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|Lynn L. Bergeson
Bergeson & Campbell, P.C.
On August 24, 2013, Canada issued a significant new activity (SNAc) notice for multi-walled carbon nanotubes (MWNCT).
August 26th, 2013
Canada Issues SNAc for MWCNTs
On August 24, 2013, Canada issued a significant new activity (SNAc) notice for multi-walled carbon nanotubes (MWNCT). See http://www.gazette.gc.ca/rp-pr/p1/2013/2013-08-24/html/notice-avis-eng.html#d104 The notice states that MWCNTs are not included on the Domestic Substances List and that "a significant new activity in relation to the substance may result in the substance becoming toxic within the meaning of section 64 of the Canadian Environmental Protection Act, 1999." The notice defines substance as "short tangled multi-walled carbon nanotubes" that have the following characteristics:
(a) At least 90 percent of the substance is composed of elemental carbon;
(b) The nanotubes measure from 0.09 to 10 micrometres in length, with a 1.1 micrometre average; and
(c) The diameter of the nanotubes measures from 5 to 25 nanometres, with a 12 nanometre average.
A significant new activity in relation to the substance is:
(a) Its manufacture or import in a quantity greater than 100 kilograms (kg) per calendar year when it is to be used:
(i) In consumer products as defined in Section 2 of the Canada Consumer Product Safety Act, excluding solid plastic products; or
(ii) In products intended for use by or for children from 0 to 6 years old; or
(b) In all other cases, its manufacture or import in a quantity greater than 10,000 kg per calendar year.
The notice states that despite the above restrictions, "the manufacture or import of the substance to be used to manufacture an export-only product is not a significant new activity when the manufacturing process of the product results in releases of the substance to the aquatic environment in a quantity not exceeding 1 kg per day per site after wastewater treatment." In addition, the manufacture or import of the substance to be used as a research and development substance is not a significant new activity. Information that must be provided prior to the commencement of a proposed significant new activity includes analytical information to determine the length and diameter of the substance, as well as information describing the primary and secondary particle size, agglomeration or aggregation state, shape, chirality, surface area, and surface charge of the substance; a brief description of the manufacturing process that details precursors of the substance, reaction stoichiometry, nature (batch or continuous), and scale of the process; analytical information to determine the leachability potential of the substance and its precursors from any final product resulting from the significant new activity; and analytical information to determine the dispersibility of the substance in the most significant environmental media related to the significant new activity. If the substance will be manufactured or imported in a quantity greater than 10,000 kg per calendar, the notice specifies additional test data that must be submitted. Manufacturers or importers must identify "every government department or government agency, either outside or within Canada, to which the person proposing the significant new activity has provided information regarding the use, manufacture and import of the substance and, if known, the department's or agency's file number and, if any, the outcome of the department's or agency's assessment and risk management actions in relation to the substance imposed by the department or agency." Finally, the notice requires submission of "all other information or test data in respect of the substance that are in the possession of the person proposing the significant new activity, or to which they have access, and that are relevant to determining whether the substance is toxic or capable of becoming toxic."