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FORMULATORFORMULATORFORMULATORApril2003April

2004

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

INSIDE:The GHS: A Globally Harmonized System of Classification and Labelling of Chemicals

Ontario’s Blue Box Program Up and Running – And You’re Included!

Step One – Defining the ConcernA major accomplishment towards rationalising HHW programmes!

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CCSPA Message ................................................................................5CCSPA Board of Directors 2004 .........................................................7CCSPA Staff 2004 ..............................................................................9FEATURESThe GHS: A Globally Harmonized System of Classification and Labelling of Chemicals ............................................................10By Terrance Persad

Ontario’s Blue Box Program Up and Running –And You’re Included! ......................................................................13By Dennis Darby

Step One – Defining the ConcernA major accomplishment towards rationalising HHW programmes!14By Stephen Rathlou

A.I.S.E.Uniting the European Cleaning Products Industry for more than 50 Years........................................................................16By Maarten Labberton

Product CareSM Continues to Grow..................................................18By Brigid Klein

Public Consultation with Environmental Civil Society ....................20By Barbara Schaefer

CONTENTS

FORMULATORFORMULATOR April2004

April2004

The Annual Magazine of the Canadian Consumer Specialty Products Association

The FORMULATORCanadian Consumer Specialty Products Association (CCSPA)130 Albert Street, Suite 800Ottawa, ON K1P 5G4Tel: (613) 232-6616Fax: (613) 233-6350E-mail: [email protected]: www. ccspa.org

BOARD OF DIRECTORS

ChairDennis Darby

1st Vice ChairBrian Tuffin

2nd Vice ChairHeather Allen

TreasurerJim Hunking

SecretaryBill Fitzpatrick

DirectorRene Brabender

DirectorAndré Azar

DirectorJay Pollack

DirectorDouglas Thiemann

Immediate Past ChairDavid Edge

CSPA DirectorChris Cathcart

Soap and Detergent DirectorErnie Rosenberg

Executive DirectorShannon Coombs

The FormulatorPublished by:

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

Tel: (204) 480-4400, Fax: (204) 480-4420www.mediaedge.ca

The FormulatorPublished for:

Canadian Consumer Specialty Products Association (CCSPA)

130 Albert Street, Suite 800Ottawa, ON K1P 5G4Tel: (613) 232-6616Fax: (613) 233-6350

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

Publisher: Robert ThompsonEditor: Rachel Naud

Editorial Consultant: Nancy HitchinsSales Manager: Andrew Pattison

Sales Representatives: Les Bridgeman, Hayden Dookheran, George Kamstra, Roberta Kellow,

Andrew Pattison, David Tetlock Art Director: Sean Rickner

Layout and Design: Kris GrapentineAdvertising Art: Demuth Flake

Cover photo courtesy of Jacques Lanctôt, Process Safety and Environment Director,

Recochem Inc., Napierville, Québec.

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.

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THE CCSPA FORMULATOR • 2004 5

CCSPA MESSAGE

Increasingly, major challenges to our industry sector have

an international com-ponent. This is to be expected in an economy where corporations, regulators and interest groups all operate glob-ally. As this global future unfolds, CCSPA and our members will need to speak out on interna-tional harmonization of regulations - supporting them proactively where they are beneficial and

pressing for uniquely Canadian solutions where ben-efits are absent.

As Maarten Labberton describes in this issue, the International Association for Soaps and Detergents and Maintenance Products (AISE) have spoken with a unified voice for a wide and international mem-bership during 50 years of unprecedented change in Europe. Similar to CCSPA, AISE has faced legislative challenges to the very core of its business operations. Its response has been a combination of voluntary pro-action (through product stewardship) and adjustment to new policy directives.

Particularly important for North American formula-tors to consider is how AISE has approached the EU Chemicals Policy - the proposed “REACH” system. Many of our members who do business in Europe are already aware of the costs and difficulties they will face meeting the stringent demands of this policy. We should also be aware that the ideas behind REACH could well appeal to North American regulators. When, in 1852, Victor Hugo wrote: “an invasion of armies can be resisted, but not an idea whose time has come,” he made no distinction between good and bad ideas!

This issue of The Formulator highlights two issues with international significance that are currently high on our list of priorities at CCSPA.

• Product Stewardship as a voluntary response to extended producer responsibility; and

• The Global Harmonization System for classification and labeling chemical substances and products.

Product Stewardship, or Extended Producer Responsibility, in our sector involves formulators in regulated and voluntary actions spanning the life cycles of their products. Proper post-consumer waste management is a major factor in the life cycle of for-

mulated products. Federal, provincial and munici-pal regulators across Canada are seeking ways to reduce the material and financial loads on municipal waste services and to pass the costs first from one to another and finally to the producer of the product. Packaging recycling programs are being developed across Canada. Currently in Ontario, these are being led by legislated stewardship under the Ontario Waste Diversion Act. Independently, numerous Household Special (or Hazardous) Waste collection programs have been established in many municipalities across the country.

Late in 1999 our association initiated and funded the development, by the Canadian Standards Association (CSA), of a new national standard for household haz-ardous waste (HHW). The purpose of the standard, as described in detail by Stephen Rathlou, was to “define the concern” as a precondition for managing the solu-tion. Specifically, the purpose of the standard is to put, on a rational basis, the physical and/or chemical crite-ria of products that support a requirement for special care to be taken in their post-consumer management.

