Background

The Chemical Weapons Convention (CWC), which Canada has signed and enforces through the Canadian National Authority (CNA), prescribes chemical substances that are prohibited, and substances that need an import permit (GIP-108) in order import any amount into Canada.

On occasion, research groups may find themselves accidentally in violation of the importation provisions. This can result in affected Principal Investigators needing to retroactively apply for an import permit, which is an unnecessary administrative burden in particular for the PI as well as for other groups, such as Purchasing and the Department of Environmental Health and Safety (EHS).

When accidental importation occurs, it is usually because an expensive, often multi-chiral, specialty compound is ordered from an American supplier, and since the shipping cost of just a gram or two of this chemical would be unwarranted, a few other, more mundane chemicals are ordered. Unfortunately, some of these very common chemicals are covered by the CWC, and in a few cases, these chemicals have not been recognized by the US supplier as being special and have not been stopped at the border by Canadian border controls. These oversights lead to the PI and the University being unwittingly in violation of the CWC regulations. If the oversight were caught at the border, there would be a delay in the order delivery of at least weeks while the paperwork is completed and processed.

PIs and students would be accustomed to ordering these chemicals from Canadian suppliers, where the supplier has already done the paperwork around either importation to or manufacturing in Canada. As a result, adding these chemicals to an order would not seem unusual, particularly the “precursor” chemicals on Schedule 3 (see below).

The regulation recognizes the possibility of honest errors in importation and thus allows for retroactive application for import permits; however, the paperwork and process can be cumbersome.

Recommendation

In order to avoid the significant inconvenience of having to retroactively apply for an export permit, please familiarize anyone ordering or potentially ordering from a US or other foreign company with the attached list of common chemicals that are on the CWC.

If you have any questions or need any further information, please contact geoff.shirtliff.hinds@utoronto.ca.

Schedule 2

Schedule 3