ÿþ<img src='smalllogo.gif' alt='Logo' /><br/><h1>Groups outline position to Health Canada</h1><p>In a position paper delivered to Health Canada, seven leading health and environmental organizations, representing Canadians from across the country, have called for hazard and ingredient labelling of household products. </p>

<p>For the past two years, LEAS executive director Mae Burrows has represented the non-governmental public interest sector in a consultation forum with Health Canada that has been considering possible changes to labelling regulations. Representatives from the chemical producers and product manufacturers have also been part of the forum.</p>

<p>In May, 2007, after two years of discussion, it was clear that consensus on hazard labelling could not be reached and participants were asked to submit their positions. Together with the orther organizations, Burrows issued this position paper. Healther Logan, director of Cancer Control Policy for the Canadian Cancer Society also issued a supporting letter along with the paper.</p>

<h3><span style="font-weight: bold;">

<p>Position submission to Health Canada</p>

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<p><span style="font-weight: bold;">

<p>Chronic Hazards for Consumer Chemical Labelling</p>

<p>May 11, 2007</p>

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<p> </p>

<p><br/>

Submitted by <span style="font-weight: bold;">Mae Burrows</span></p>

<p>&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp; Non-governmental public interest sector</p>

<p><br/>

<span style="font-weight: bold;">Background</span></p>

<p>Health Canada has been managing a consultation process with various expert stakeholders from labour, public interest, and chemical manufacturers and distributors with a goal to find consensus on labeling chronic hazard chemicals in consumer products in Canada. This process has been called the Ad Hoc Expert Working Group: Chronic Hazard Implementation of Global Harmonization System: Chronic Hazards for Consumer Chemicals. The Labour Environmental Alliance Society (LEAS) through Mae Burrows has been representing the non-governmental public interest sector.</p>

<p>The group has arrived at consensus on the need to label products for chronic health hazards but could not arrive at consensus as to whether labeling would occur only when there was a proven risk to the consumer when exposed to the chemical in the product (risk based management) or if labeling was to occur if there was a known hazardous chemical (carcinogen, reproductive or developmental toxicant, or sensitizer) present in the product (hazard based labeling). The exception to this was consensus that germ cell mutagens would be labeled because safe thresholds of exposure cannot be determined.</p>

<p>Since the working group could not arrive at consensus on risk or hazard-based labeling, the sectors are submitting their views in a position paper. These position papers will be sent to Health Canada, as well as the Consumer Products Sectoral Working Group.</p>

<p><span style="font-weight: bold;">Public interest position</span></p>

<p>Recent public surveys by LEAS clearly show that Canadians are demanding that they are able to exercise their right to know by having labeling that informs of known and potentially toxic materials in consumer products. It is the view of the Non-Governmental Public Interest sector, as represented in the following signed organizations that products containing hazardous chemicals should have:</p>

<p>&bull;&nbsp;&nbsp; &nbsp;Full ingredient disclosure and hazard labeling of hazardous chemicals contained in consumer domestic-use manufactured products</p>

<p>&bull;&nbsp;&nbsp; &nbsp;Hazard labeling, using distinct symbols or letters for each hazard class, for all ingredients designated as carcinogens (labeled &ldquo;C&rdquo;), reproductive toxicants (&ldquo;R) and mutagens (&ldquo;M&rdquo;) according to IARC (Group 1, 2A, 2B) or the OEHHA (P65), reproductive and developmental toxicants' (&ldquo;D&rdquo;) according to P65 or the EU CMR list, as well as endocrine disrupting chemicals (&ldquo;EDs&rdquo;) listed EU and EPA, and sensitizers as listed in the&nbsp; EU directives and other reviewed lists acceptable to the international community. This would be in addition to current hazard labelling that indicates corrosive, flammable or explosive ingredients. In the alternative, Canada may consider adoption of the&nbsp; GHS standard symbols and hazard phrases for all these categories</p>

<p>&bull;&nbsp;&nbsp; &nbsp;Plain English and French prescribed risk phrases to accompany hazard symbols, such as &quot;the ingredient methylene chloride in this product has been designated as a possible human carcinogen.&quot; </p>

<p><span style="font-weight: bold;">The rationale</span></p>

<p>&bull;&nbsp;&nbsp; &nbsp;Consumers should have the same rights as employees in the workplace when it comes to exposure to hazardous chemicals in products. In the workplace, employees have a right to see full disclosure of ingredients in products that contain hazardous chemicals. They also have the right to be informed if any of those ingredients are classified as carcinogens, reproductive or developmental toxicants or sensitizers. Consumers should have that same right. MSDS are not available to consumers, nor required. Further, there is no system in place to ensure MSDS accuracy, nor education and training in their use. Consumer label information needs to address these gaps through full disclosure of hazardous ingredients and clear symbols.</p>

