Canada Gazette, Part I, Volume 157, Number 24: Tents Regulations
June 17, 2023
Canada Consumer Product Safety Act
Department of Health
REGULATORY IMPACT ANALYSIS STATEMENT
(This statement is not part of the Regulations.)
Issues: The Tents Regulations help protect people of Canada from injuries and deaths caused by tent fires in Canada by specifying fire-safety labelling and flammability performance requirements for tents. The Tents Regulations incorporate by reference specific sections of an industry standard that addresses the flammability issues associated with tent materials commonly used at the time the regulation was enacted, namely, paraffin-coated cotton canvas. The performance requirements in this industry standard are now less suited to address the flammability hazards of the types of tent materials sold in the market today. The current requirements may inhibit using tent materials that would likely be deemed safe from a risk perspective, and tent manufacturers may apply flame retardant chemicals to tent materials in order to comply with the requirements.
Description: Health Canada is proposing to replace the current flammability and fire-safety labelling requirements in the Tents Regulations with contemporary requirements developed by the Canadian General Standards Board in their standard entitled CAN/CGSB-182.1-2020 Flammability and Labelling Requirements for Tents (the CGSB standard). Health Canada is also proposing to add flammability performance and fire-safety labelling requirements to the Toys Regulations in order to continue regulating children’s play tents not intended to be used as outdoor shelters because Health Canada proposes to exclude them from the Tents Regulations. Finally, Health Canada is proposing amendments to the Textile Flammability Regulations to exclude from those regulations products that are regulated under the Toys Regulations.
Rationale: The proposal seeks to improve on the requirements in the Tents Regulations and Toys Regulations by continuing to provide health and safety protections to people of Canada from flammability hazards posed by tents and children’s play tent products, while reducing regulatory burden for industry and benefitting people of Canada by helping to reduce exposure to flame retardant chemicals. Costs to manufacturers are expected to be low, as previous equipment utilized for testing tents can continue to be used for the proposed requirements. Some tent manufacturers have reported they are already testing their products to the CGSB standard. Flexible transition periods are proposed to reduce the impact to businesses while at the same time protecting the health and safety of people of Canada.
This regulatory proposal helps address a number of issues related to the requirements for tents in the Tents Regulations under the Canada Consumer Product Safety Act (CCPSA). The issues include an outdated reference and methodology used to assess flammability performance in modern tent materials, leading to potential reliance on flame retardant chemicals to meet compliance. Children’s play tents, including those that are used indoors, are also subject to the Tents Regulations and must meet the same flammability performance requirements as a tent, which again may result in flame retardant chemical use. Exposure to certain flame retardants may result in potential human health effects.
Outdated performance criteria
The Tents Regulations set out requirements for fire-safety labelling and flammability performance requirements for all pliable materials that constitute the floor, walls and top of the tent. The Tents Regulations incorporate by reference specific sections of the standard CPAI-84 (1995), A Specification for Flame-Resistant Materials Used in Camping Tentage, published by the Industrial Fabrics Association International, formerly the Canvas Products Association International. The CPAI-84 was originally published in 1972 and tents were typically made of paraffin-coated (waxed) cotton canvas at the time. Certain flammability criteria, such as flaming debris and after-flame time were incorporated from CPAI-84 and have since not been updated. The performance requirements in CPAI-84 are less suited to address the flammability risks for the types of tent materials sold in the market today, which are mostly synthetic, lightweight, and have different burning properties (e.g. melting and dripping). As such, the current Tents Regulations may inhibit industry from developing and using tent materials that would likely be deemed safe from a risk perspective but cannot meet the current regulatory requirements.
Additionally, the current Tents Regulations reference a static version of CPAI-84, which has been replaced by the ASTM F3431-21, entitled Standard Specification for Determining Flammability of Materials for Recreational Camping Tents and Warning Labels for Associated Hazards, published by ASTM International.
Flame retardant chemicals
Flame retardants are composed of various types of chemicals, and these chemicals have received greater attention recently due to their use in household products and health and environmental concerns. Tent manufacturers may commonly apply flame retardant chemicals on tent materials in order to comply with the flammability performance requirements in the Tents Regulations as the performance criteria in CPAI-84 may not be suited for materials used in tents today. Human exposure to some flame retardant chemicals has been associated with adverse health effects. Studies by Duke Universityfootnote 1,footnote 2 found that handling a tent treated with a flame retardant chemical resulted in dermal exposure, and inhalation exposure to the flame retardant chemical is likely to occur while a person is inside a tent that has materials treated with flame retardant chemicals. A number of stakeholders have expressed concerns to Health Canada about the use of flame retardant chemicals on tents for the purpose of meeting the existing flammability performance requirements of the Tents Regulations. Since children’s play tents are also required to meet the flammability performance requirements in the Tents Regulations, it is anticipated these products are also treated with flame retardant chemicals.footnote 3
Children’s play tents
Play tents are subject to the Tents Regulations since they are included in the definition of a tent. However, the classification of play tents in the context of the Tents Regulations is not a clear process, and similar products such as play tunnels may not be in scope despite posing similar hazards. Conversely, the primary use of certain play tents may be indoors — a characteristic not shared with other items listed in the definition of a tent (e.g. camping tents, dining shelters and ice-fishing tents) since they are primarily intended for outdoor use.
The scope of the CGSB standard does not include children’s play tents unless they resemble a camping tent or other shelter and are intended for use outdoors. The proposal to amend the Tents Regulations to align with the requirements of the CGSB standard would result in certain children’s play tents that do not provide outdoor shelter no longer being in scope of the Tents Regulations. The flammability performance requirements in CPAI-84 are not appropriate for these excluded children’s play tents; however, the minimum flammability performance requirements for textile products in the Textile Flammability Regulations may not be sufficiently protective of children nor do they specify any fire-safety information. As such, a regulatory gap would be created for the flammability performance of certain children’s play tents.
The Hazardous Products (Tents) Regulations were enacted under the Hazardous Products Act on January 21, 1988, to help protect people of Canada from injuries and deaths caused by tent fires. Tents made of textile material can burn when exposed to an open flame or other ignition sources. Occupants are confined in a relatively small space with limited exit points, so in the event of a fire, occupants may have difficulty exiting the tent, creating the potential for smoke inhalation, burn injuries or death. In addition, the flammability hazard associated with tents may not be readily apparent to some people, and there is a potential for product misuse given that they are often used close to open flame or other ignition sources. Between 1972 and 1987, the Government of Canada received reports of 164 camping tent fires that resulted in 32 deaths and 40 injuries, more than half of which involved children. At that time, tents were typically made of paraffin-coated (waxed) cotton canvas, and some could burn completely in under a minute.
