Nonylphenol and its Ethoxylates Contained in Products

Instructions Specific to Notice


Instructions for Completing the Schedules to the Canada Gazette Notice Requiring the Preparation and Implementation of Pollution Prevention Plans in Respect of Nonylphenol and its Ethoxylates Contained in Products

This insert provides additional information on how to complete the forms associated with the Canada Gazette Notice Requiring the Preparation and Implementation of Pollution Prevention Plans in Respect of Nonylphenol and its Ethoxylates Contained in Products, Notice Reference Code P2NPE. Information presented in this insert complements the information provided in the Generic Instructions for Completing the Schedules to Canada Gazette Notices Requiring the Preparation and Implementation of Pollution Prevention Plans, hereafter referred to as the Instructions.

This insert is intended to provide guidance only. It does not in any way supersede or modify the Canadian Environmental Protection Act, 1999 (CEPA 1999) or any Notice issued by the Minister of Environment under section 56 of CEPA 1999 requiring the preparation and implementation of a pollution prevention (P2) plan. In the event of an inconsistency between this document and CEPA 1999 or the P2 Notice issued by the Minister and published in the Canada Gazette, CEPA 1999 and the P2 Notice prevail.

Definitions

NP and NPEs – refers to Nonylphenol (NP) and all Nonylphenol Ethoxylates (NPE). This includes raw NP and NPEs (as a commodity chemical).

Table 1 lists CAS registry numbers for the NP and NPEs most commonly used in Canadian industry. This list is for guidance purposes only, is non-exhaustive and does not preclude NP and NPEs with CAS numbers not appearing on this list.

Table 1a: CAS Numbers for Most Commonly Used Nonylphenolsin Canadian Industry1
Substance NameCAS Number
1 Guidance of CAS registry numbers to be used in the calculation of the NP reduction objective (Subsection 4(1) of the Notice)
Nonylphenol104-40-5
n-Nonylphenol (mixed isomers)25154-52-3
Nonylphenol, industrial84852-15-3
Table 1b: CAS Numbers for Most Commonly Used Nonylphenol Ethoxylates in Canadian Industry2
Substance NameCAS Number
2 Guidance of CAS registry numbers to be used in the calculation of the NP and NPEs reduction objective (Subsection 4(1) of the Notice)
2-(p-Nonylphenoxy) ethanol104-35-8
2-(2-(p-Nonylphenoxy)ethoxy) ethanol20427-84-3
p-Nonylphenol polyethylene glycol ether26027-38-3
Nonylphenol hepta(oxyethylene)ethanol27177-05-5
Nonylphenol nona(oxyethylene)ethanol27177-08-8
Ethoxynonyl-benzene28679-13-2
Nonylphenoxy ethanol27986-36-3
Oxirane, methyl-, polymer with oxirane, mono(nonylphenyl) ether37251-69-7
2-(2-(2-(2-(p-Nonylphenoxy)ethoxy) ethoxy)ethoxy) ethanol7311-27-5
Nonylphenol polyethylene glycol ether9016-45-9
Ethanol, 2-[2-(nonylphenoxy)ethoxy]-27176-93-8
Nonylphenol ethoxylate37340-60-6
Poly(oxy-1,2-ethanediyl), alpha-(2-nonylphenyl)-omega-hydroxy-51938-25-1
Nonylphenol ethoxylate68412-53-3
Poly(oxy-1,2-ethanediyl), alpha(isononylphenyl) omega-hydroxy37205-87-1
Poly(oxy-1,2-ethanediyl), alpha(nonylphenyl) omega-hydroxy, branched68412-54-4
Poly(oxy-1,2-ethanediyl), alpha(4-nonylphenyl) omega-hydroxy, branched127087-87-01

Derivatives or salts of NP and NPEs – Substances derived from NP or NPEs which may have the potential, through their degradation, to produce NP or NPEs.

Table 2 lists CAS registry numbers for derivatives or salts of NP and NPEs most commonly used in Canadian industry. This list is for guidance purposes only, is non-exhaustive, and does not preclude NP and NPEs salts and derivatives with CAS numbers not appearing on this list.

Table 2a: CAS Numbers for Most Commonly Used Derivatives or Salts of Nonylphenol in Canadian Industry3, 4
Substance NameCAS Number

3 Due to the potential, through their degradation, to produce NP, these products are not recommended as alternatives to NP (Paragraph 4(3)(b) of the Proposed Notice).

