CCCR Record Keeping Requirements

                                                                                         

Many chemical companies are unaware that it is not enough to just have compliant labels. Companies are also required to keep records of how they determined a particular CCCR classification. Section 5 of the Consumer Chemicals and Containers Regulations, 2001 states:

“The person responsible must

(a) keep or cause to be kept, for a period of at least three years after the date of manufacture or importation of a chemical product or container, all records relating to the determinations required under subsection 4(1); and

(b) within 15 days after receipt of a request from an inspector, provide the records referred to in paragraph (a) to the inspector."

The determinations of subsection 4(1) (which are referred to in part a) are as follows:

"The person responsible, 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. "

Section 12(1) on child-proof containers contains the following record-keeping requirements

"The person responsible must keep or cause to be kept, for a period of at least three years after the date of manufacture or importation, the following information:

(a) for a container that comes into direct contact with the chemical product, the specifications critical to the child-resistant characteristics of the container, which specifications must include

(i) the physical measurements within which the container retains its child-resistant characteristics,

(ii) if applicable, the torque that must be applied to open or close the container, and

(iii) the compatibility of the container and its closure system with the chemical product that is to be put into it; and

(b) the test results that demonstrate that the container and its closure system comply with the requirements of a standard set out in paragraph 9(b)."

A responsible chemical manufacturer can often provide these CCCR records within 15 minutes, not 15 days.

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