In 2011, the Hazardous Products (Tents) Regulations were transferred from the Hazardous Products Act to the Canada Consumer Product Safety Act (CCPSA) when Part I and Schedule I to the Hazardous Products Act were repealed and replaced with the CCPSA. In 2016, the Hazardous Products (Tents) Regulations were repealed and replaced with the Tents Regulations. At that time, non-substantive changes were made to the regulations, including changing the scope of application of the regulations to be consistent with the authorities set out in the CCPSA.
A tent is defined in the Tents Regulations as “a portable shelter made of fabric or other pliable material, such as a camping tent, an ice-fishing tent or a dining shelter, and includes a play tent, but excludes a tent subject to the National Building Code of Canada, 2010, issued by the Canadian Commission on Building and Fire Codes, National Research Council of Canada, a canopy, an awning, a tarpaulin, a tent trailer and an air-supported structure.” Children’s play tents that are subject to the requirements under the Tents Regulations are also subject to other regulations under the CCPSA, such as the Toys Regulations. The Tents Regulations specify fire-safety labelling and flammability performance requirements for tents and incorporate by reference specific sections of the 1995 edition of the CPAI-84 standard.
The Textile Flammability Regulations under the CCPSA apply to consumer products within the scope of that Act that are textile products or bedding, but exclude certain products if there are flammability performance requirements set out in other regulations under the CCPSA. For example, tents, as defined under the Tents Regulations, are excluded from the scope of the Textile Flammability Regulations.
Health Canada’s consumer product compliance verification projects target products suspected of non-compliance and as such, project results do not reflect overall market compliance rates. Nevertheless, the compliance rates over multiple project years have been low. To help regulated parties understand the requirements of the Tents Regulations, Health Canada published an industry guide on the departmental website in 2009, prior to the 2010/2011 compliance verification project, and a webinar was presented to industry and testing laboratories in early 2013, prior to the 2013/2014 compliance verification project. Despite the education and information provided to regulated parties and other stakeholders, the compliance rate did not improve. There are multiple reasons for the compliance failures observed in the 2013/2014 project, most notably, that certain tent components failed flammability performance requirements, such as having after-flame times longer than permitted by the Tents Regulations. Non-compliant products were subject to various enforcement actions such as voluntary recalls, stop sales, stop distributions and trader commitments.
In 2013, Health Canada completed an internal process to proactively review the regulations under the CCPSA and the Cosmetic Regulations under the Food and Drugs Act. The review process considers the current regulatory environment and assesses regulatory options for identified issues. The review also aligns with the Government of Canada’s regulatory reform initiatives to address health and safety considerations while reducing unnecessary regulatory burden on industry and improving alignment of requirements with major trading partners. The review of the Tents Regulations recommended substantive changes that included improving the test methodology.
In order to move forward with the recommendation, in 2013, the Department asked the Canadian General Standards Board to put together a technical committee for the development of a new National Standard of Canada for tent flammability and fire-safety labelling. The Board is accredited by the Standards Council of Canada as a standards-development organization. Standards developed by the Board are based upon Canadian context and harmonization with national or international standards. The development of standards follows a consensus process involving a broad range of stakeholders. The CGSB standard, which would be incorporated by the proposed amendments, was developed through the cooperation of representatives from the following categories:
- producer (six businesses and one industry association);
- regulatory (Health Canada);
- user (Health Canada Product Safety Laboratory, five testing laboratories, one consultant for consumer interests and one consumers’ association);
- academia (university); and
- general interest category (two consultants).
The CGSB standard was finalized and made publicly available on the Government of Canada Publications website in April 2020 and entitled CAN/CGSB-182.1-2020, Flammability and Labelling Requirements for Tents.
An anticipated additional benefit of the development of the CGSB standard was that the new standard would help eliminate or greatly reduce the use of flame retardant chemicals on tents. The development of the CGSB standard was supported by testing conducted by Health Canada on a variety of tent materials, including flame retardant treated and untreated fabrics, supplied by industry representatives in the standard’s technical committee. While testing was limited to the samples provided, the test data indicated that most untreated fabrics were able to pass the performance criteria. In Health Canada’s opinion, most tent products could meet the flammability performance provisions of the CGSB standard without reliance on the use of flame retardant chemicals.
Although a tent that meets the flammability performance requirements helps to mitigate the flammability hazards, tents are not fireproof and can catch on fire from contact with an open flame or other ignition source, such as a camp fire (and sparks or embers from the fire), barbeque, fuel-powered lantern, firepot, stove, heater, candle or cigarette. Data on fire incidents was collected from a variety of databases and sources, including the Department’s internal databases on incidents, the Canadian Hospitals Injury Reporting and Prevention Program (CHIRPP), and various provincial and territorial Office of the Fire Marshal or Office of the Fire Commissioner. Narratives from CHIRPP incidents indicate that tents caught on fire with serious burn injuries reported in several cases. For example, one incident reported the consumer went to sleep and the camp stove caught on fire. The provincial and territorial data from the Office of the Fire Marshal or Office of the Fire Commissioner suggests that fire events can occur in Canada within these product categories. The information from the various databases highlight that tent fires can occur, and may lead to injuries or death. A further breakdown on fire-related events can be found in the benefits section “Regulatory analysis.”
The primary policy objective of this regulatory proposal is to help maintain health or safety protections for consumers from the hazards posed by tent fires while improving upon the test methodology used to assess tent flammability performance requirements. The proposed amendments will also help to reduce the use of flame retardant chemicals in tent materials.
In addition, the proposal will help to maintain health and safety protection for young children from flammability hazards posed by children’s play tents through appropriate fire-safety labelling and flammability performance requirements in the Toys Regulations.