With a team of stakeholders, from industrial, academ-ic, consumer, municipal and legal backgrounds, the finished standard was published in September of 2003. To our knowledge, it is the first rational, criterion-based definition of HHW in the world. The next steps for this standard will involve interpreting its technical content for consumers, municipal waste managers and producers and importers of consumer products. We are also engaged in promoting the standard to pro-vincial and federal government agencies responsible for environmental aspects of waste management.

Our colleagues in the United States have also been active in product stewardship. In December 2000, CSPA‘s voluntary program Product CareSM was approved and continues to grow and add new compa-nies to its participants. Both our efforts in Canada and those of CSPA reflect very clearly the value and inter-national character of voluntary actions by our sector to go beyond the demands of regulation.

In Canada, Ontario is leading the way on mandatory support from industry of municipal waste recycling programs. In previous issues of The Formulator, we have described the building of programs under the Ontario Waste Diversion Act. After a year of delays, the Blue Box Program is up and running. Starting in 2004, glass, metal, textile, plastic and paper packaging, and printed paper wastes are to be collected separately from residential sources by municipalities in Ontario, with 50 per cent of the program costs funded by indus-try “stewards.” As Dennis Darby (chair of Stewardship Ontario) describes it:

By Edwin BerrySenior Technical Advisor

6 THE CCSPA FORMULATOR • 2004

“Companies doing business in Ontario - whose prod-ucts’ packaging and printed paper can end up in resi-dential Blue Boxes or the municipal residential waste system - must register with Stewardship Ontario by April 20, 2004 to fulfill their obligations.” If your busi-ness meets these criteria (with some exemptions), you are included.

Turning now to matters of international regulatory harmonization. In December 2002, the United Nations Committee of Experts for the Transport of Dangerous Goods and the Globally Harmonized System for Classification and Labelling of Chemicals adopted the GHS and it is now ready for implementation. Canada played a lead role in the development of the GHS system and at the World Summit on Sustainable Development in August 2002, committed to the Plan of Implementation. Health Canada, as the lead agency, is moving quickly to implement the many changes that GHS will bring for manufacturers and importers of personal and household care products, as outlined in the article by Terrance Persad.

GHS is a Globally Harmonized System for classify-

ing and labelling hazardous chemicals. It consists of two elements: a) harmonized criteria for classifying substances and mixtures according to their health, environmental and physical hazards; and b) harmo-nized hazard communication elements, including requirements for labelling and safety data sheets. The GHS introduces standardized hazard symbols, signal words and hazard statements as part of its labelling requirements.

There is no question that for jurisdictions that have no (or minimal) appropriate regulations, GHS will provide substantial protection to workers and con-sumers. In Canada, these benefits are already largely available through the Consumer Chemicals and Containers Regulations, the Workplace Hazardous Materials Information System and the regulation of Transportation of Dangerous Goods. For Canadians, the benefits of GHS will be realized through harmo-nization on a global basis. However, until our major trading partners, particularly the United States, also fully implement the system, it is difficult to see what value will result from unilateral action in Canada.

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Shannon CoombsExecutive Director

CCSPA

CSPA Director

Chris CathcartPresident

Consumer Specialty Products Association

Soap & Detergent Director

Ernie RosenbergPresident & CEO

The Soap & Detergent Association (US)

Immediate Past Chairman

David EdgeVice President

Development and Quality AssuranceUnilever Canada

Director

Douglas ThiemannGeneral ManagerHome Hardware

Stores Limited

Director

Jay PollackVice President

Marketing The Nu-Gro Corporation

Director

André AzarDeputy to the President

Lavo Inc.

Treasurer

Jim HunkingGeneral ManagerQuixtar Canada

Corporation

2nd Vice Chair

Heather AllenGeneral ManagerReckitt Benckiser

(Canada) Inc.

1st Vice Chair

Brian TuffinPresident &

General ManagerS.C. Johnson and Son,

Limited

Chair

Dennis DarbyExternal Relations Officer – Canada

Procter & Gamble Inc.

Secretary

Bill FitzPatrickMarketing Manager,

CanadaEcolab Co.

Director

Rene BrabenderSales & Marketing Manager, Canada

Stepan Canada Inc.

CCSPA BOARD OF DIRECTORS 2004



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SHANNON COOMBS, EXECUTIVE DIRECTOR Shannon has a 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 where she handled all PMRA and cost recovery issues. Her responsibilities at CCSPA include managing all government relations activities for the Board of Directors and CCSPA Committees as well as issues such as the single jurisdiction for antimicrobials; environmental assessments; cost recovery; pest control regulation and GHS.

EDWIN BERRY, SENIOR TECHNICAL ADVISORWith a Ph.D. from the University of Surrey, Ed’s career in industry, government and consulting has ranged from basic research to corporate management. Since joining CCSPA in 1998, Ed has led the association’s stewardship responsibilities for post-consumer waste management and Household Hazardous Waste (HHW); regulatory work in the development of new classification and labelling regulations for consumer chemical products (CCCR); and the implementation of the Canadian Environmental Protection Act (CEPA). Starting April 1, 2004, in a new position as senior technical advisor, Ed will focus his efforts on the critical files pertaining to Categorization and Screening of the Domestic Substances List (CSDSL) and related CEPA issues.

NANCY HITCHINS, MANAGER, ADMINISTRATION & MEMBER SERVICESAs manager, 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.

