By Josh Hosen
•
12 Jul, 2023
On June 17th, Health Canada published Regulations Amending the Formaldehyde Emissions from Composite Wood Products Regulations in Canada Gazette, Part I. The amendments are open for public comment until August 31st, 2023. These amendments serve to resolve several lingering issues from the original Regulations, including: 1.) QC test requirements: QC testing carried out routinely in production mills do not need to be accredited to ISO/IEC 17025. The amendments clarify that only the primary testing (i.e. initial qualification testing and quarterly testing) needs to performed by an accredited laboratory. 2.) Recordkeeping: the requirements for maintaining Declarations of Certification (DoC's) throughout the supply chain were revised to clarify these requirements for manufacturers, importers and sellers of component parts and finished goods. a.) Manufacturers of component parts and finished goods can now create an "attestation" document that includes the entity's address and contact information, and the third party certifier (TPC) information for each DoC received with panels incorporated into these products. These manufacturers must still retain copies of all DoC's they receive, as well as the attestation(s) they create, but they do not need to provide them to importers or sellers . b.) Importers and sellers of component parts and finished goods no longer need to receive and retain copies of all DoC's for the component parts and finished goods they import or sell, respectively; instead, they must receive and retain the attestations mentioned above. This removes some of the burdensome recordkeeping and supply chain confidentiality issues associated with the original requirements, which mandated they retain (and in the case of importers, pass along) all products' DoC's throughout the supply chain. 3.) Notice of non-compliant lots: The time period required to notify customers of a non-complying lot was revised from 48 hours to 72 hours to align with TSCA Title VI. Other minor amendments were made as well, and are worth reviewing if you are in any way impacted by CANFER. The amendments can be reviewed in their entirety here: Canada Gazette, Part 1, Volume 157, Number 24: Regulations Amending the Formaldehyde Emissions from Composite Wood Products Regulations . It is beneficial to have a copy of the original Regulations open for review as well, which is located here: Formaldehyde Emissions from Composite Wood Products Regulations (justice.gc.ca) . We know it's difficult to keep up with regulatory changes like these, and to fully understand how they impact you and your company. Capital Testing’s dedicated staff is here to help, so contact us today if you have any questions.