Replace the existing fire-safety labelling and flammability performance requirements
Health Canada is proposing amendments to replace the existing fire-safety labelling and flammability performance requirements in the Tents Regulations with the requirements set out in the CGSB standard using an ambulatory incorporation by reference. The requirements of the CGSB standard are better suited to address the flammability hazards of the types of materials used in tents today. Compared to the current Tents Regulations, the CGSB standard utilizes a more balanced approach to assess the flammability performance of tents by updating the existing flammability requirements to allow mass loss as a performance criteria, modify conditions for flaming debris, and eliminate certain flammability criteria that are no longer pertinent. It is anticipated that this update may help eliminate or greatly reduce the use of flame retardant chemicals in tent products. Additionally, the equipment utilized for testing of tents can continue to be used to assess compliance with the CGSB standard, which may reduce cost impacts. Similar to the procedures set out in the current Tents Regulations, the CGSB standard requires specimens be prepared and tested under three test conditions (as received, after leaching and after weathering). Lastly, the proposed scope of the Tents Regulations maintains oversight of products such as dining shelters that share similar hazards to those as tents.
Children’s tents that provide shelter outdoors, such as youth camping tents, youth sun shelters and play tents that resemble a camping tent, would continue to be subject to the fire-safety labelling and flammability performance requirements in the Tents Regulations. However, the proposed changes to the Tents Regulations would align the regulations with the CGSB standard by excluding children’s play tents where they do not provide outdoor shelter.
Include children’s play tents in the Toys Regulations
Since Health Canada is proposing to exclude children’s play tents not intended for outdoor shelter from the amended Tents Regulations, the Department proposes to amend the Toys Regulations to maintain appropriate regulatory oversight of flammability hazards and fire-safety labelling for play tents intended for use by children under 14 years of age.
The proposed amendments to the Toys Regulations would add fire-safety labelling and flammability performance requirements for play tents and define them as a “toy intended to be entered by a child.” This term aligns with the definition of play tents set out in the International Standards Organization’s ISO 8124-2:2014, Safety of toys — Part 2: Flammability (the ISO toy standard). The proposed definition would encompass toys such as play tunnels, teepees and bed tents that share similar characteristics to a play tent and provide partial to full enclosure. Similar to the proposed changes for tents, it is anticipated that play tents would also have a reduced need for flame retardant chemicals in order to comply with the updated performance requirements.
The proposed amendments to the Toys Regulations would require that a toy intended to be entered by a child must meet the flammability performance requirements in the ISO toy standard. Health Canada is proposing an ambulatory incorporation by reference of the ISO toy standard so that this requirement in the Toys Regulations remains up to date when changes are made to the standard. The department is also proposing fire-safety labelling requirements in order to alert caregivers to keep toys intended to be entered by a child away from sources of heat or open flames.
Note that toys intended to be entered by a child that provide shelter outdoors and meets the proposed definition of a tent, would be subject to the fire-safety labelling and flammability performance requirements in the Tents Regulations instead of the proposed requirements in the Toys Regulations.
Consequential amendments are required to the Textile Flammability Regulations to exclude products within the scope of the Toys Regulations.
Coming into force
The amended regulations would come into force on the date on which they are published in Canada Gazette, Part II. A transitional period of 365 days following the date on which the proposed regulations come into force would be provided to allow industry to deplete existing stock that complies with the existing Tents Regulations and Toys Regulations.
Transitional compliance period
After the amended regulations have come into force, they would authorize a transitional compliance period whenever the CGSB standard or the ISO toy standard is updated. This transitional compliance period would allow
- 180 days for manufacturers and importers to meet either the final amended standard or the standard as it was written the day before it was amended; and
- 365 days for advertisers and sellers to meet either the final amended standard or the standard as it was written on the day before it was amended.
Health Canada has conducted the following consultation activities to obtain early feedback from consumers and impacted stakeholders on the policy elements of the proposal. Health Canada took into account the combined findings as it developed and refined the regulatory proposal in preparation for prepublication in the Canada Gazette, Part I.
A notice regarding this proposal was published on the Government of Canada website in January 2019 and stakeholders were also invited to participate in the CGSB’s public consultation on the draft CGSB standard. Comments on the proposal were received from seven stakeholders, including three industry members, two industry associations, one supplier of tent materials to Indigenous communities and one testing laboratory. The stakeholders were generally supportive of the proposal to replace the current fire-safety labelling and flammability performance requirements in the Tents Regulations with those in the CGSB standard. One tent retailer and one tent association group expressed support to use the CGSB standard instead of relying upon current requirements in the Tents Regulations, but preferred a voluntary approach. Respondents were also supportive of the proposal to amend the Toys Regulations to continue to regulate the requirements for fire-safety labelling and flammability performance of play tents for indoor use only and of play tents that do not provide outdoor shelter.
On April 22, 2020, the Department informed stakeholders by email that the CGSB standard was published and available online, and the Department was working on the proposal to replace the existing requirements in the Tents Regulations with the requirements from the CGSB standard. The Department has received multiple enquiries on the progression and status of the regulatory proposal since 2020. Information about this regulatory proposal has been listed on the Department’s Forward Regulatory Plan since 2021–2023.
Cost-benefit analysis survey
Health Canada hired a third-party contractor, Cheminfo Services Inc. of Markham, Ontario, to conduct additional consultations with key stakeholders to support the required cost-benefit analysis. Cheminfo Services undertook the consultation from approximately July 2021 to December 2021 to contact various levels of trade, including association groups, affected by the proposal. Although considerable attempts were made to contact stakeholders, a limited number provided responses to the questionnaires. In total, 15 responses to the questionnaires were received (5 tent manufacturers, 1 play tent manufacturer, 5 tent importers or retailers, and 4 play tent importers and retailers). Written responses were also received from two companies. Key association groups such as the Outdoor Industry Association (OIA), Canadian Toy Association (CTA) and Canadian Textile Industry Association (CTIA) were also contacted. These associations were encouraged to share the questionnaires related to the proposal with their members. Despite two attempts by the CTA and CTIA, no responses to the questionnaires were received from their members. The CTA provided a written response on their position about the proposal, reiterating their response from the 2019 consultation — that they are supportive of the requirements to be aligned with the ISO toy standard. The OIA shared the questionnaire with its Flame Retardants Cohort and one member (a tent manufacturer) responded to the questionnaire. Cheminfo Services also noted the OIA’s Flame Retardants Cohort conducted research on the safety and other effects of regulatory standards, but no information or data were shared with the contractor. One testing laboratory, involved on the technical committee for the development of the CGSB tent standard, was also contacted. No information was received from the testing laboratory.