CCSPA STAFF 2004



The GHS is a Globally Harmonized System for clas-sifying and labelling hazard-

ous chemicals. It consists of two elements: a) harmonized criteria for classifying substances and mix-tures according to their physical, health and environmental hazards, and b) harmonized hazard com-munication elements, including requirements for labelling and safe-ty data sheets. The GHS introduces standardized hazard symbols, sig-nal words and hazard statements as part of its labelling requirements and a 16-heading MSDS similar to the ISO format. Canada is moving quickly to implement GHS and is working toward having the system fully operational by 2008.

ScopeIn Canada, four sectors will be directly affected by GHS imple-mentation: consumer chemical products, workplace chemicals, pest control products and trans-portation of dangerous goods. GHS covers all hazardous chemi-cals, dilutions and mixtures. Pharmaceuticals, veterinary drugs, cosmetics and food additives will not be covered at the point of inten-tional intake, but will be covered where workers may be exposed and in transport. Hazardous wastes are not within the scope of GHS.

ImpactGHS will affect companies whose products are subject to CCCR (Consumer Chemicals and Containers Regulations) 2001, WHMIS (Workplace Hazardous Materials Information System), TDG (Transportation of Dangerous Goods) and/or PCP (Pest Control Products) regulations. Companies will typically be required, over a phase-in period, to learn and adopt new or modified criteria for hazard classifications, change labels for all impacted products sold in Canada, change all MSDS, modify com-puter and other operating systems used to generate labels and MSDS, modify staff-training programs on

hazard communication and trans-port of dangerous goods and, last but not least, absorb the cost of implementation.

BenefitsThe primary goals of GHS are to enhance protection of human health and environment, provide a framework for countries that do not have existing systems, reduce the need for duplicate testing and evaluation and facilitate interna-tional trade in chemicals.

BackgroundThe GHS is the culmination of more than 10 years of work, involv-ing individuals from a multitude of countries, international organiza-tions and stakeholder organiza-tions. Four major international organizations were involved in its development: 1) IOMC, the Inter-organization Programme for the Sound Management of Chemicals, co-ordinated the effort; 2) OECD, the Organization for Economic Co-operation and Development, provided expertise in establishing classification criteria; 3) ILO, the International Labour Organization, provided expertise in hazard com-munication; and 4) UNSCETDG, the United Nations Economic and Social Council’s Sub-Committee

A Gl bally Harmonized System of Classification & Labelling of Chemicals

By Terrance PersadRegulatory Manager, JohnsonDiversey Canada, Inc.


of Experts on the Transportation of Dangerous Goods, con-tributed to physical hazards. UNSCEGHS, the United Nations Economic and Social Council’s Sub-Committee of Experts on the Globally Harmonized System of Classification, has adopted inter-national responsibility for the GHS and endorsed the GHS for global implementation in July 2003.

Four major existing regulatory systems were used as a basis for the development of GHS: 1) Canadian Workplace, Consumer and Pesticides; 2) U.S. Workplace, Consumer and Pesticides; 3) UN Transport Recommendations; and 4) EU Directives on Substances and Preparations.

The GHS is a non-binding agreement, similar to the UN Recommendations for Trans-portation of Dangerous Goods. Countries and sectors within coun-tries will decide whether and how to implement. There is interna-tional consensus that all countries should have the GHS fully opera-tional by 2008.

Government of Canada Canada played a lead role in the development of the GHS system and committed to the Plan of Implementation at the World Summit on Sustainable Development in August 2002. Health Canada is the lead agency co-ordinating GHS implementa-tion in Canada and is working toward having the system begin phase-in by 2006 and fully opera-tional by 2008.

In February 2003, Canadian gov-ernment agencies presented GHS at the Government Interface in Ottawa. In September 2003, Health Canada issued a ‘Situational Analysis” document that provided a comparison between existing hazard classification and commu-nication systems in Canada and the Globally Harmonized System. The document also identified some issues that may need to be consid-ered during GHS implementation in Canada.

On Oct. 15, 2003, the Government of Canada held a GHS kickoff work-shop in Toronto. The workshop was

attended by 117 participants from Canada and the U.S. However, U.S. government officials were not present. Government of Canada officials responsible for CCCR 2001, WHMIS, PCP and TDG pre-sented a general overview on GHS, four sectoral presentations and an overview of their implementa-tion plan. This was followed by a panel discussion and a Q&A ses-sion. In the afternoon, participants attended breakout sessions aligned by the four sectors – Consumer, Workplace, PCP and TDG. These sessions were designed to solicit feedback from participants on issues and concerns with Canadian implementation and solutions to address the concerns. The sessions did not involve technical discus-sions on the Situational Analysis document released in September.

Primary concerns expressed by participants at the Oct.15 work-shop include: 1) harmonization with major trading partners, espe-cially the U.S., and within prov-inces, sectors and departments; 2) classification & labelling issues; 3) cost impact versus benefit; 4) training & education; 5) timelines for implementation; 6) impact on existing exemptions; 7) regulations development and the consultative process.

The Government of Canada is in the process of forming four mul-tistakeholder Sectoral Working Groups (Consumer, Workplace, PCP and TDG) and a multistakeholder GHS Co-ordinating Committee. The existing government-only Int-erdepartmental Committee, which prepares Canada’s position for international discussions, will now also focus on the implementation of the GHS in Canada.

