Conditions for Import of CAS 2041102-83-2

Summary#

This notice from the Department of the Environment publishes two items. First, Ministerial Condition No. 20432 (under the Canadian Environmental Protection Act, 1999) allows one notifier to manufacture or import a specific chemical (CAS 2041102-83-2) but only under strict conditions for impurity limits, handling and disposal. Second, it reports on the National Air Pollution Surveillance Program Memorandum of Understanding: it was published earlier, had a 60‑day comment period, received no public comments, and some provinces asked for changes.

What it does#

• Ministerial Condition No. 20432:

  • Allows the notifier who supplied information on June 19, 2020 to make or import the named substance (CAS 2041102-83-2) — but only if the conditions are met.
  • Limits impurities in the substance to no more than 1.5% of one related chemical and 0.05% of another.
  • Prohibits releasing the substance or related waste to the environment.
  • Requires on‑site collection of waste and sets how it must be destroyed or disposed:
    • If the substance in waste is less than 1.3 kilograms per site per day, it may go to a wastewater system or follow other permitted disposal routes.
    • If it is ≥ 1.3 kilograms per site per day, it must be incinerated or sent to an engineered hazardous waste landfill (where incineration is not possible) in accordance with applicable laws.
  • Requires immediate action and notification to the Minister if any release occurs.
  • Requires the notifier to inform and get written confirmation from any party they transfer the substance or waste to, except transfers in consumer products, drugs/cosmetics, or natural health products.
  • Requires record-keeping on uses, quantities, transfers, and disposal, kept in Canada for at least five years.
  • The conditions came into force on November 5, 2020.

• National Air Pollution Surveillance Program Memorandum of Understanding:

  • Notes the MOU was published in the Canada Gazette on October 6, 2018 with a 60‑day public comment period.
  • States no public comments were received, but some provinces requested changes.
  • Says a report summarizing those provincial changes is available from Environment Canada (contact details provided in the notice).

Who's affected#

• Ministerial Condition No. 20432 mainly affects:

  • The named notifier (the company or person who filed the information on June 19, 2020).
  • Any business that plans to manufacture, import, handle, or dispose of this particular substance (CAS 2041102-83-2).
  • Waste disposal and incineration facilities that might accept this waste at the ≥ 1.3 kilograms per site per day threshold.
  • Downstream recipients of the substance (unless the transfer is in a consumer product, drug/cosmetic, or natural health product).

• The National Air Pollution Surveillance Program MOU affects:

  • Federal, provincial and territorial agencies involved in air monitoring and air quality data.
  • Researchers, public health bodies and others who use or rely on national air pollution data.
  • The notice does not list exactly which provinces asked for changes.

Why it matters#

• The ministerial conditions are a targeted risk-control step. They let a specific party work with the chemical while limiting impurities, preventing releases, and setting clear disposal rules. That protects local environments and clarifies responsibilities for companies and waste handlers.
• The waste thresholds and disposal rules (notably 1.3 kilograms per site per day) could change how small versus larger generators manage their waste and which disposal facilities they must use.
• The update on the National Air Pollution Surveillance Program MOU signals ongoing adjustments to how air monitoring is coordinated across jurisdictions. People who use air-quality data or run monitoring networks may want to read the summary report mentioned in the notice.