Modern treaty obligations and Indigenous engagement and consultation
In accordance with the Cabinet Directive on the Federal Approach to Modern Treaty Implementation, an initial assessment was conducted on this regulatory proposal. The assessment concluded that implementation of this proposal would be unlikely to impact on the rights, interests or self-government provisions of treaty partners. All people of Canada, including Indigenous Peoples, would benefit from the public health and product safety approach taken in these proposed regulations.
The Department considered the following three options:
- Status quo
- Under this option, Health Canada would continue to rely upon the current Tents Regulations for fire-safety labelling and flammability performance requirements in Canada. As the Tents Regulations reference the CPAI-84 standard, certain performance requirements might not be reflective of the flammability risks of the type of tent materials used today, posing a regulatory burden to industry. Additional industry guidance on the regulatory requirements could improve industry knowledge; however, the performance criteria in CPAI-84 could continue to result in poor compliance. Regulated parties would likely continue to use flame-retardant chemicals to help comply with the flammability performance requirements of the Tents Regulations.
- For these reasons, the status quo is not the preferred option.
- Rescind the Tents Regulations and utilize CCPSA and/or voluntary instruments
- Under the second option, the Department would seek to rescind the Tents Regulations and rely either upon other authorities under the CCPSA or voluntary instruments. Without the Tents Regulations applying to tents, they would be subject to the flammability requirements in the Textile Flammability Regulations under the CCPSA. The flammability performance requirements in the Textile Flammability Regulations are not sufficiently protective for tent products because tent materials are identified as a higher risk due to their use near open flames or ignition sources; also, the Textile Flammability Regulations do not prescribe specific fire-safety warnings. Tents made from cotton canvas, while less common than those made of synthetic materials in the current marketplace, would not have appropriate flammability oversight.
- An alternative would be to rely on voluntary industry standards in conjunction with the general prohibitions under the CCPSA. Under this option, there would be an expectation of voluntary compliance with the requirements of an appropriate consensus standard that helps mitigate the hazards from tent fires. Health Canada would encourage the CGSB standard for voluntary compliance; however, it is not clear what level of voluntary uptake could be expected, and gaps in protection would exist where compliance with the standard was lacking. In the United States, the voluntary standard ASTM F3431-21 is applicable to tents intended for use with camping appliances (e.g. wood stoves), and references the CGSB standard for flammability performance. However, the ASTM standard does not specify flammability performance requirements for tents not intended for use with camping appliances. As such, the ASTM standard only covers a limited subset of tent products in the marketplace: even full adherence to the ASTM standard would result in less protection for the people of Canada as not all tent products are included in its scope. Another industry standard which could be considered is ISO 5912:2011, Camping tents - Requirements and test methods. However, Health Canada found the ISO test method to be time-consuming, with variable results and failures recorded for lower-risk fabrics. Additionally, the ISO standard would require industry to invest in the procurement of expensive laboratory equipment. Given the upfront cost of the ISO standard, it might be less readily accepted or considered.
- For children’s play tents, the removal of the Tents Regulations would leave them subject to the Textile Flammability Regulations. The flammability requirements for textile products in the Textile Flammability Regulations might not be sufficiently protective of children and could lead to a gap in protections. Fire-safety labelling to alert caregivers would also be absent as a requirement for these products. Uptake for voluntary compliance with a consensus standard is also unclear.
- It should also be noted that compliance expectations which rely on voluntary standards could be difficult to enforce since these requirements are not regulatory requirements.
- For these reasons, using a voluntary approach is not the preferred option.
- Amend Regulations
- The third and selected option would repeal the existing flammability and labelling requirements in the Tents Regulations and incorporate newer, consensus-based requirements set out in the CGSB standard. The proposed amendments would help maintain the level of protection for the people of Canada from incidents caused by fires in tent products while updating the regulatory requirements to be reflective of the types of materials used in tents today. The requirements in the CGSB standard would reduce regulatory burden for industry and help eliminate or greatly reduce reliance on flame retardant chemicals. The use of ambulatory incorporation by reference would allow the regulations to keep pace with technological changes and other relevant factors which are taken into account in the updating of the standard, for which there is a periodic, consensus-driven process. Amendments to the Toys Regulations to add appropriate fire-safety labelling and flammability performance requirements from the ISO toy standard for a toy intended to be entered by a child would continue to protect young children from fire injuries and deaths.
Benefits and costs
The cost-benefit analysis (CBA) aims to estimate the proposed costs and benefits of making amendments to the Tents Regulations and Toys Regulations in a quantitative and qualitative manner. In 2021, Health Canada retained Cheminfo Services Inc. of Markham, Ontario, to analyze the costs and benefits associated with this regulatory proposal. The CBA report is available upon request from the contact listed at the end of this Regulatory impact analysis statement.
The cost-benefit analysis measures all impact of the proposed regulations as being relative to a baseline scenario. This allows for proper attribution of changes that are directly due to the proposed regulations, focusing on relevant impacts while ignoring other non-related factors.
In the baseline scenario, the current regulatory environment under the Tents Regulations and Toys Regulations would continue to be in place. Tent flammability performance would continue to be tested to the CPAI-84 methodology and manufacturers and importers might rely on flame retardant chemicals for compliance. Children’s play tents would continue to be covered under the Tents Regulations, creating a situation where some toys intended to be entered by children would have different flammability performance and labelling requirements than others. The number of events (incidents, injuries, fatalities, and property damage) would continue to occur at rates similar to historic levels.
In the regulatory scenario, new ambulatory references using the CGSB standard for the fire-safety and flammability requirements would be incorporated into the Tents Regulations, and toys intended to be entered by a child would be covered under the Toys Regulations with new fire-safety labelling and flammability performance requirements set to the ISO toy standard. Manufacturers and importers would face upfront and ongoing costs related to changes in testing and labelling requirements and savings from reduced reliance on flame retardant chemicals and improved test methodology to assess flammability performance. The risk of incidents related to fires from tents and children’s play tents would be maintained at or lower than levels in baseline scenario and lower potential risks related to exposure to flame retardant chemicals.
The one-time or annual ongoing costs are composed of several activities for tent manufacturers such as meeting the proposed flammability requirements, fire-safety labelling requirements, and unsold tent inventories when the proposal comes into effect. For retailers, these costs are in relation to management of inventory that meets the flammability and fire-safety labelling requirements and stranded inventory when the regulations come into effect. Similar costs are applicable to play tent manufacturers.