CCSPA and GHSThe Canadian Consumer Specialty Products Association (CCSPA) is committed to working with govern-ment and other Canadian and U.S. associations to ensure a successful implementation of GHS in Canada. CCSPA has been monitoring GHS

GRA105_Graham Ad.eps 11/02/2004 9:41:00 AM


during the international develop-ment phase and has been actively involved in all aspects of Canadian implementation.

In February 2003, GHS in Canada was introduced at the CCSPA/Federal Government Interface in Ottawa. In June 2003, CCSPA representatives met with Health Canada to gather information on GHS implementation, establish the association as a key stakehold-er and to stress harmonization with trading partners, primarily the U.S.

In September 2003, CCSPA final-ized the formation of a CCSPA-GHS Working Group. The group is comprised of CCSPA members from Canada and the U.S., rep-resenting 23 companies, three associations and two consult-ing firms, and is structured into four sub-committees, Consumer, Workplace, PCP and TDG, align-ing with the government’s

GHS websitesUnited Nations:www.unece.org/trans/danger/publi/ghs/officialtext.html

Health Canada:www.hc-sc.gc.ca/english/about/ghs/index.htmlwww.hc-sc.gc.ca/francais/a_propos/ghs/index.html

Sectoral Working Group structure. The function of the CCSPA-GHS Working Group is to represent the association and member compa-nies, to be involved in discussion and development of internal and external strategies, and to interact with government and other asso-ciations on GHS implementation in Canada. In October 2003, the group analyzed Health Canada’s Situation Analysis Document by sectors and participated in all aspects of the Oct. 15 workshop.

CCSPA, through the GHS Working Group is fully represented on each of the multistakeholder Sectoral Working Groups and on the mul-tistakeholder GHS Co-ordinating Committee and will be participat-ing in upcoming meetings to be held by each of these groups to discuss and plan GHS implemen-tation in Canada. For information on GHS in general and/or involve-ment in CCSPA-GHS Working Group activities, contact the CCSPA office in Ottawa.


On Dec. 22, 2003, Ontario’s Environment Minister Leona Dombrowsky announced

approval of a plan that will direct industry to pay 50 per cent of the net cost of municipal Blue Box pro-grams for the collection of packaging waste materials in the province. As a result, beginning in early 2004, about $3 million each month will flow from industry to Ontario municipalities.

Announcing the program, the Minis-ter noted:

“This is a first step in our plan to dras-tically reduce landfill use. We plan on phasing in a ban on organic waste in our landfills because we believe that organic waste is a resource, not garbage.”

The Minister has also asked Waste Diversion Ontario to submit, by March 2004, a plan to expand the recovery of material suitable for blue boxes from the current 45 per cent to a target of 60 per cent by 2008. Under the current plan, it is projected that 50 per cent of Blue Box wastes will be diverted by the end of 2006.

Blue Box Program Plan – may be more than you thought!Blue Box waste is currently pre-scribed by Ontario Regulation: O. Reg. 273/02. It encompasses pack-aging and printed materials and a wide range of consumer products that consist of any of – or any combi-nation of – the following:

• Glass • Metal • Paper

• Plastic • TextilesWhat this means, in practice, is that stewards – brand owners and first importers of products into Ontario – are obligated to pay levies on these materials, whether or not a local municipality currently picks them up in the Blue Box. Except in the case of the de minimis described under “Exemptions”, there is no escape.

The plan, developed by Waste Diversion Ontario (WDO) and Stewardship Ontario, is designed to ensure the ongoing development and operation of Ontario’s Blue Box recycling system. It outlines specif-ics about diverting Blue Box wastes and how industry will pay for half the net costs of municipal Blue Box programs. It details how funding will be collected from industry and distributed to municipalities, and used to pay for program costs and for making the overall recycling system more efficient and effective and for market development, promotion and education.

WDO, created by the Waste Diver-sion Act in June 2002, is a permanent, non-Crown corporation made up of industry, municipal, non-government and government representatives. It is expected to oversee the various waste management programs that will be developed under the Waste Diver-sion Act over the following few years – including household special and organic wastes.

For the Blue Box program, Steward-ship Ontario has been designated by the Industry Funding Organization (IFO) to work with the WDO on the program and be responsible for its implementation – the collection of fees. Stewardship Ontario is made up of industry stewards – brand owners or first importers of products that are the source of Blue Box wastes – from whom fees will be collected, starting early in 2004. Subsequently, fees will be set annually. Meanwhile, $5 mil-

lion from the Liquor Control Board of Ontario – as part of an annual five-year commitment – will be provided for payment to municipalities and for its administrative costs.

Stewards and their ObligationsCompanies doing business in Ontar-io - whose products’ packaging and printed paper can end up in resi-dential Blue Boxes or the municipal residential waste system -- must register with Stewardship Ontario by April 20, 2004, to fulfill their obligations.

“Packaging” means all products made of paper, glass, metal, plastics, textiles or any combination thereof to be used for the containment, protection, handling, delivery and presenta-tion of goods, from raw materials to processed goods, from the producer to the user or the home consumer.

ExemptionsTo ease the burden on small busi-nesses, Stewardship Ontario has established the following de minimis thresholds for determining if a stew-ard is required to register:• Stewards of Blue Box wastes with

2002 Ontario gross revenues from sales of less than $2 million are exempted from paying fees to Stewardship Ontario and, further-more, are not obligated to register with Stewardship Ontario in the first year of the program.