4 These substances should not be included in the NP reduction calculation.

a Additive in plastics and polymer manufacturing – typically contains free NP as an impurity at 1 to 3%.

Phenol, dinonyl1323-65-5
Phenol, nonyl-, barium salt28987-17-9
Phenol, nonyl derivatives68081-86-7
Barium, carbonate nonylphenol complexes68515-89-9
Phenol, nonyl-,phosphitea26523-78-4
Phenol, nonyl derives., sulphides68515-93-5
Table 2b: CAS Numbers for Most Commonly Used Derivatives or Salts of Nonylphenol Ethoxylates in Canadian Industry5, 6
Substance NameCAS Number

5 Due to the potential, through their degradation, to NPEs, these products are not recommended as alternatives to NPEs (Paragraph 4(3)(b) of the Proposed Notice).

6 These substances should not be included in the NPE reduction calculation.

Poly(oxy-1,2-ethanediyl), alpha-(nonylphenyl)-omega-hydroxy-, phosphate51811-79-1
Ammonium salt of sulphated nonylphenol ethoxylate9051-57-4

Raw NP and NPEs – refers to nonylphenol and its ethoxylates as a commodity chemical, and not contained in any formulation or final product.

NP and NPEs in Formulations – refers to any mixture of substances that includes NP or NPEs.

NP and NPEs in Final Products – refers to any product, either in bulk or packaged, that contains NP or NPEs as an ingredient.

OP and OPEs – refers to Octylphenol and all Octylphenol Ethoxylates. This includes raw OP and OPEs (as a commodity chemical) and OP and OPEs contained in formulations and as part of final products.

Table 3 lists CAS registry numbers for the OP and OPEs most commonly used in Canadian industry. This list is for guidance purposes only, is non-exhaustive and does not preclude OP and OPEs with CAS numbers not appearing on this list.

Table 3a: CAS Numbers for Most Commonly Used OP CAS Registry Numbers in Canadian Industry7, 8
Substance NameCAS Number

7 Due to their similar toxicological properties to NP, these substances are not recommended as suitable alternatives to NP (Paragraph 4(6)(b) of the Notice).

8 These substances should not be included in the NP reduction calculation.

Phenol, 4-octyl1806-26-4
Phenol, octyl27193-28-8
Table 3b: CAS Numbers for Most Commonly Used OPEs CAS Registry Numbers in Canadian Industry9, 10
Substance NameCAS Number

9 Due to their similar toxicological properties to NPEs, these substances are not recommended as suitable alternatives to NPEs (Paragraph 4(6)(b) of the Notice).

10 These substances should not be included in the NPE reduction calculation.

Poly(oxy-1,2-ethanediyl), alpha-(octylphenyl)-omega-hydroxy-, branched68987-90-6
Polyethylene glycol octylphenol ether9002-93-1
Ethoxylated octylphenol9036-19-5

Soap and Cleaning Products – refers to all products (powder, liquid, tablet or other form) containing NP or NPEs as an ingredient that are used for industrial and institutional, household, or other cleaning. For example, this includes but is not limited to laundry detergents, dish detergents, dishwasher detergents, hard surface cleaners, disinfectants, polishes, general purpose cleaners, toilet bowl cleaners, deodorizers, air fresheners, rug and carpet cleaners, metal cleaners, vehicle cleaners, etc.

Textile Wet Processing Aids – refers to all processing aids containing NP or NPEs as an ingredient used in textile wet processing. Environment Canada considers wet processes to be those textile manufacturing or producing processes that discharge significant quantities of water. The pollution prevention planning requirements target the processing aids used for the following textile processes, considered to be wet processes: scouring, neutralizing, desizing, mercerizing, carbonizing, fulling, bleaching, dyeing, printing, finishing and any other wet process. Please see definitions in Table 4 of each wet process as defined in the supporting document to the Priority Substances List Assessment carried out on textile mill effluent.

Table 4: Summary of Textile Wet Processes Definitions
Wet ProcessDescription
ScouringAn alkaline treatment for removal of natural fats, waxes, proteins, dirt, oil and other impurities.
NeutralizingThe process of raising or lowering the pH of textiles to near neutral after acid or alkali treatments.
DesizingThe removal of stiffening materials (sizes) from applied yarns or fabrics.
MercerizingA process that chemically increases the tensile strength, luster, dye affinity, and abrasion resistance of a fabric.
CarbonizingA process of adding an acid solution and heat, to remove plant matter from wool.
FullingThe washing of a wool textile in a thick soap solution, to compact and soften the wool.
BleachingA chemical treatment to improve the whiteness of a textile.
DyeingThe addition of dyes or pigments in an aqueous solution to change the colour of the textile.
PrintingA localized dyeing process in which a dye or pigment is applied to the fabric in a design.
Finishing (wet)The addition of a variety of finishing agents in a solution to improve the appearance, texture, and performance of the fabric.

