a positive sign ("+") in front of the reported quantity.
Completion Date:
___________________________________
(YYYY/MM/DD)
Total Results Achieved
The information below summarizes the total change achieved by implementing ALL actions identified in the previous section.
Note: Indicate a decrease with a negative sign ("-") and an increase with a positive sign ("+") in front of the reported quantity.
If you manufacture triclosan-containing products that are cosmetics, natural health products or drugs, indicate the total change in quantity of triclosan used in the manufacture of these products.
- Total change in kilograms relative to the Base Year: ________________________
- Total change in percentage relative to the Base Year: __________________________
If you import triclosan-containing products that are cosmetics, natural health products or drugs, indicate the total change in quantity of triclosan imported in these products.
- Total change in kilograms relative to the Base Year: ________________________
- Total change in percentage relative to the Base Year: __________________________
Total Anticipated Manufacture and Import Post Implementation
If you manufacture triclosan-containing products that are cosmetics, natural health products or drugs, indicate the total yearly quantity of triclosan, in kilograms, anticipated to be used after implementation: _______________________
If you import triclosan-containing products that are cosmetics, natural health products or drugs, indicate the total yearly quantity of triclosan, in kilograms, anticipated to be imported after implementation: _________________________
Maintaining Progress and Tracking Results
Describe the method used to track progress in implementing the P2 Plan and how you have and will continue to maintain the reductions: ________________________________________________________________________
__________________________________________________________________________________
Objective of the Notice
Were you subject to the Final Notice on the date of its publication? ☐ Yes ☐ No
- If yes, did you achieve a minimum reduction of 30%? ☐ Yes ☐ No
- If no, explain why this Plan did not meet the objective: ____________________________________________________________________________________________________________________________
Were you subject to the Final Notice after the date of its publication? ☐ Yes ☐ No
- If yes, did you achieve a minimum reduction of 95%? ☐ Yes ☐ No
- If no, explain why this Plan did not meet the objective: ____________________________________________________________________________________________________________________________
Other Factors to Consider
Describe how the factors to consider, under section 4 of the Notice, were taken into account when implementing the P2 Plan, except if a waiver has been granted by the Minister.
___________________________________________________________________________________
___________________________________________________________________________________
___________________________________________________________________________________
Alternatives to Triclosan
Are you using alternatives to triclosan in your products? ☐ Yes ☐ No
If yes, provide the following information:
- Chemical name of the alternative substance: __________________________________________________
- Common name or trade name: ___________________________________________________________
- CAS Number: _______________________________________________________________________
- Quantity of the alternative substance(s), in kilograms, used in the Implementation Year ____________________
- Anticipated quantity of the alternative substance(s), in kilograms, to be used following the Implementation Year: ____________________________________________________________________________
Have you conducted an assessment of hazards and potential risks of alternative substance(s) since submission of Schedule 1?
- ☐ Yes ☐ No ☐ Not applicable
- If yes, please describe the assessment and its conclusion for each of the alternative substances for which you plan to use: _________________________________________________________________________________
- _________________________________________________________________________________
Certification
☐ I hereby certify that a P2 Plan in respect of triclosan has been implemented and that the information provided in this schedule is true, accurate and complete.
Name: ____________________________________
Title/Position: ______________________________
Email: ____________________________________
Date: _____________________________________
General Comments: _____________________________________________________________________
__________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________