• Stewards with 2002 Ontario gross revenues from sales more than $2 million are above the de mini-mis threshold and will be required to register. However, following registration, stewards that gener-ated less than 15 tonnes of Blue Box packaging and printed paper materials in 2002 are also exempt-ed from year one of the program.

Full details of obligations, exemp-tions, and how to register and calculate fees are available from the Stewardship Ontario website, www.stewardshipontario.ca/main.asp.

Ontario’s BLUE BOX Program Up and Running...And You’re Included!

By Dennis DarbyChair of the Board, Stewardship Ontario; Chair of the Board, CCSPA


CCSPA initiated and funded the development of a new national standard by the

Canadian Standards Association (CSA) to define household haz-ardous waste (HHW ) using a risk-based approach and scien-tific criteria. CCSPA also developed the seed document that started the development process. A CSA multi-stakeholder technical com-mittee was convened, chaired by Stephen Rathlou of S.C. Johnson and Son, and the first draft stan-dard was produced in May 2000. After a rocky journey, controversy and debate and 15 drafts, the group finally achieved consensus and the finished standard was published in September 2003. To our knowl-edge, this is the first rational, cri-teria-based definition of HHW in the world.

Across North America, a grow-ing number of municipal waste diversion programmes encompass what is commonly known as HHW. Typically, these wastes are “defined” by lists of product categories that include items such as “household cleaners,” “solvents,” “pesticides,”

etc. These lists fail to recognise that there is a wide range of proper-ties within each broadly described item. For example, baking soda is widely touted by non-government environmental organisations as a “household cleaner.” The most widely used “solvent” is water. And diatomaceous earth (silicon diox-ide) is a relatively inert and non-toxic “pesticide.” None of these, nor many other wastes, deserve the description of “hazardous.”

With all good intentions, these pro-grammes are focussed on protect-ing the environment and reducing waste. The reality is that only a very small fraction of household waste is hazardous – less than one per cent. And only a fraction of that one per cent has potential for environmental impact when disposed of in an approved land-fill operation. So, there is little potential for either environmental protection or for extending landfill capacity through special diversion programs for HHW (even as com-monly defined). However, we do recognise the more real concern of risk to private and municipal work-ers when truly hazardous materials are included in regular household wastes.

HHW programmes are expensive – as much as 10 times the cost of normal disposal – and funding is limited. It is critical then to the sustainability of these programmes that they focus on only those wastes that truly present a risk. There are more efficient ways to divert general and special wastes

without taking resources away from HHW programmes.

This new CSA standard – Z752-03, Definition of Household Hazardous Waste has already been viewed by several provincial and municipal governments and Environment Canada and can be used immediately in discussions regarding policy, codes of practice and stewardship. Manufacturers can use Z752 now to assess their formulations with regard to the potential classification of leftover products. However, the standard is a technical document written primarily for brand owners/formu-lators of household products. As a result, it is difficult for consumers to understand, or for municipali-ties to apply, either to their pro-grammes or to public education.

To realise the full potential of this standard, some next steps are required.

The standard needs to be “trans-lated” into user-friendly, actionable information, without reverting to the “list paradigm.” This means finding a way of helping consumers and municipalities identify those wastes that are described by the standard. In the short term, this may involve some less-than-ideal methods, for example, reference to some hazard symbols required by the Consumer Chemicals and Containers Regulations. Longer term, a more efficient and accurate system needs to be established that is directly connected to the standard.

Step One: Defining the Concern

A major accomplishment towards

rationalising HHW programmes!

By Stephen Rathlou, P.Eng.Manager, Regulatory AffairsS.C. Johnson and Son, Limited


The standard needs to be pro-moted – i.e., key decision-makers at the municipal and provincial levels need to understand and buy in to the standard. This will require some effort to present and dis-cuss the standard in a number of fora. It is a sensitive issue, and we are thankful that we have had the involvement and support of some respected municipal members on the CSA Technical Committee. At this time we have three organisa-tions that have expressed inter-est in promoting the standard. These opportunities are being pursued now.

The standard may be used as a solid and defensible basis to:• reduce costs of new and existing

HHW programmes;• ensure that truly hazardous

wastes are excluded from the

regular domestic waste stream;• aid programmes in safely con-

solidating categories of HHW, improving efficiency and safety; and

• standardise stewardship pro-grammes across Canada, allow-ing for national consumer educa-tion, consistent with the national marketing of our products.

Industry participants on the CSA technical committee included Ed Berry (CCSPA), Glenn Parker followed by Kevin Mahoney (Procter & Gamble), John Owens (S.C. Johnson), Robert Hamilton (Access Business Group), and Terry Goulding (CPCA).

Also active on the technical committee were: University of Waterloo, Trent University, AMRC and the Municipality of Waterloo,

Recycling Council of Alberta, Consumers Association, City of Toronto, Regional Municipality of Niagara, Municipal Enforcement Sewer Use Group, the Canadian Bar Association and Environment Canada.

This CSA standard is a major suc-cess that many said could not be achieved and we should be proud. However, the standard is only a tool. How we use this tool to its greatest potential depends on tak-ing the next steps. And timeliness is critical as provinces consider extended producer responsibil-ity and stewardship programmes – funded at least, in part, by brand owners. We should not miss any opportunities to promote the use of this standard as these activi-ties proceed.