Pulp and Paper Processing Aids – refers to all the processing aids containing NP or NPEs as an ingredient used by the pulp and paper industry. For example, this includes but is not limited to de-resinating agent, wetting agent, feltwash, pitch dispersant, polymer used in coatings, equipment conditioner, flocculants, degreaser, biocide, drainage aids, etc.

Preparation Year – The Preparation Year is from January 1 to December 31, 2003 for all person(s) subject to the Notice on the date of publication. For all person(s) that became subject to the Notice after the date of publication, the Preparation Year is the first calendar year (January 1 to December 31) in which the criterai in section 2 of the Notice are met.

Base Year – The Base Year is from January 1 to December 31, 1998 for all person(s) subject to the Notice on the date of publication. Should there be no NP and NPE use data for the 1998 calendar year, the first year after 1998, but no later than 2003, for which there is data should be considered as the base year. For all person(s) that became subject to the Notice after the date of publication, the Base Year and the Preparation Year are the same. The information submitted for the Preparation Year will be considered the information as the Base Year.

Who is subject to the Notice?

You are subject to the Notice if you do one or both of the activities below and you meet the threshold described below.

Activities:

  1. owning or operating a facility that manufactures soap and cleaning products, or processing aids used in textile wet processing, or pulp and paper processing aids, excluding those products or processing aids for export to another country; or
  2. importing soap and cleaning products, or processing aids used in textile wet processing, or pulp and paper processing aids into Canada, excluding those products or processing aids for export to another country;

Threshold:

If you have purchased or otherwise acquired a total of 2000 kg or more of NP and NPEs during one calendar year between January 1, 2003 and December 31, 2012 for the above activities, you are subject to the Notice. Note that this amount includes raw NP and NPEs, NP and NPEs in formulations, and NP and NPEs in final products.

Note: Although the reporting requirements related to NP or NPEs used in the manufacturing of products, and those for NP or NPEs imported in products have been separated, it is important to remember that when calculating whether you meet the threshold of 2000 kg of NP and NPEs purchased, this includes both the NP and NPEs that you have imported (including raw NP and NPEs, NP and NPEs in formulations, and NP and NPEs in final products), and any NP and NPEs that you have purchased domestically.

In addition to "Section B: Substance Information" of the Instructions: 3.0 – Substance and Activity

The substances for which you are reporting are NP and NPEs (see definition at the beginning of this Instruction Insert). There are two activities for which this Notice is applicable – NP or NPEs used in the manufacturing of products, and NP or NPEs imported in products. If you only perform one of these activities, check the appropriate box and continue on with the rest of the sections. If you perform both activities, you must complete sections 3.0 through 7.0 of the Declarations and Interim Progress Reports separately for each activity.

Part 4 Baseline Information Note c) Reporting Period

There are two possible scenarios by which you can be subject to the Notice.

Scenario 1 – You are subject on the date of publication of the Notice:

This means that as of the date of publication of the Notice, you meet the criteria set out in the Notice and therefore you must prepare and implement a P2 Plan. That is, in the calendar year 2003 you have purchased or otherwise acquired 2000 kg or more of NP and NPEs for the activities specified in the Notice.

Preparation Year: Your Preparation Year is January 1 to December 31, 2003. Information for this year should be inserted wherever you are asked for information from the Preparation Year. If you have been granted a time extension by the Minister, you may be required to report for a different Preparation Year. If this is the case, indicate the new year.

Base Year: Your Base Year is 199811, or the first calendar year (January 1 to December 31) since 1998 where you purchased or otherwise acquired 2000 kg or more of NP and/or NPEs for the following activities:

  1. Manufacturing soap and cleaning products, processing aids used in textile wet processing, or pulp and paper processing aids.
  2. Importing soap and cleaning products, processing aids used in textile wet processing, or pulp and paper processing aids.

11 Should there be no NP and NPE use data for the 1998 calendar year, the first year after 1998, but no later than 2003, for which there is data should be considered as the base year.

If you are subject to the Notice on the date of publication, the following table lists the forms to be filed (mandatory and optional), the applicable reporting year(s) for each form, and the deadline for filing each of the forms.