During 2021, Cheminfo Services contacted businesses and associations that would be impacted by this regulatory proposal and asked them to complete questionnaires focused on identifying cost impacts. The information about the responses and costs are summarized as follows:
- Input on costs were received from five tent manufacturers. One company with a high volume of annual sales stated there were no one-time or annual costs relating to the proposed changes since they already meet the CGSB standard. Two companies with moderate volume sales responded, with one company providing no cost data while the other responded that there were no costs since they meet the CGSB standard. Two companies with small volume sales identified one-time costs and annual costs relating to the proposed changes.
- Three tent manufacturers noted the use of flame retardant chemicals is expected to fall.
- Tent importers and retailers did not identify one-time or annual incremental costs, but noted the seasonal nature of products and complexities with supply chains due to the COVID-19 pandemic would require 12 months or more to sell existing inventory.
- Tent importers and retailers were supportive of the proposal to replace the CPAI-84 reference with the CGSB standard in the Tents Regulations.
- The Outdoor Industry Association (OIA) did not provide any comment or data, but forwarded the questionnaires to its members.
The CBA estimates that approximately 1 million tent products are sold annually in the Canadian marketplace. The surveyed manufacturers sell approximately 500 000 tent products in Canada, reflective of half the market. Market data for other products that fall within the scope of the Tents Regulations, such as dining shelters and gazebos, were limited.
- Only one toy manufacturer responded to the questionnaire and identified no additional one-time or ongoing costs relating to the proposed changes. The manufacturer stated a preference to use the ISO toy standard or its equivalent.
- Four retailers who sell a large portion of children’s play tents to the Canadian marketplace responded to the questionnaire. None of the companies reported a cost relating to the proposed changes and identified a period of 12 to 24 months to deplete existing inventory.
- The Canadian Toy Association (CTA) assisted in forwarding the questionnaires to its members; however, no responses were received. The CTA indicated support toward applying the flammability and labelling requirements of ISO 8124-2 and EN 71-2.
The CBA extrapolated responses from the survey to the industry by weighting costs per tent and then multiplying by the number of tents impacted. The one-time costs were sales weighted as $0.03 cents and around $0.04 cents for annual ongoing costs. This data forms the basis of the low-cost scenario. A high-cost scenario, excluding the sales of the high-volume company (who reported no costs), was also developed, and its combination with the low-cost scenario forms the basis of the central cost scenario.
The CBA found one-time costs of $0.2 million and ongoing annual costs of $0.25 million for tents under the central cost scenario. The total present value 10-year cost is estimated at $2.8 million discounted at 7%. For children’s play tents, the CBA estimated the total present value 10-year cost as $281,000.
The CBA assumed no incremental costs to the Government of Canada as a result of this proposal. The costs to administer, promote and enforce the proposed amended Regulations would become part of Health Canada’s existing compliance and enforcement program for consumer products.
The CBA uses information provided from affected stakeholders. Five tent manufacturers responded to the questionnaire, which may represent a small sample of all affected companies. Given that two tent manufacturers with high and medium volume sales indicated they are currently meeting the CGSB standard and have not attributed costs to the proposal, this may skew the cost analysis from companies that have yet to adopt the CGSB standard. As such, higher costs relating to the proposal may be possible if the sample is not representative of all manufacturers. Using the high-cost scenario (excluding the high-volume tent manufacturer), the costs to tent manufacturers are around $690,000 to $819,000 annually with a total present value 10-year cost of approximately $7.5 million. For toy manufacturers, information was received from only one company and used in the model and may not be representative of other companies. Using the high-cost scenario, the cost to toy manufacturers is around $69,000 to $82,000 annually, with a total present value 10-year cost of approximately $754,000.
The benefits portion of the CBA study considered data from a variety of sources. Information was collected from internal databases along with requesting information from external sources such as the CHIRPP. Health Canada also contacted the respective Office of the Fire Marshal or the Office of the Fire Commissioner in each of the provinces and territories in order to obtain information on fire-related events involving tents and play tents. This regulatory proposal is not expected to generate new health benefits, but would continue to help maintain the protection of the people of Canada from tent fires and play tent fires, while greatly eliminating or reducing the reliance on flame retardant chemicals. The reduction of flame retardant chemical use may have economic benefits in terms of cost savings for some Canadian tent suppliers, and also benefit the health of end users.
From 1987 to June 2011, Health Canada received 68 reports related to tents. This included 2 deaths that were related to flammability as well as 10 injuries. There was 1 report related to a primary hazard of flammability. This was a burn/scald to an adult in August 1992. From June 20, 2011, to December 31, 2020, Health Canada received 29 reports related to tents (15 from the industry, 13 from consumers, 1 from the media). Of the 29 reports, 1 involved death, 7 involved injuries, and the rest were related to product defects, recalls, complaints and inquiries. The report involving death originated from a media article reported in 2015, and involved 4 fatalities. Data obtained from the CHIRPP from April 2011 to May 2018 found 132 injuries involving tents. Eight of the injuries were the result of a tent catching on fire. One additional record related to tent fires was found between May 2018 and February 2021. Many of the records indicate the tent caught on fire and caused burn injuries to the individual. No data was available on the type of tent involved or time period (year), other than a brief description of the incident. No reports were found in the United States’ Consumer Product Safety Commission’s database related to tent or children’s play tent flammability between April 2011 to December 2020. However, records were found in the United States’ National Electronic Injury Surveillance System (US NEISS) and United States Clearinghouse Data. From January 2010 to December 2019, 58 reports were received in the US NEISS data with 53 burn injuries and 3 reports related to flammability in the Clearinghouse Data, though one report may not be the direct result of a tent fire.
Recent data was retrieved from the databases after the completion of the CBA study. From January 2021 to December 31, 2022, Health Canada received 10 reports related to tents (6 from the industry, 4 from consumers). CHIRPP data from February 2021 to January 2023 found 14 records related to tent flammability issues, most narratives indicate the individual sustained burn injuries from a tent fire. No reports were found in the United States’ Consumer Product Safety Commission’s database between January 2021 to December 2022. Recent US NEISS data found 20 reports involving fires and tents between January 2020 to December 2021, involving 19 burn injuries. Finally, United States Clearinghouse data from January 2020 to December 2021 found 12 reports related to flammability issues in tents with several resulting in death.