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A.I.S.E.Uniting the European Cleaning Products Industry for more than 50 Years

Based in Brussels, Belgium, A.I.S.E. (the International Association for Soaps,

Detergents and Maintenance Products) is the official body rep-resenting these sectors through the national associations of 30 countries, primarily in Europe. Combined membership of the national associations totals some 900 companies, of which many are small and medium-sized enterpris-es (SME). A significant proportion are also active in the industrial and institutional (I&I) domain.

The strength of A.I.S.E. centers around its ability to act as a voice for all its members, whether large or small. A.I.S.E. has been in existence for more than 50 years, during which the industry has wit-nessed unprecedented progress, heightened innovation and the production of safer and more envi-ronmentally friendly products for

both household and I&I markets. The main themes of our work are: innovation, safety and hygiene. It is the goal of A.I.S.E. to support our members’ efforts to supply essen-tial and consistently high quality products to:

• satisfy the differing needs of 500 million European consumers;

• ensure the products are safe for use in their homes; and

• constantly improve all aspects of their impact on the environment.

Legislative challengesAs membership in the European Union (EU) has grown, and with increasing prosperity, legislative directions have changed from a mainly economic focus to increas-ingly include the environment, human health and consumer policy. We at A.I.S.E. have always been involved in the legislative ini-tiatives of the European authorities affecting our industry.

A.I.S.E. has always been deeply involved in providing industry expertise and support to the European authorities on legisla-tive developments. Besides recent examples on the Dangerous Pre-p arations/Substances Directives and Biocides Directive, the associa-tion is particularly involved in the Detergents Regulation and the new European Chemicals Policy.

Voluntary actionThroughout the years, our industry has worked with its stakeholders

in an effective and objective way by launching several voluntary initiatives supporting this goal. Notable has been “The Code of Good Environmental Practice for Household Laundry Detergents.”

Drafted in 1996, this voluntary initiative resulted in an EC recommendation two years later. The starting point of the code was our appreciation of a change of emphasis in the public debate about our products and the environment. The focus correctly switched to the washing process as a whole. Thus product ingredients, packaging, manufac-turing, distribution and disposal are all seen to play an important role alongside the actual use of detergents in the washing machine. In this way, it is clear that changes of environmental impacts are necessary throughout the overall life cycle of the washing process.

In 1997, European laundry detergent manufacturers began to formulate, within A.I.S.E., an ambitious plan in which they would participate with the support of consumers. One hundred seventy (170) compa-nies in 15 EU Member States plus Iceland, Norway and Switzerland – covering more than 90 per cent of the European market – committed themselves to make substantive voluntary contributions to envi-ronmental goals throughout a five-year period ending in 2001. The

By Maarten LabbertonDirector-GeneralAISE (Association Internationale de la Savonnerie, de la Détergence et des Produits d’Entretien)


final results showed an impressive decrease in the use of poorly bio-degradable ingredients and impor-tant reductions in:

• consumption of household laun-dry detergents;

• energy use; and• packaging

In parallel, consumers have been provided with a series of tips on how to use our products in a more sustainable way. This was achieved through a unique pan-European campaign called “Washright,” symbolized by a white T-shirt with an open washing machine door on the front. The Washright campaign included on-pack messages on 500 million packages sold every year, an Internet website and a TV campaign throughout the last three years. The aim of each year’s TV campaign – with TV spots in the main European languages broad-cast at peak viewing times – was to reach at least 70 per cent of all European consumers twice – a goal we have largely met.

Complementary to the Washright recommendations, we have devel-oped a standard system to inform consumers of the number of wash-es in a detergent pack – be it a pow-der, a liquid or a unit dose prod-uct. This increased transparency enables consumers to judge value more clearly. In some countries, retailers can show price per wash on shelves – a high degree of trans-parency, which we applaud. We are very pleased that the European Commission has recognized this

and inserted a similar require-ment in the draft EU Detergent Regulation, one of our legislative challenges frequently discussed these days, particularly within the European Parliament.

The new EU chemicals policyThe Commission’s Strategy for a Future Chemicals Policy introduc-es a plan for chemicals manage-ment called REACH (Registration, Evaluation, Authorisation of CHemicals). The proposed REACH system foresees targeted risk assessment procedures for all chemicals above one tonne per year per manufacturer in the EU, as well as a specific authorization procedure for chemicals, poten-tially of high concern. It is based on the key concepts of risk assessment and shared responsibility at all stages. The future policy places the responsibility on industry to ensure the safety of its products, from the point of production of a substance through its life cycle and along the distribution chain.

A.I.S.E. is broadly supportive of the revision of the Future Chemicals Policy and is committed to help shape the content of the forth-coming regulations and commu-nicate the industry’s views on the REACH system to all interested parties. However, the proposal should become more workable and less burdensome, particu-larly for smaller companies; and the concept of risk assessment as promoted in the industry’s HERA

initiative should be more clearly recognized. HERA is the joint proj-ect on Human and Environmental Risk Assessments on ingredients of household cleaning products run by the main A.I.S.E. and chemical supplier companies.

The industry has always been responsive to consumer demand for more product performance and convenience, while maintaining human and environmental safety and improving environmental quality. As a responsible industry, A.I.S.E. and its members are com-mitted to applying the concept of sustainability.

During the course of 2004, A.I.S.E. hopes to launch its new initia-tive, the Charter on Sustainable Development. Commitment to the Charter is voluntary and open to any company belonging to the European detergent, cleaning and maintenance products industry. By committing, companies undertake to apply the concept of sustain-ability to their operations and to measure and report the annual progress they make in improving their sustainability, using key per-formance indicators.

