To assist in determining whether an incident meets the criteria set out in CCPSA for reporting, Health Canada recently published the following table as a guide to "reportable events" contemplated under CCPSA:
CCPSA imposes very onerous, and likely impractical in many instances, timing obligations for reporting incidents.
Contravention of the new CCPSA rules will fall into one of two categories--"violations" or "offences.
A company or person who breaches a provision of CCPSA, or certain types of orders made under it, may be found guilty of an "offence.
Since CCPSA will mark a brand new regime of consumer product regulation in Canada, these penalties are a first as well--there currently is no comparable set of obligations for suppliers of general consumer products in Canada.
CCPSA will affect all companies, both Canadian and non-Canadian, that manufacture or sell consumer products in the Canadian marketplace.
CCPSA will make Canada's consumer product safety regime more similar to that of Canada's major trading partners (primarily the U.
The potential breadth of Health Canada's new investigative and recall powers under CCPSA, the increased severity of the offence provisions under CCPSA, and the Canadian government's recent focus on product safety generally, will create a far greater risk for any company that does not have these systems in place if a safety incident occurs.
Beyond that, other unintended consequences of CCPSA are foreseeable.