Fire data from provinces and territories
Health Canada requested fire incident data related to tents and children’s play tents from the provincial and territorial fire authorities (i.e. Office of the Fire Marshal or Office of the Fire Commissioner). Alberta, Ontario and Nunavut provided data associated with fires and injuries involving these product categories. Other provinces and territories noted they do not collect the level of detail needed to discern between the product categories requested. For Alberta, from 2011 to April 2020, the province reported 12 events related to the property class of tents, and another 4 events related to children’s play houses (which may include children’s play tents). Fire-related injuries were reported in 2 of the events involving tents. The information received from Alberta indicates that approximately 1.2 tent fires and 0.2 injuries occurred on average over a 10-year period. This represents a 0.05 injury rate per million population per year. For children’s play houses, the average occurrence is around a 0.4 per year with no injuries reported over the same period.
For Ontario, from 2000 to 2020, there were 6 incidents reported under the property type of tents (including one fatality in 2000). There were also 4 incidents reported under the property type of gazebos and 95 reported under sheds or children’s playhouse. Serious injuries were reported in 5 events involving tents and gazebos, and 8 events involving sheds and children’s playhouses. The information received from Ontario indicates that approximately 0.5 tent and gazebo fires occurred per year and 0.24 serious injuries occurred on average over a 21-year period. For sheds and children’s play houses, the average occurrence is around 4.5 per year with 0.38 serious injuries reported over the same period. The information for Ontario indicates 0.033 serious injuries per million population per year from tent and gazebo fires, and 0.003 fatalities rate per million population per year. It is important to note certain limitations with the provincial data: there may be varying types of products in each category; there may be no distinction between consumer products and products used for commercial purpose; and the affected product may not be composed of fabric-based materials (e.g. a wooden gazebo vs. fabric covers on a gazebo). Nevertheless, the provincial data suggests fire events do occur in Canada within these product categories.
The territory of Nunavut reported 2 events associated with tent flammability. One event involved 4 fatalities within the same family in 2015 (identical to the media report mentioned above). The camping stove is suspected as the cause of the fire. The other event in 2020 resulted in injuries to one person.
The cost benefit study found an injury rate of about 0.023 injuries per million population per year based on the Alberta and Ontario data, which suggests about 0.862 injuries per year across Canada. For fatalities, based on combined data from Alberta and Ontario, the study predicted 0.003 per million population per year, with a fatality rate of 0.094 fatalities per year across Canada. Tent fires in Canada are estimated at 3.3 occurrences per year based on the Alberta and Ontario data.
Summary of CBA
The main purpose of the proposal is to continue to protect the people of Canada from the flammability hazards associated with tents while updating the flammability performance requirements to be reflective of the type of tent materials used today. While the contracted CBA report found a net benefit of $6.5 million using the central cost scenario, the benefits are driven by a hypothetical reduction in the risk of fatalities primarily associated with children’s play tents. The study did not find evidence to reliably identify the extent that the proposed CGSB standard would reduce the number of fires, injuries, and fatalities. As the proposal amends the performance requirements in the current Tents Regulations, it is difficult to characterize any benefits or attribute any reductions in tent fire fatalities and injuries relative to the existing requirements. Additional benefits, such as a reduction in flame retardant exposure to users, could not be monetized. Costs to Canadian consumers are expected to be minimal. The CBA reported an estimated average price increase per tent over ten years to be about $0.50 under the central cost scenario.
- Number of years: 10 (2023-2032)
- Base year for costing: 2023
- Present value base year: 2022
- Discount rate: 7%
|Impacted stakeholder||Description of cost||Base year||Other relevant years||Final year|| Total
|Government||No Costs Anticipated||$0||$0||$0||$0||$0|
|Industry||Flammability Testing and Label Changes||$659,849||$3,559,307||$482,125||$3,328,645||$473,924|
|All stakeholders||Total costs||$659,849||$3,559,307||$482,125||$3,328,645||$473,924|
Some of the costs faced by industry are expected to be passed on to the people of Canada. However, as the initial costs will be paid by industry, they have been assigned to them as a stakeholder. Some of these costs may be offset from reduced reliance on flame retardant savings.
As there was uncertainty in the assumptions to calculate the effectiveness of the reductions in fire hazards, while noting a positive outcome would be maintained based upon historical levels, Health Canada has opted to not display the monetized benefits, and instead is providing only the monetized costs.
Quantified (non-$) and qualitative impacts
- Maintain protection from fire-related events for tents and play tents, including toys intended to be entered by a child.
- Potential for less flame retardant chemicals applied to tents sold in Canada, and fewer associated adverse health impacts for people of Canada who use tents. This could also be a benefit to manufacturers in lowering their production costs.
- Costs for testing equipment is minimized as previous equipment for testing CPAI-84 can be utilized for testing to the CGSB standard. Industry burden may be reduced as fewer products may fail testing to the current requirements.
- Potential for less flame retardant chemicals applied to children’s play tents sold in Canada, and fewer associated adverse health impacts for Canadian children who use children’s play tents.
- It is possible some inventories of tents or children’s play tents may remain unsold, depending on the timing and communications with industry.
- Businesses could choose to terminate the supply of some tents or children’s play tents to minimize impacts (products withdrawn or discontinued).
- Some costs may be passed on to final consumers in the form of marginally higher prices.
Small business lens
Analysis under the small business lens concluded that the proposed amendments would not impact small businesses.
It is expected that tents which comply with the current flammability performance requirements under the Tents Regulations would continue to comply with the CGSB standard. Similarly, play tents meeting the flammability performance requirements currently would also continue to comply with the ISO toy standard.
Cheminfo Services reported responses from two small businesses, one domestic and one foreign. The small Canadian business did not identify any specific impacts in their response to the questionnaire. The small foreign business (a tent manufacturer) noted different standards would increase its costs and that it lacked the resources to make multiple versions of their products for specific markets. The manufacturer also reported one-time costs and annual costs. It is important to note that the proposed requirements from the CGSB standard are more reflective of the types of materials currently used in tents, which would help reduce the regulatory burden to industry. Cheminfo Services also reported the company represents less than half of one percent of the Canadian market in 2020. Since the estimated tent market is around 1 million units, this would imply around 5 000 tents are sold in Canada by this particular small business. The small business also reported they expect the use of flame retardant chemicals to be reduced, implying a benefit to consumers even though there are costs associated with the proposal.
