Lead corrosion guidance and precursor-control proposal

Summary#

Two notices from Health Canada appear in this Gazette entry. One publishes final guidance called Guidance on sampling and mitigation measures for controlling lead corrosion to help authorities reduce lead at the tap. The other is a Notice of intent under the Controlled Drugs and Substances Act proposing tighter rules on precursor chemicals and drug equipment, with a public consultation open until March 3, 2025.

What it does#

• Final guidance on lead corrosion (under the Canadian Environmental Protection Act, 1999):

  • Gives practical sampling steps, triggers for action, and mitigation approaches for water distribution systems and plumbing.
  • Covers system-wide corrosion control and specific advice for multi-dwelling buildings, schools, daycares and office buildings.
  • Was publicly consulted for 60 days in 2023 and updated; the notice is dated January 31, 2025.

• Proposed amendments to precursor and device rules (under the Controlled Drugs and Substances Act and the Precursor Control Regulations (PCR) / Schedule IX):

  • Make reporting of suspicious transactions to Health Canada mandatory for licensed and registered companies.
  • Require licensed/registered dealers to do criminal record and background checks on key personnel who handle precursors.
  • Add condition-of-sale restrictions for products containing ephedrine and pseudoephedrine (moving in line with an interim order for some natural health products).
  • Extend import-registration controls to the component parts of “designated devices” such as pill presses and encapsulators.
  • Give Health Canada more flexibility to add or remove licence/registration conditions or to partially suspend activities when risks are identified.
  • The department says these changes are intended to help law and border enforcement respond faster to illegal manufacture and trafficking of synthetic drugs.

Who's affected#

• Water and building side:

  • Municipal water authorities, local regulators, plumbers, building owners, school boards and employers responsible for schools, daycares and multi-unit housing.
  • Residents, parents and building occupants who get water from the affected systems.

• Drug-control side:

  • Health Canada licence holders and registrants that manufacture, distribute or import precursor chemicals.
  • Pharmacies and distributors (because of proposed limits on ephedrine/pseudoephedrine sales).
  • Importers and suppliers of pill presses, encapsulators and their parts.
  • Law enforcement and border agencies (they would get expanded reporting and regulatory tools).

• If unclear: the proposed CDSA changes are still in consultation, so the final list of who must comply could change.

Why it matters#

• Lead guidance: following the new guidance could reduce people’s exposure to lead from plumbing and distribution systems. That matters for children, pregnant people and others sensitive to lead. The guidance gives towns and building managers clearer steps for testing and fixing problems.
• Precursor and device proposals: they aim to disrupt illegal synthetic-drug production (driven in part by fentanyl). The Gazette notice quotes the broader context that between January 2016 and June 2024 there were 49,105 apparent opioid toxicity deaths in Canada, with 79% of accidental apparent opioid deaths in early 2024 involving fentanyl. If adopted, the proposals could mean more paperwork and checks for legitimate chemical suppliers, new sale limits for some over-the-counter products, and stricter import rules for equipment — all intended to reduce diversion to illegal markets. The CDSA changes are proposals, not law yet, and comments are being accepted until March 3, 2025.