<p>&bull;&nbsp;&nbsp; &nbsp;Health Canada&rsquo;s priority should be to develop and enforce regulations to protect the health of Canadians. Ingredient and hazard labelling fulfills consumers&rsquo; right to know what chemical ingredients they may be exposed to and the potential health hazards associated with using them; however Health Canada&rsquo;s obligation to protect Canadians does not end with labeling hazardous chemicals in products. Control and bans of hazardous chemicals would be the next direct and required step.</p>

<p>&bull;&nbsp;&nbsp; &nbsp;Hazard-based labeling would follow the Precautionary Principle that states &ldquo;when an activity raises threats of harm to human health or the environment, precautionary measures should be taken even if some cause-and-effect relationships are not fully established scientifically&rdquo;</p>

<p>&bull;&nbsp;&nbsp; &nbsp;Disclosure of potentially toxic ingredients allows for consumer education about ingredient safety and toxicity as well as environmental sustainability and helps encourage the market for safer, environmentally preferable products.</p>

<p><br/>

Signed by: </p>

<p>Mae Burrows, Labour Environmental Alliance (LEAS) and CancerSmart Consumer</p>

<p>Kathleen Cooper, Canadian Environmental Law Association</p>

<p>Dr. Warren Bell, Canadian Association of Physicians for the Environment</p>

<p>Angela Rickman, Prevent Cancer NOW Coalition</p>

<p>Andrea Reimer, Western Canada Wilderness Committee</p>

<p>Deena Dlusy-Apel, Breast Cancer Action Montreal</p>

<p>Heather Logan, Canadian Cancer Society (sign-on by way of attached letter)</p>

<p><br/>

May 8, 2007</p>

<p>Ms. Mae Burrows, Executive Director</p>

<p>Labour Environmental Alliance Society</p>

<p>1203-207 West Hastings Street, Vancouver, BC</p>

<p>Canada V6H 1H7</p>

<p>SUBJECT:&nbsp; HAZARD BASED LABELLING </p>

<p>Dear Mae,</p>

<p>Thank you to learn more about the work of Health Canada&rsquo;s Multi-Sectoral Expert Advisory Committee and your role as a non-governmental Public Interest Representative on that group.&nbsp; The Canadian Cancer Society is aware of the position paper regarding hazard based labeling that was drafted by the Labour Environmental Alliance Society for submission to Health Canada, and offers the following comments in support:</p>

<p>1.&nbsp;&nbsp; &nbsp;The Canadian Cancer Society is supportive of hazards based labeling of all manufactured consumer based products in Canada. The announcement of Cosmetic Regulations in November 2006 was an important step forward in providing clear, understandable information for Canadians to enable them to make informed choices.&nbsp; The Society strongly believes that this approach must be expanded to include all manufactured consumer based products in Canada that informed consumer choice. </p>

<p><br/>

2.&nbsp;&nbsp; &nbsp;The Canadian Cancer Society&rsquo;s comments and support are limited to that part of the LEAS position paper that related to carcinogenicity and endocrine disruption, given that they are both within the mandate of the Canadian Cancer Society to address. While important to overall health, comments regarding the appropriateness of reference lists and labeling products with known mutagenic agents and/or reproductive toxins are outside the mandate of the Canadian Cancer Society. </p>

<p>The Canadian Cancer Society is committed to consumer product labeling and to identifying, in partnership with organizations like the Labour Environmental Alliance Society and the National Committee on Environmental and Occupational Carcinogens, potential models for a pan-Canadian approach to labeling. A single best practice has not yet been identified or endorsed by the Canadian Cancer Society.</p>

<p>Thank you for the opportunity to comment on the draft position paper on hazard based labeling and to contribute to your efforts to ensure informed consumer choice. If there are opportunities to engage in this discussion with Health Canada&rsquo;s multi-sectoral Expert Advisory Committee in the future please do not hesitate to let me know.</p>

<p><br/>

Sincerely, </p>

<p><br/>

Heather Logan</p>

<p>Director, Cancer Control Policy </p>

<p>Canadian Cancer Society</p>

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<br/><br/><br/><small>http://leas.ca/Groups-outline-position-to-Health-Canada.htm <br/>Updated: September 6, 2007</small>