In order to minimize impacts to all businesses (including small businesses) and achieve the policy objectives, the proposed amendments would come into force on the date of publication in Canada Gazette, Part II. However, a transitional provision would allow products compliant with the current Tents Regulations and Toys Regulations to continue to be manufactured, imported, advertised, or sold in Canada for 365 days beginning on the day the proposed amendments come into force. This additional time of one year would allow small businesses sufficient time to bring new products into compliance while depleting existing inventory. Additionally, the proposed amendments would also include a period of time to comply when new versions of the standards (i.e. the CGSB standard or the ISO toy standard), incorporated by reference, are published. The manufacturer or importer would be allowed 180 days to manufacture or import products that meet either the new or the previous version of the standard. Additionally, advertisers and retailers would be allowed 365 days to advertise or sell products that meet either the new or the previous version of the standard.
The regulatory proposal would not result in any administrative burden on businesses; therefore, the one-for-one rule does not apply.
Regulatory cooperation and alignment
The proposal is not related to a commitment under a formal regulatory cooperation forum.
The proposal considered available alignment options with international jurisdictions.
International – tents
Based on the information from the CBA report, it is reported that tents made in Canada may represent a small percentage of the total tents in the market, while imported tents account for the majority of total tents sold in Canada. Importation, based upon country of origin and not brand, is predominantly from Asian countries such as China and Bangladesh, while the United States represents about 11% of the imported tents. Data on exports or re-exports indicate they would compose a small proportion of the overall trade in tents.
In the United States, the ASTM International purchased the rights to CPAI-84 and revised the CPAI-84 specifications under a new tent standard, resulting in ASTM F3431-20. The standard underwent minor revisions in 2021, resulting in the current version: ASTM F3431-21, which is a voluntary standard in the United States. The CPAI-84 specifications are mandatory in certain States.
It is important to highlight that ASTM F3431-21 references the CGSB standard for the flammability performance of tents, and both standards therefore assess products using identical requirements for flammability performance. However, the scope of the ASTM F3431-21 is limited to tents that are intended for use with camping appliances. Therefore, the voluntary ASTM standard does not apply to the majority of tent products available in the marketplace.
Harmonization and alignment with ASTM F3431-21 would result in a decreased protection to the people of Canada from the hazards posed by tent fires. The amendments proposed in the Tents Regulations continue to apply to tent products for use with or without camping appliances since flammability hazards exist with tents whether or not they are intended for use with camping appliances. Tent products can catch on fire from contact with an open flame or other ignition sources and the risks of smoke inhalation, burn injuries or death remain the same irrespective of whether the source originates from inside or outside the tent. While this may impact certain U.S. manufacturers wishing to access Canadian markets, the protection provided to the people of Canada is greater in scope than ASTM F3431-21 and remains aligned with what is subject to the current Tents Regulations. There may exist minor differences in the fire-safety labelling requirements of the ASTM and the CGSB standard; however, the CGSB standard allows for statements that convey the same meaning to be used.
Exportation of tent products would not be affected as the Canadian requirements meet or exceed the standards for tents in North America.
International – children’s play tents
Adoption of the ISO toy standard for toys intended to be entered by a child increases harmonization and alignment with an international safety standard. The European Union’s Toy Safety Directive specifies compliance of toy products to several standards including EN 71-2:2020, Safety of toys - Part 2: Flammability. The flammability performance requirement for toys intended to be entered by a child in the ISO toy standard are equivalent to those in EN 71-2:2020.
This proposal would result in decreased regulatory burden for manufacturers and producers of toys intended to be entered by a child, and reduced reliance on flame retardant chemicals to meet the proposed requirements. The approach to adopt the ISO toy standard by ambulatory incorporation by reference would result in the requirements remaining current to any changes with the international standard.
Strategic environmental assessment
In accordance with the Government of Canada’s Cabinet Directive on the Environmental Assessment of Policy, Plan and Program Proposals, a preliminary scan was conducted and concluded that a strategic environmental assessment is not required.
While a reduction in the use of flame retardant chemicals is likely to have a positive impact on the environment, this impact is expected to be minimal.
Gender-based analysis plus
The regulatory proposal would be expected to generate benefits for all people of Canada primarily by continuing to protect them from flammability hazards posed by tent and children’s play tent products. Information from Statistics Canada indicates that both male and female persons participate in tent camping activities across Canada, with greater participation by persons in the adolescent to young-adult age groups. The proposal is not expected to have unintended negative impacts.
Tent products are intended to be portable and temporary shelters for activities such as leisure, sleep or rest, but are not intended to serve as a permanent shelter or home. Persons experiencing homelessness may utilize tent products in a manner that is not the intended purpose. Nevertheless, the proposal would continue to provide protection by specifying flammability performance requirements for tent materials and specific directions on safe use through fire-safety labelling on the product.
Implementation, compliance and enforcement, and service standards
The regulatory proposal would be made under the authority of the CCPSA and would come into force on the day on which it is published in Canada Gazette, Part II. These proposed regulations would include a transitional period that allows a product compliant to the current requirements to continue to be manufactured, imported, advertised, or sold in Canada for 365 days beginning on the day the proposed regulations come into force. During this transition period, regulated parties would be able to comply with either the current regulations or the amended regulations.
The regulatory proposal would include a period; after a new version of a standard incorporated by reference is published; that would allow 180 days to manufacture or import and 365 days to advertise or sell products that meet either the new or the previous version of the standard.
Health Canada would develop information materials to help industry stakeholders understand and comply with the amended requirements. The test methods used by Health Canada’s Product Safety Laboratory would be made available upon request to the Government of Canada.
Compliance and enforcement
Compliance and enforcement activities would follow established Health Canada approaches and procedures, including sampling and testing of products, inspections at business locations, follow-up on incidents reported by the Canadian public and follow-up on mandatory incident reports by industry. Non-compliant products would be subject to the enforcement actions available to Health Canada inspectors under the CCPSA, and could include voluntary commitment to product correction by industry, negotiation with industry for the voluntary removal of non-compliant products from the market, seizure, orders for recall or other measures, administrative monetary penalties or prosecution.
Health Canada would also seek to maximize compliance with the proposed amendments through ongoing industry and retailer education, and maximize tent safety through consumer outreach and education.
