Home > Nanotechnology Columns > Bergeson & Campbell, P.C. > Canada Seeks Comment on Proposed Approach to Address Nanoscale Substances on the DSL
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Lynn L. Bergeson Managing Director Bergeson & Campbell, P.C. |
Abstract:
Environment Canada and Health Canada have released a February 2015 consultation document entitled Proposed Approach to Address Nanoscale Forms of Substances on the Domestic Substances List.
March 5th, 2015
Canada Seeks Comment on Proposed Approach to Address Nanoscale Substances on the DSL
Environment Canada and Health Canada have released a February 2015 consultation document entitled Proposed Approach to Address Nanoscale Forms of Substances on the Domestic Substances List. See http://nanotech.lawbc.com/uploads/file/00154145.PDF Environment Canada and Health Canada propose a stepwise approach to address nanoscale forms of substances on the Domestic Substances List (DSL):
1. Establishment of a list of existing nanomaterials in Canada;
2. Prioritization of existing nanomaterials for action; and
3. Action on substances identified for further work.
The proposed criteria for defining existing nanomaterials include, but are not limited to:
- The substance has a chemical composition that is identical to that of a bulk substance already listed on the DSL; AND
- The substance is in commerce in Canada at quantities above 100 kilograms (kg)/year; AND
- The substance is at or within the nanoscale in at least one external dimension, or has internal or surface structure at the nanoscale; OR
- The substance is smaller or larger than the nanoscale in all dimensions and exhibits one or more nanoscale properties/phenomena.
Proposed criteria for substances to be excluded, unless they are intentionally manufactured to exhibit one or more nanoscale properties/phenomena, include, but are not limited to:
- Polymers;
- Organic or organo-metallic pigments and dyes;
- Naturally occurring or incidentally produced nanomaterials; and
- Deoxyribonucleic acid, ribonucleic acid, proteins, peptides, liposomes, antibodies, viruses or a virus-like particles, organelles or other biological materials.
Questions for stakeholders include:
List of Existing Nanomaterials:
- Is the list of nanomaterials in Appendix A of this document a good preliminary reference list of existing nanomaterials in Canada?
- What additional criteria could be considered to identify existing nanomaterials?
- What methods can be used to collect information to develop a more comprehensive list or verify information on existing nanomaterials in commerce in Canada?
- What other sources of information are available to determine the commercial status of existing nanomaterials in Canada?
- What barriers exist to obtaining/providing information on existing nanomaterials in Canada?
Prioritization
- What factors should Environment Canada and Health Canada consider when prioritizing nanomaterials?
- What outcomes should Environment Canada and Health Canada consider when prioritizing nanomaterials?
Comments will be due 60 days after the document is posted on the Canadian Environmental Protection Act (CEPA) Environmental Registry. In June 2015, Environment Canada and Health Canada intend to conduct an information gathering survey and hold a stakeholder workshop to discuss the proposed approach and the information gathering survey.
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