The purpose of this email is to serve as a reminder of the regulatory requirements for quick skin-bonding adhesives, including cyanoacrylate glues, in Canada. The Consumer Product Safety Program (CPSP) is responsible for the administration and enforcement of the Canada Consumer Product Safety Act (CCPSA) including the Consumer Chemicals and Containers Regulations, 2001 (CCCR, 2001) which are empowered by the CCPSA.
Section 6 of the CCPSA prohibits the manufacture, import, advertising, or sale of a consumer product that does not meet the requirements set out in the regulations. Relevant excerpts from the CCPSA and CCCR, 2001 are attached as an Appendix to this letter.
As part of the CPSP mandate, compliance verification inspections are completed on a wide variety of consumer products, including quick skin-bonding adhesives that are manufactured, imported, advertised and sold in Canada. Health Canada assesses compliance to the requirements set out in the CCPSA and CCCR, 2001. Any quick skin-bonding adhesive available to consumers in Canada must meet the requirements for packaging and labelling set out in Part 4 of the CCCR, 2001. It is the manufacturer’s or importer’s responsibility to assess whether or not their product is a quick skin-bonding adhesive, as defined in the CCCR, 2001.
Health Canada recently performed a compliance verification project for consumer chemicals, which included quick skin-bonding adhesives supplied by various manufacturers, importers and retailers. The CPSP found that many retailers and distributors were unaware that the CCCR, 2001 require quick skin-bonding adhesives to be packaged in child-resistant containers when displayed and sold to consumers. Several instances of quick skin-bonding adhesives without correct hazard labelling and child-resistant packaging were found for sale which consequently led to several enforcement actions, including two consumer product recalls (Bob Smith Industries, Satellite City Hot Stuff).
Consumer Chemicals and Containers Regulations, 2001
Under the CCCR, 2001, all consumer chemical products, including chemical containers, must be assessed by the manufacturer or importer to determine whether the product or container falls under any of the hazard categories described by Parts 1 to 5 of the CCCR, 2001. Parts 1 to 5 of the CCCR, 2001 are listed as: Toxic Products, Corrosive Products, Flammable Products, Quick Skin-bonding Adhesives, and Pressurized Containers. Once assessed, these products may be subject to the CCCR, 2001, including specific labelling and packaging requirements.
Quick Skin-Bonding Adhesive Packaging and Labelling
The CCCR, 2001 require quick skin-bonding adhesives to be packaged in child-resistant containers. Health Canada recognizes that it may be challenging to make the immediate container of a quick skin-bonding adhesive child-resistant and so the CCCR, 2001 permits a child-resistant container to enclose a quick skin-bonding adhesive.
Specific hazard labelling must be displayed on the container of a quick skin-bonding adhesive. This labelling must be visible at the point of sale and must be present on the container for the useful life of the product. In addition, the CCCR, 2001 contains requirements on the location, contrast, size, and shape of the wording. There is a small container exception for containers with a main display panel less than 35 cm2.
Note that other requirements of the CCCR, 2001 may also apply to your quick skin-bonding adhesive product. It is the manufacturer’s or importer’s responsibility to assess whether or not their product falls within any of the other hazard categories set out in the CCCR, 2001.
If there are any questions about this letter or about the CCPSA and CCCR, 2001, please contact the CPSP by phone at 1-866-662-0666 or via email at [email protected].
Consumer and Hazardous Products Safety Directorate
Healthy Environments and Consumer Safety Branch
Health Canada / Government of Canada
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Appendix – Relevant Excerpts from Legislation
Section 6 of the CCPSA states:
No person shall manufacture, import, advertise or sell a consumer product that does not meet the requirements set out in the regulations.
Section 1 of the CCCR, 2001 (Interpretations):
quick skin-bonding adhesive means a Category 4 adhesive set out in Part 4 that has properties similar to an alkyl cyanoacrylate adhesive and that is capable of bonding skin with skin instantly or nearly instantly.
responsible person means
(a) the manufacturer, in the case of a chemical product or container that is manufactured in Canada; and(b) the importer, in the case of a chemical product or container that is imported.
Section 4 the CCCR, 2001 states:
4 (1) The responsible person, using one or more of the applicable properties, data sources or test procedures set out in section 6 or Parts 1 to 5, must determine
(a) the hazard categories of the chemical product or container and, if applicable, its appropriate sub-categories;
(b) the type of container that is required; and
(c) the information that is required to be displayed on the container.
Resources
The Canada Consumer Product Safety Act (CCPSA):
http://laws.justice.gc.ca/eng/acts/C-1.68/index.html
The Consumer Chemicals and Containers Regulations, 2001:
http://laws.justice.gc.ca/eng/regulations/SOR-2001-269/index.html
The Guide to Canadian Consumer Chemical Product Assessment (2nd ed):
http://www.hc-sc.gc.ca/cps-spc/pubs/indust/hpa-pcc/guide-evaluation-eng.php