Form Submittal Schedule
FormReporting YearDeadline for filing form
Declaration of Preparation (Schedule 1); mandatoryBase Year = 1998
Preparation Year = 2003
July 31, 2005
Interim Progress Report #1 (Schedule 4); mandatoryJanuary 1–December 31, 2006January 31, 2007
Interim Progress Report #2 (Schedule 4); mandatoryJanuary 1–December 31, 2007January 31, 2008
Interim Progress Report #3 (Schedule 4); mandatoryJanuary 1–December 31, 2009January 31, 2010
Declaration of Implementation (Schedule 5); mandatoryJanuary 1–December 31, 2010January 31, 2011
Request for Waiver of Factors to Consider (Schedule 2); optionaln/aprior to the end of the time period specified in the Notice for preparing a P2 plan
Time Extensions(Schedule 3); optionaln/a
  • for preparing or implementing a P2 plan, prior to the end of the time period specified in the Notice
  • for Interim Progress Reports, prior to the deadline specified in the Notice for filing the form

Scenario 2: You are subject after the date of publication of the Notice

This means that after the date of publication of the Notice, you fulfill the criteria set out in the Notice and therefore you must prepare and implement a P2 Plan. That is, in 2003, you did not purchase or otherwise acquire 2000 kg or more of NP and NPEs for the activities specified in the Notice; however in one or more subsequent calendar years (2004 to 2012 calendar years) you have exceeded this 2000 kg threshold.

Preparation Year: Your Preparation Year is January 1 to December 31 of the year that you meet the criteria outlined in section 2 of the Notice. For example, if you become subject to the Notice because of NP and NPEs purchased in 2005, your Preparation Year is 2005. Information for this year should be inserted wherever you are asked for information for the Preparation Year. If you have been granted a time extension by the Minister, you may be required to report for a different Preparation Year. If this is the case, indicate the new year.

Base Year: Your Base Year is the same as your Preparation Year. Therefore, the year to which your reduction efforts will be compared is the same as the Preparation Year and all references to the Base Year throughout the Declaration are referring to the year you have entered as your Preparation Year. You need not enter Base Year information in the Declaration as it is the same as the Preparation Year.

If you became subject to the Notice after the date of publication, the following table lists the forms to be filed (mandatory and optional), the applicable reporting year(s) for each form, and the deadline for filing each of the forms.

Form Submittal Schedule
FormReporting YearDeadline for filing form
12 A person becomes subject to the Notice on January 1st of the year following the year that the criteria in section 2 are met.
Declaration of Preparation(Schedule 1); mandatoryBase Year = Preparation Year, therefore no reporting of base year data is required Preparation Year = calendar year you met the criteria in section 2 of the Notice7 months after becoming subject to the Notice12
Interim Progress Report #1 (Schedule 4); mandatory1st year after your Preparation Year13 months after becoming subject to the Notice
Interim Progress Report #2 (Schedule 4); mandatory2nd year after your Preparation Year25 months after becoming subject to the Notice
Declaration of Implementation (Schedule 5); mandatory3rd year after your Preparation Year37 months after becoming subject to the Notice
Request for Waiver of Factors to Consider (Schedule 2); optionaln/aprior to the end of the time period specified in the Notice for preparing a P2 plan
Time Extensions (Schedule 3); optionaln/a
  • for preparing or implementing a P2 plan, prior to the end of the time period specified in the Notice
  • for Interim Progress Reports, prior to the deadline specified in the Notice for filing the form

Reporting requirements are further clarified using the following example. For example, if you exceeded the 2000 kg threshold specified in paragraph 2(1)(b) of the Notice during the 2005 calendar year, you would become subject to the Notice on Janaury 1, 2006 and the following reporting requirements would apply:

Form Submittal Schedule
FormReporting YearDeadline for filing form
Declaration of Preparation (Schedule 1); mandatoryPreparation Year = 20057 months after becoming subject to the Notice = July 31, 2006
Interim Progress Report #1 (Schedule 4)January 1–December 31, 200613 months after becoming subject to the Notice = January 31, 2007
Interim Progress Report #2 (Schedule 4)January 1–December 31, 200725 months after becoming subject to the Notice = January 31, 2008
Declaration of Implementation (Schedule 5)January 1–December 31, 200837 months after becoming subject to the Notice = January 31, 2009

4.2 On-site Uses

This information is provided to assist in completing Part 4.2 in the Declaration of Preparation, the Interim Progress Reports and the Declaration of Implementation.

