Chemical Weapons, Designated Substances, Controlled Goods, Nanotechnology
McMaster University is required to complete the Annual Declaration of Past Activities in conformity with Section 11 of the Chemical Weapons Convention Implementation Act (CWCIA, hereafter “the Act”). Under the Act, the Canadian National Authority (CNA) is responsible for the collection and monitoring of data concerning the annual production, processing, consumption, import and export of chemicals covered by the Chemical Weapons Convention (CWC) in Canada and prepares annual national declarations to the Organization for the Prohibition of Chemical Weapons (OPCW).
To meet Canada’s international obligations, Canadian companies and institutions are required by the Act to submit up to two declarations a year to the CNA: an Annual Declaration of Past Activities (ADPA) and an Annual Declaration of Anticipated Activities (ADAA). The Annual Declaration of the Past Activities is due by February 28 for the previous calendar year.
The specific information required for the declaration depends on the CWC Schedule to which a chemical belongs. The toxic chemicals and their precursors are classified into three Schedules based on their risk for chemical weapons production.
Importing and Exporting of Scheduled Chemicals
Any chemicals listed within Schedule 1 requires an individual Import Permit for importation. This permit is also required for U.S. imports. For exportation, chemicals within Schedule 1 requires an individual Export Permit. Schedule 2 and 3 require an individual Export Permit for most countries, however, for export to United States, general Export Permit could be used. Any mixtures of Schedules 1, 2, or 3 could also require permits depending on the concentration.
Permit applications for Schedule 1 chemicals must be submitted at least 45 days prior to anticipated shipment date. Please plan your research around these requirements.
Please review the Chemical Weapons Convention Annual Declaration and the Annex for additional details regarding the Annual Declaration. Please contact Suba Sathiyavanthan, sathis16@mcmaster.ca, if you have any questions or refer to the Department of Foreign Affairs website.
The Controlled Goods Program (CPG) is a Federal Government Program designed to strengthen Canada’s defense trade controls. Legislated by the Defense Production Act (DPA) and the Controlled Goods Regulation (CGR), the mission of the program is to prevent the proliferation of weapons of mass destruction and conventional weapons by regulating and controlling the examination, possession and transfer in Canada of controlled goods and/or technology. Specifically, these items fall under Group 2, Hem 5504 and Group 6 of the Export Control List.
Individuals undertaking research in which you possess, transfer or examine controlled goods and/or controlled technology must conform to the Federal Controlled Goods Regulations (CGR) by registering with the Controlled Goods Directorate (CGD). Registration will be through the Designated Official (DO) of the University in Environmental and Occupational Health Support Services (EOHSS), and includes a security assessment that takes into account the following over the five years prior to the person’s consent to such an assessment: personal references, criminal history, place of residence, employment and educational history.
Controlled Goods Designated Official:
Alicia Westfall, ext 24967 Gilmour Hall, Rm 304
Alternate Contact: Cheryl Beecroft, ext 27593 Gilmour Hall, Rm 304
Definitions:
Examine: Means to consider in detail or subject to an analysis in order to discover essential features or meaning.
Possess: Either actual possession, where a person has direct physical control over a controlled good at any given time, or constructive possession, where the person has the power and the intention at a given time to exercise control over a controlled good, either directly or through another person or persons.
Transfer: means in respect of a controlled good and/or controlled technology to dispose of it or disclose its content in any manner.
Designated Substances
The Ministry of Labour (MOL) has designated a Regulations for 12 designated substances due to their toxicity and/or carcinogenic properties. The Occupational Health and Safety Act (OHSA) defines a Designated Substance as:
a biological, chemical or physical agent or combination thereof prescribed as a designated substance to which the exposure of a worker is prohibited, regulated, restricted, limited or controlled.
The following materials have been rated as Designated Substances and are covered under Regulation 490/09:
The Act ensures that workers exposure is controlled, toxic substances in the workplace are clearly identified and the worker’s receive sufficient information to handle toxic substances safely. The Regulations apply to all individuals and contractors who process, use, handle or store Designated Substances in McMaster University owned facilities, areas in host institutions occupied by McMaster University staff and students or in the field.
Once a Designated Substance is present in the workplace in order for the University to comply with the Act, McMaster University is required to maintain an inventory of all Designated Substances.
If you are using chemicals classified as Designated Substances, please complete an assessment form located in RMM 500 Designated Substances Control Program. The Designated Substances assessment must be reviewed by your local Joint Health and Safety Committee (JHSC). In addition, a copy of the assessment must be reserved in the area containing the Designated Substance, and a copy of the assessment must be sent to University Health and Safety (UHS).
Please note, if modifications are made to the process, use, handling and/or storage of Designated Substances, the assessment must be updated and reviewed with the local JHSC.
Please send all assessments to UHS as we maintain an inventory of all Designated Substances used at McMaster University. Please submit your copies to UHS in Gilmour Hall Room 304 or electronically to uhs@mcmaster.ca.
Over the last several years the amount of research in the area of nanotechnology has been increasing as a result of market demand. As with most new technology, the earliest and greatest exposure to hazards is most likely to occur in the workplace. Workers in the nanotechnology industry have the potential to be exposed to engineered materials with novel sizes, shapes, and physical and chemical properties. The following resources are available regarding best safety practices for working with nanomaterials.
IRSST – Best Practices Guide to Synthetic Nanoparticle Risk Assessment
http://www.irsst.qc.ca/media/documents/PubIRSST/R-599.pdf
NIOSH – Approaches to Safe Nanotechnology – Managing the Health and Safety Concerns Associated with Engineered Nanomaterials
http://www.cdc.gov/niosh/docs/2009-125/pdfs/2009-125.pdf
NIOSH – General Safe Practices for Working with Engineered Nanomaterials in Research Laboratories
http://www.cdc.gov/niosh/docs/2012-147/pdfs/2012-147.pdf