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July 5, 2010: New Update on Canadian Chemical Management Program Regarding the Proposed Rosin Flux Ban

The risk management scope documents have been published for the substances for the Batch 10 of the Challenge. Detailed documents can be found on the Eco Action website here.

October 27, 2009: Update on Canadian Chemical Management Program Regarding the Proposed Rosin Flux Ban

The October 20th deadline to submit information to the Canadian Chemical Management Program has passed.  Hopefully, we have all made them aware of the severity of controlling or banning the five substances. The question is now what are the next steps?

Once the risk evaluators have considered the information sent by industry, they will write a draft Screening Assessment Report, which will contain their rationale for coming to the conclusion that the substance is/is not “toxic” (as defined in the Canadian Environment Protection Act). If they decide on “toxic”, there will also be a Risk Management Scope, which will describe what measures should be taken towards the substance (ban, control, nothing at all). After these documents are published (expected publication date is June 26, 2010), there will be a 60-day comment period during which anyone can comment on the document, methods of analysis, data considered, conclusions, etc. The comments and Environment Canada’s responses get published, so we can consult them. Then, the final Screening Assessment Report and Risk Management Approach will be published (anticipated on December 25th, 2010), taking into account the comments we received. Another public comment period, then the risk managers have 24 months to prepare the proposed risk management instrument (the regulations), then more public comments, then a final risk management instrument 18 months later. With these time lines, our industry will get many opportunities to communicate our concerns to the government.  If  you officially submitted some information, you will be considered a “Stakeholder” and put on a list so that anytime something is published, you will be made aware. If you did not submit information, you will have to check the government's web site or stayed tuned to Adtool's Eco-Action section for further details on the Canadian Chemical Management proposal to ban or control rosins in fluxes.

Enviroment Canada currently could not say what would happen if the substance was banned, or if it’s even a possibility, but we have to remember that the main concern when it comes to these substances is the likelihood of the substance being released in the environment in a quantity or conditions (to cite CEPA) that it may cause harm to the environment. This is not only dependent on the quantity that is used throughout the country, but also on the form it is used in. This is where the risk assessors have to use their knowledge of the chemistry of the substance.  

(Source: communications with Evironment Canada)


September 2009:

To all of our customers:

Below is the info on the proposed control or banning of Five Rosin and Resin acids identified under Batch 10 of the “EcoAction Initiative” that are used in fluxes.  Adtool, one of our suppliers Koki as well as some local media and our customers & competitors are lobbying against it.  We have also written our local MP’s as well to inform them of our position. Please ensure to follow the direction on Environment Canada's web site below as well as your local MP's to make them aware of the implications of this proposal.

We will also be working on adding sections with updated information as we recieve it. The 1st deadline on the Government's agenda is October 20th, 2009 so it is imperitive we act.

A PDF form to send to the government is available to download here in Acrobat and here in Word.

The official CAS# affecting all of us are:

  • CAS# 64365-17-9; Resin acids and Rosin acids, hydrogenated, esters with pentaerythritol
  • CAS# 65997-06-0; Rosin, hydrogenated
  • CAS# 65997-13-9; Resin acids and Rosin acids, hydrogenated, esters with glycerol
  • CAS # 68648-53-3; Resin acids and Rosin acids, hydrogenated, esters with triethylene glycol
  • CAS# 124751-15-1; Resin acids and Rosin acids, fumarated, barium salts

  • Details on the proposal and the process to argue against it: 
    ecoaction

    http://www.chemicalsubstanceschimiques.gc.ca/challenge-defi/batch-lot-10/index-eng.php (opens new page).


    Government Contact Information:

    Completed questionnaires or requests for additional information should be sent to:

    DSL Surveys Coordinator
    Chemicals Management Plan

    Gatineau (QC) K1A 0H3
    Telephone: 1-888-228-0530 (in Canada) or 819-956-9313
    Fax: 1-800-410-4314 (in Canada) or 819-953-4936
    E-mail: DSL.surveyco@ec.gc.ca


    Media Releases:

      EP&T
     

    EP&T Article:

    September 25, 2009
    October, 2009


    IC

    IPC's comments on the proposal dated Oct 1, 2009 (Adobe Format)pdf. Click to download.

    IPC's web page with an overview of the situation. Click here to open.


    Our orriginal source of this alert is from the IPC on August 28th, 2009

    IPC Government Relations Alert
    Dear Colleagues:
    I am writing to let you know of a proposed Canadian regulation targeting the elimination of several substances that may be vital to the electronics industry.
    On June 20, the Canadian government released a list of substances that could be slated for elimination, including three substances that are critical, functional ingredients in solder flux:

    1. Rosin, hydrogenated;
    2. Resin acids and Rosin acids, hydrogenated, esters with triethylene glycol; and
    3. Resin acids and Rosin acids, hydrogenated, esters with glycerol.

    Without action from industry, these substances are likely to be restricted under Canada's Chemical Management Program which aims to regulate 200 chemical substances categorized as being potentially harmful to human health and/or the environment. Below is a short background on this program:
    Canada's Chemicals Management Program is a part of the Canadian Environmental Protection Act of 1999 and is the first chemicals program to categorize chemicals. The ultimate goal of the program is to improve protection against hazardous chemicals. The program involves a variety of measures to ensure the proper management of chemicals: information on proper use and disposal; regulations to restrict and possibly ban chemicals; and a risk-based, science-based approach to chemical assessments. The government has instituted a science-based regulatory system to improve assessment and mitigation of risks to ensure the proper management of chemicals.
    Every three months, the Canadian government publishes batches of 10-25 substances from the list of 200 chemical substances. Industry and stakeholders will have six months to provide comments once a batch is released on how the Canadian government should proceed forward. The government will take one of the following actions on chemicals once the comment deadline is complete: no action, put the chemical on a Priority Substances List for further assessment, or recommend the chemical be added to the List of Toxic Substances with the possibility of virtual elimination.
    IPC is working with our members, especially the IPC Solder Value Products Council, to gather more information about these substances and their use in solder products, particularly flux. We would appreciate your feedback on the effect of this ban on your business. Once we have gathered sufficient information, we will prepare comments for submission to the Canadian Government on behalf of the industry.
    Please send your comments, feedback and questions about the Canadian Chemicals Management Program to Stephanie Castorina (StephanieCastorina@ipc.org) or Fern Abrams (fabrams@ipc.org) or call IPC's Environmental Policy Office at +1 703-522-0225.
    Sincerely,
    Anthony Hilvers
    Vice President of Industry Programs
    IPC — Association Connecting Electronics Industries®
    3000 Lakeside Drive
    Suite 309 S
    Bannockburn, IL 60015-1249 USA
    +1 847-597-2837 tel
    +1 847-615-5675 fax
    www.ipc.org

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