Consumer and Hazardous Products Safety Directorate
Healthy Environments and Consumer Safety Branch
269 Laurier Avenue West
Address Locator: 4908B
PROPOSED REGULATORY TEXT
Interested persons may make representations concerning the proposed Regulations within 70 days after the date of publication of this notice. They are strongly encouraged to use the online commenting feature that is available on the Canada Gazette website but if they use email, mail or any other means, the representations should cite the Canada Gazette, Part I, and the date of publication of this notice, and be sent to Prathipan Ratnam, Senior Regulatory Policy and Risk Management Advisor, Consumer and Hazardous Products Safety Directorate, Healthy Environments and Consumer Safety Branch, Department of Health, address locator: 4908B, 269 Laurier Avenue West, Ottawa, Ontario, K1A 0K9. (email: CCPSA-LCSPC@hc-sc.gc.ca).
Ottawa, June 8, 2023
Assistant Clerk of the Privy Council
1 (1) The following definitions apply in these Regulations.
- components and accessories
- means items that are intended to be used with a tent, such as side panels, curtains, footprints, flies and gear lofts, whether they are sold with the tent or separately, but does not include the following:
- (a) packaging such as a bag for tents, poles or stakes;
- (b) threads, zippers, ropes, hook and loop fasteners and webbing;
- (c) labels and logos with a surface area of less than 1 000 cmfootnote 2, calculated in a manner set out in Annex A of the safety standard; and
- (d) fabric or other pliable material with a surface area less than 1 000 cmfootnote 2. (composants et accessoires)
- safety standard
- means the Canadian General Standards Board standard CAN/CGSB-182.1-2020, entitled Flammability and labelling requirements for tents, published in April 2020, as amended from time to time. (norme de sécurité)
- means a structure that meets the following conditions:
- (a) it is portable;
- (b) it is intended to shelter persons from outdoor environmental elements such as precipitation, sun, wind or insects;
- (c) it is made of, in whole or in part, fabric or other pliable material;
- (d) it has a top;
- (e) it has at least one side that constrains egress; and
- (f) it is not subject to the National Building Code of Canada, 2020, published by the Canadian Commission on Building and Fire Codes, National Research Council of Canada. (tente)
Reference in the safety standard
(2) For the purposes of these Regulations, a reference to “tent” in the safety standard has the same meaning as in subsection (1).
Performance and testing requirement
2 (1) When tested in accordance with the safety standard, fabric and other pliable material of a tent or of its components and accessories must meet the requirements set out in section 5.2.1 of the safety standard.
(2) When tested in accordance with the safety standard, flooring materials of a tent, within the meaning of section 4.3 of the safety standard, that do not meet the requirements set out in section 5.2.1 of the safety standard must meet the requirements set out in section 22.214.171.124 of the safety standard.
3 (1) A tent must meet the labelling requirements set out in section 6 of the safety standard.
(2) For the purposes of this section, a reference to “children’s tent” in the safety standard means a tent that is intended to be used by a child under 14 years of age and that is not intended to be used with a device to cook or heat.
(3) For the purposes of this section, a reference to “appliance” in the safety standard means a device to cook or heat.
4 Despite sections 2 and 3, a tent that meets a requirement set out in those sections, as it read immediately before the day on which a new version of the safety standard is published, may continue to meet that requirement during the following period:
- (a) in the case of the manufacture or import of the tent, for the period of 180 days that begins on the day on which the new version of the safety standard is published; and
- (b) in the case of the advertising or sale of the tent, for the period of 365 days that begins on the day on which the new version of the safety standard is published.
5 (1) The definitions plush toy and soft toy in section 1 of the Toys Regulations footnote 4 are replaced by the following:
- plush toy
- means a toy with a raised fibre surface, but does not include a toy intended to be entered by a child. (jouet en peluche)
- soft toy
- includes a toy that is stuffed or made of pliable rubber or pliable plastic, but does not include a toy intended to be entered by a child. (jouet mou)
(2) Section 1 of the Regulations is amended by adding the following in alphabetical order:
- toy intended to be entered by a child
- means a toy that is constructed, in whole or in part, from fabric or other pliable material and that is intended to fully or almost fully enclose a child. (jouet conçu pour qu’un enfant puisse y entrer)
6 The headings before section 45 and sections 45 to 47 are replaced by the following::
Toys Intended to be Entered by a Child
45 Sections 46 and 47 do not apply to a tent as defined in subsection 1(1) of the Tents Regulations.
Requirement and testing
46 (1) A toy intended to be entered by a child must be tested in accordance with clauses 5.1 and 5.4 of the International Organization for Standardization of ISO 8124-2, entitled Safety of toys — Part 2: Flammability, published in August 2014, as amended from time to time, and meet the requirements set out in clause 4.4 of standard ISO 8124-2, excluding the requirement that the toy and the packaging be permanently marked with a statement if the spread of the flame of the test sample is between 10 mm/s and 30 mm/s.
(2) Despite subsection (1), a toy intended to be entered by a child that meets a requirement set out in that subsection, as the requirement read immediately before the day on which a new version of standard ISO 8124-2 is published, may continue to meet that requirement during the following period:
- (a) in the case of the manufacture or import of the toy intended to be entered by a child, for the period of 180 days that begins on the day on which the new version of the standard; and
- (b) in the case of the advertising or sale of the toy intended to be entered by a child, for the period of 365 days that begins on the day on which the new version of the standard is published.
47 (1) The outer surface of a toy intended to be entered by a child must have a permanent label containing the following warning or a different warning of equivalent meaning, in bold uppercase characters at least 3 mm in height and in both official languages: “WARNING: KEEP AWAY FROM HEAT AND OPEN FLAME / MISE EN GARDE : TENIR LOIN DES SOURCES DE CHALEUR ET DES FLAMMES NUES”.
(2) The permament label must contain the following alert symbol, at least 6 mm in height, immediately before the warning:
(3) The warning and the symbol must be affixed to the toy intended to be entered by a child in such a manner that they are legible and clearly visible throughout the life of the toy.
Textile Flammability Regulations
7 Paragraph 2(b) of the Textile Flammability Regulations footnote 5 is replaced by the following:
- (b) dolls, plush toys, soft toys and toys intended to be entered by a child;
Consumer products deemed to meet applicable requirements
8 A consumer product referred to in the Tents Regulations or the Toys Regulations, as those Regulations read immediately before the day on which these Regulations come into force, that, immediately before that day, met the applicable requirements for that consumer product is deemed, beginning on the day on which this section comes into force, to meet the applicable requirements for that consumer product under these Regulations for a period of 365 days.
9 The Tents Regulations footnote 6 are repealed.
Coming into Force
10 These Regulations come into force on the day on which they are published in the Canada Gazette, Part II.
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