A.I.S.E.’s pledge is to continue working with its partners in civil society, government and industry to develop innovative solutions to ensure a better quality of life for all in Europe.

For further information on A.I.S.E., its work and activities, please visit its website, www.aise-net.org.


Product CareSM Continues to Grow

Product CareSM, CSPA’s voluntary stewardship program, has grown con-

siderably since it was approved in December of 2000. Today, the program has 63 members and counting!

Product Care is a stewardship pro-gram for the consumer and insti-tutional specialty products indus-try co-ordinated by the Consumer Specialty Products Association. Participating companies have agreed to go beyond govern-ment regulations in emphasizing health, safety and environmental concerns by carefully designing products, purchasing raw mate-rial and packaging, operating safe manufacturing facilities, promot-ing safe storage and distribution, providing useful product informa-tion, answering consumers’ ques-tions and anticipating product disposal needs.

As we continue to add new com-panies to our membership roster, Product Care is also continuing to offer introductory and advanced training workshops. Companies that have never before had a product stewardship program receive guidance on the concepts of stewardship and the benefits of membership in Product Care. Companies that already have a

stewardship program in place are shown where Product Care would fit into their current operations. Both groups are given Product Care-specific guidance on how to conduct a self-assessment, or evaluation, of ongoing efforts or programs.

Additionally, Product Care has developed a variety of resources for its members. The first of these is a Product Care CD that con-tains information tools to help in recruitment and serve as a refer-ence guide for current program participants. The CD incorpo-rates Power Point presentations and templates for external news releases and internal employee communication venues. The CD was distributed at the 90th CSPA Annual Meeting in December 2003.

Product Care has also recently completed two website projects. The first is the development of www.productcare.com, which is aimed at explaining the program to consumers and a general audi-ence. The second effort focuses on a redesign of the Product Care section on the CSPA website at www.cspa.org. Both projects were unveiled at CSPA’s Annual Meeting in December 2003.

For further information on Product Care, please contact Brigid Klein at 202-872-8110 or [email protected].

By Brigid KleinAsst. General CounselConsumer Specialty Products Association


1. A & V, Inc.*

2. Access Business Group of Alticor, Inc

3. ACCRA PAC, Inc.*

4. Acuity Specialty Products Inc/ZEP

5. Aerofil Technology Inc.

6. Aeropres Corporation

7. Arylessence, Inc.

8. BBJ Environmental Technologies, Inc.

9. Buckeye International, Inc.*

10. CCL Custom Manufacturing, Inc.

11. The Clorox Company

12. Crown Cork & Seal Company

13. The Dial Corporation

14. Diversified CPC International, Inc.

15. The Dow Chemical Company

16. Ecolab, Inc.

17. EMSAR Incorporated

18. Expo Chemical Company, Inc.

19. ExxonMobil Chemical Company

20. Faultless Starch/Bon Ami Company

21. Formulated Solutions

22. Fuller Brush Co., Inc.

23. John R. Hess & Company, Inc.

24. Hillyard Industries, Inc.*

25. Hydrosol, Inc.

26. I-K-I Manufacturing Co., Inc.

27. Industrial Hydrocarbons, Inc.

28. Interpolymer Corporation*

29. JohnsonDiversey, Inc.

30. KO Manufacturing, Inc.

31. L & G Cleaning Products, Inc.

32. Lonza Inc.

33. Lumi-Lite Candle Co., Inc.

34. McLaughlin Gormley King Company*

35. Michelman, Inc.

36. Microbiotest, Inc.

37. NCH Corporation

38. Novozymes Biologicals, Inc.

39. OMNOVA Solutions, Inc.

40. Outsourcing Services Group, Inc.

41. Plaze, Inc.*

42. Precision Valve Corporation

43. Procter & Gamble Company, US Fabric & Homecare

44. PROSAR/International Poison Center*

45. Reckitt Benckiser

46. Recochem, Inc.

47. Rhodia

48. Rocky Mountain Poison and Drug Center

49. Rohm and Haas Company

50. S.C. Johnson & Son, Inc.*

51. SeaquistPerfect Dispensing

52. Shaw Mudge & Company

53. Spartan Chemical Company, Inc.*

54. Speer Products, Inc.

55. State Industrial Products

56. Stepan Company

57. Summit Packaging Systems, Inc.

58. Technical Propellants, Inc.

59. Troy Chemical Industries, Inc.

60. Uniqema

61. United States Can Company

62. WD-40 Company

63. Zobele Industrie Chimiche Spa

PRODUCT CARESM PARTICIPANTS (January 2004)

*companies that have renewed their commitment to Product Care


By Barbara Schaefer,Consultations Co-ordinator

The Canadian Environmental Network (CEN) has been facilitat-ing networking among environ-

mental organizations since 1977. When it was established, the CEN’s objective was to support and strengthen the participation of environmental non-government organizations (ENGOs) in their consultations with Environment Canada. Since then, the CEN has strived to broaden its scope. Today, assisted by financial support from Environment Canada, it provides co-ordination, communication, research and networking services to more than 800 Canadian environmental groups affiliated through one of CEN’s 11 regional (provincial and territorial) networks.