This part should be completed only for NP or NPEs used in the manufacturing of products. Indicate whether you manufactured products containing NP or NPEs during the Preparation Year (see above for definition) or during the Base Year (see above for definition). If yes for either year, enter, in kilograms, the amounts of NP and NPEs that you used in manufacturing of products for each year and specify how you estimated the values. In the last column of the table, indicate the "on-site activity" by explaining how NP and NPEs were used by your facility in the reporting year(s) (for example, an on-site activity could be "formulating soap and cleaning products").

Note that if you have imported raw NP or NPEs or NP or NPEs in formulations, and are using this to manufacture other final products, this amount of NP and NPEs should be included in this part.

4.5 Additional Information

4.5.1 NP and NPEs Imported in Products

This information is provided to assist in completing Part 4.5.1 in Declaration of Preparation, the Interim Progress Reports and the Declaration of Implementation.

This part should be completed only for NP or NPEs imported in products. Indicate whether you imported products containing NP or NPEs during the Preparation Year (see above for definition) or during the Base Year (see above for definition). If yes for either year, in kilograms, enter the amounts of NP and NPEs that you imported for each year and specify how you estimated the values.

4.5.2 All Manufactured or Imported Products Containing NP and/or NPEs

This information is provided to assist in completing Part 4.5.2 in the Declaration of Preparation, the Interim Progress Reports and the Declaration of Implementation.

This part should be completed for both importing and manufacturing of products containing NP or NPEs. Indicate whether you imported or manufactured products containing NP or NPEs in the Preparation Year (for the Declaration of Preparation), or in the Reporting Year (for the Interim Progress Reports and the Declaration of Implementation). Then, in the first column of the table, list each product (containing NPorNPEs) that you imported or manufactured.

Indicate in the second column whether each product was manufactured or imported.

Indicate in the third column the concentration of NP and NPEs in each product.

5.1 Anticipated Actions / Actions Taken to Date / Actions Taken

This information is provided to assist in completing Part 5.1 in the Declaration of Preparation, the Interim Progress Reports and the Declaration of Implementation.

Note that you must complete part 5.1 for each action that you anticipate doing or have taken. Also note that the actions entered in this section pertain only to the activity that you chose in Section 3.0. For example, if you are currently reporting information for NP or NPEs used in the manufacturing of products, the actions listed in this section will be specifically for the manufacturing of products containing NP or NPEs.

In the Declaration of Preparation, you are asked for the "change to annual use" anticipated to be achieved from each action. For example, if one anticipated action is that you intend to reformulate some of your products to use an alternative, the "anticipated change" is the total reduction of NP and NPEs in kilograms, due to that reformulation. In the Interim Progress Reports and the Declaration of Implementation, this value will be the total actual reduction of NP and NPEs in kilograms that occurred due to this particular action (i.e. the reformulation).

5.15 Baseline Element(s) Affected

In this section, you are asked to relate the anticipated change (reported in part 5.1.4) to a baseline element. If you are currently reporting information NP or NPEs used in the manufacturing of products (because you chose that option in Part 3.0), then the baseline element is "on-site uses", but you are asked to use the "appropriate alphabetical label" for the baseline element and for "on-site uses", that label is "A". Therefore, enter "A" in this field. If you are currently reporting information for NP or NPEs imported in products , then the baseline element is total imports. As there is no alphabetical label for this element, leave the field blank. For further explanation of the alphabetical labels, see part 5.1.5 in the Instructions.

5.2 Total Anticipated Results / Total Results Achieved To Date / Total Results Achieved

This information is provided to assist in completing Part 5.2 in the Declaration of Preparation, the Interim Progress Reports and the Declaration of Implementation.

Complete this section only for manufacturing of products containing NP or NPEs. Report the total results anticipated or achieved from all actions that pertain specifically to the manufacturing of products containing NP or NPEs. In the first column of the table, "Type of Use" is already filled in as "On-Site Uses". This term refers to using NP or NPEs in the manufacturing of products at your facility. Other types of uses have been removed because they are not applicable to products containing NP or NPEs.

5.3 Detailed Information on Results Anticipated / Achieved To Date / Achieved

This information is provided to assist in completing Part 5.3 in the Declaration of Preparation, the Interim Progress Reports and the Declaration of Implementation.

Complete this section only for NP or NPEs imported in products. Summarize, in kilograms, the total changes to the amount of NP and NPEs that you import as compared to the amount you imported during the Preparation Year and the Base Year. These total anticipated results or results achieved should summarize all actions pertaining to NP or NPEs imported in products.

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