The CEN is an independent, non-par-tisan organization that does not take positions on environmental issues. Rather, the CEN actively encourages and supports those who take part in public consultation processes, par-ticipate in working groups or who are delegates to national and international conferences.

The CEN is favoured by federal gov-ernment departments hosting public consultations because of its delegate selection process, which is transparent,

bilingual and supported by the envi-ronmental community for its ability to reach policy makers.

The consulting, support and network-ing services, originally developed for Environment Canada, are now being used by other ministries and govern-ment organizations. The growing list includes: Canadian International Development Agency, Natural Resources Canada, Human Resources Development Canada, Foreign Affairs and International Trade, Canadian Environmental Assessment Agency, Canadian Council of Ministers of the Environment, International Development Research Centre, Health Canada and Canada Mortgage and Housing Corporation. The CEN’s egalitarian working practices have also engendered partnerships with unions, private business, and universities.

The CEN co-ordinates the work of national caucuses made up of partici-pants drawn from its affiliated mem-ber groups. These caucuses address issues of environmental concern such as atmosphere and energy, biological diversity, biotechnology, environmen-tal planning and assessment, envi-ronmental economics, environmental education, agriculture, forests, health, mining, toxics and water.

Working groups are often formed

by the caucuses to support the par-ticipation of CEN members, in spe-cific public consultations that focus on critical issues. Examples include: the development of “best practices” in environment; the establishment of legislative reforms; the development of the Harmonization Accord; and bringing representatives to official Canadian delegations for international meetings such as the World Summit on Sustainable Development.

Caucuses are bodies of the CEN – self-directing but subject to CEN bylaws and policies. Caucus members determine the priority issues and activities upon which they will focus. Members elect a steering committee responsible for administering caucus affairs. Generally, caucus members get together as often as possible, allowing the free flow and sharing of informa-tion, concerns and experiences among environmental groups from across the country.

Caucuses select ENGO delegates to participate in government consulta-tions, guided by CEN policy, which requires balanced representation of delegates according to gender, lan-guage, issue concerns, region and urban or rural location. The CEN’s democratic delegate selection process is designed to prevent “cherry picking” of ENGO delegates for government consultations.

In order for the CEN to maintain its objectivity, caucus delegates speak for themselves and their respective orga-nizations only. Delegates are, however, required to report back to the caucus where the ensuing discussion assists in the formation of an overall strategy for environmental conservation. Caucuses facilitate joint positions and cam-paigns, though not in the name of the caucus, per se, but rather in assistance to loose coalitions and signatories.

The CEN itself will take a position only on the consultative process itself. This policy is intended to protect the demo-cratic, inclusive nature of the CEN and its caucuses, and to ensure that groups are not associated with positions unless they choose to be.

For further information, please call the CEN office at 613-728-9810 or visit its website, www.cen-rce.org.

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The Canadian Consumer Specialty Products Association (CCSPA) is a national trade association representing the consumer, industrial and institutional specialty products industry.

Reaching those in Canada and the U.S. responsible for manufacturing, marketing, processing, packaging and distributing consumer, industrial and institutional specialty products, The Formulator is a great venue to spread the word about your business.

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Index to Advertisers

ChemicalsDupont .............................................. 6Mississauga, ON

ConsultantsScientific & Regulatory Consultants ....................................... 8Columbia City, IN

Consulting & Compliance TestingDell Tech Laboratories Inc. ............ 21London, ON

Custom Manufacturing & ContainersCCL Industries Inc.......................... 18Willowdale, ON

Custom PackagingNu-Gro Corporation....................... 18Brantford, ON

Dispensing SystemsSeaquist Canada Inc. ........................ 8Concord, ON

Fragrance CompoundsCompagnie Parento........................ 21Toronto, ON

Fragrance ManufacturersBelle-Aire Fragrances Inc. .............. 21Mundelein, IL

Fleurarome Ltee ............................. 21St. Eustache, QC

Hydrocarbon Aerosol PropellantsDiversified CPC International ....... 22Channahon, IL

Industrial & Consumer ChemicalsRecochem Inc. ................................ 15Brampton, ON

Lawn Care ProductsScotts Canada ................................... 8Mississauga, ON

Lawn & Garden ProductsNu-Gro Corporation....................... 18Brantford, ON

Manufacturer-Consumer ProductsProcter & Gamble Inc. .................. IFCNorth York, ON

Microbiology & Virology Testing LaboratoriesMicrobiotest, Inc. ....................... OBCSterling, VA

Packaged GoodsSC Johnson & Son, Ltd. .................. 12Racine, WI

Packaging SolutionsStull Technologies............................. 8Somerset, NJ

Plastic PackagingGraham Packaging Canada Ltd. .... 11Mississauga, ON

Plastic ContainersCousins – Currie Ltd....................... 20Woodbridge, ON

Protective ProductsAnsell Canada Inc. ........................ IBCCowansville, QC

Regulatory & Technical ConsultingTechnology Sciences Group Inc. ... 17Washington, DC

Specialty ChemicalsCognis Canada Corp......................... 8Mississauga, ON

ISP (Canada) Inc. ............................ 22Mississauga, ON

SurfactantsAjinomoto U.S.A., Inc....................... 4Paramus, NJ

Stepan.............................................. 22Mississauga, ON

ISP (Canada) Inc.4055 Sladeview Cr. Unit 7Mississauga, Ontario L5L 5Y1

Tel. 905-607-2392 Fax 905-607-9086

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