Summary of public comments received on the Chemicals Management Plan approach for a subset of inorganic and organometallic substances
Comments on the Chemicals Management Plan Approach for a Subset of Inorganic and Organometallic Substances were submitted by multiple private citizens, the Canadian Network for Human Health and the Environment (CNHHE) and the Saskatchewan Environmental Society.
Summarized public comments and responses are provided below, organized by topic.
Overarching
| Summarized/rolled-up comment | Summarized/rolled- up response |
|---|---|
| Suggested editorial changes to chemical names and formulas in the approach document. | The approach document provides the Domestic Substances List (DSL) names for these substances, which usually does not include a formula. DSL names may not reflect current naming practices. |
| It would be helpful to have the terms of the Canadian Environmental Protection Act, 1999 (CEPA) (such as, persistence and priority substances) defined in the introduction, reference to the documents identified as Priority Substances List (PSL1) assessment or a second Priority Substances List (PSL2) assessment, as well as substances already on Schedule 1 to CEPA. |
Definitions of the common terms used in the Canadian Environmental Protection Act, 1999 (CEPA) are available on the Chemical Substances website in the Chemicals Management Plan (CMP) Glossary. The documents requested are included in the reference section of this document and available from the Government of Canada website. A list of substances on Schedule 1 to CEPA is available online at the Government of Canada website. |
| Will these substances be monitored as a pro-active measure? What are the requirements and process for a re-assessment of substances? |
Some of the substances in this approach are captured in the list of substances on Schedule 1 to CEPA. Performance measurement evaluates the ongoing effectiveness and relevance of the actions taken to manage risks from toxic substances. Data from various programs that monitor these substances, such as the Monitoring and Surveillance Program in support of the Chemicals Management Plan, are used to evaluate the effectiveness of individual risk management actions, and to support performance measurement evaluations for substances which report on how well the government is meeting the overall human heath and environmental and human health objectives. The Identification of Risk Assessment Priorities (IRAP) approach considers new information to identify substances that may have the potential to cause harm to the environment or human health. For more information on this process please visit the IRAP website. |
| It is not clear when water quality guidelines are developed for specific substances. | All published Drinking Water Quality Guidelines are available from the Government of Canada Water Quality - Reports and Publications website. Development of a drinking water quality guideline for a contaminant is prioritized based on the potential risks of the contaminant and current governmental priorities. The criteria for prioritization is available at the Guidelines for Canadian Drinking Water Quality - Summary Table. |
| Further assessment of the exposure and risk to the general public from the substances included in Schedule 1 to CEPA is requested. | The moiety-based Priority Substance List (PSL) assessments and other recent Government of Canada assessments were deemed acceptable to address the risk of the substances in this document. |
| Why are organoarsenic compounds not included in the assessment (other than CAS RN 58-36-6, 10H-phenoxarsine, 10,10’-oxybis-)? | The risks associated with organoarsenic compounds identified as priorities during the categorization exercise have been or are being addressed through various approaches under the Chemicals Management Plan including the Rapid Screening Phase One and Rapid Screening Phase Two assessments. The organoarsenic compound in this document is the only organoarsenic compound remaining for assessment that was prioritized through categorization. |
Risk assessment
| Summarized/rolled-up comment | Summarized/rolled- up response |
|---|---|
| Some of the substances addressed in the approach document do not deal with the component of the substance that may be associated with greater toxicity than the components previously assessed. Namely, the perfluorinated alkyl components of certain chromium salts are not discussed. | Based on available data regarding the substances addressed in this document and related substances, the moiety-based PSL assessments were deemed acceptable to address the risk of the chemicals in this document. These perfluorinated alkyl substances were identified for further scoping/problem formulation in IRAP: results of the 2017-18 review. |
| The rationale for “no further assessment at this time” for ammonia, uranium, lead and mercury appears to be satisfactory since fairly recent reports have been published. | Noted. |
|
Given the lack of recent reports published on arsenic and cadmium, what assurances are there that recent data would not trigger new assessments? Further assessment of the exposure and risk to the general public from arsenic and cadmium substances addressed within this approach document is requested. |
Arsenic and cadmium have been identified in the results of the 2017-2018 IRAP review as substances for which further scoping is recommended. Recent information on these substances will be considered to determine if further data collection or generation is needed. |
| The cadmium-containing substances in the approach document are not listed on Schedule 1 to CEPA. There is a need to ensure that all hazards associated with cadmium, including all forms of cadmium, are addressed, considered in risk management and relayed to the public and industry. Absorption of cadmium in hexanoic acid, 2-ethyl-, cadmium salt (CAS RN 2420-98-6) may be greater than in the inorganic forms of cadmium in the assessment of “Cadmium and Its Compounds”. Information is requested on any activities being undertaken to monitor the exposure of the public to cadmium. |
Cadmium was identified in the 2017-2018 IRAP review as a substance for which further scoping is recommended. Different forms of cadmium, including organometallics and organic-metal salts, and their associated risks may be considered as part of the scoping. Since 1990, Canadian emissions of cadmium to the air have decreased by about 90% largely due to the implementation of instruments aimed at controlling industrial emissions. Exposure of the public to cadmium is monitored through programs including the Canadian Health Measures Survey, provincial drinking water programs and the National Pollutant Release Inventory. Cadmium concentrations in the environment are also monitored under the Monitoring and Surveillance Program in support of the Chemicals Management Plan. For more information please visit the monitoring and surveillance website. |
| Given the lack of recent reports published on chromium, further assessment of the risk to the general public from the chromium substances addressed within this approach document is requested. | The risk to the general public from chromium has recently been assessed in Health Canada’s Guideline for Canadian Drinking Water Quality: Guideline Technical Document – Chromium. Based on the use pattern of chromium, the human health considerations of that assessment will contribute to the regulation of chromium in Canada. Considering that assessment and the best available information, no further assessment under CEPA is warranted at this time. |
| Has Health Canada recently evaluated the exposure of Canadians to the 2 inorganic fluoride substances? If not, then Health Canada should evaluate this exposure, possibly as part of the monitoring of inorganic fluoride exposure for risk management. | Health Canada has evaluated the exposure of Canadians to fluoride in the Guideline for Canadian Drinking Water Quality: Guideline Technical Document - Fluoride. As outlined in the PSL assessment of inorganic fluorides, these fluoride substances are used primarily in drinking water treatment. Considering the recent drinking water guideline and the best available information, no further assessment of fluoride under CEPA is warranted at this time. |
| Given the lack of recent reports published on nickel, to better evaluate the exposure of the Canadian general public, testing of nickel levels in blood or urine in a random sample might be appropriate. | Nickel levels in blood and urine were measured as part of several biomonitoring programs and studies including: the Canadian Heath Measures Survey (CHMS), the First Nations Biomonitoring Initiative (FNBI) and Mother-Infant Research on Environmental Chemicals (MIREC) and follow-up studies. For more information on these initiatives please see the National biomonitoring initiatives website. |
| A further assessment of the risk to the health of the general public from ammonia-containing substances is requested. | A human health assessment of ammonia is available upon request as a supporting document to the PSL assessment Ammonia in the Aquatic Environment assessment. |
| A full assessment of the exposure and risk to the general public from the uranium substances addressed within this approach document should be conducted. | The risk to the general public from uranium has recently been assessed in Health Canada’s Guidelines for Canadian Drinking Water Quality: Guideline Technical Document - Uranium. Human health considerations of that assessment will contribute to the regulation of uranium levels in Canada. Based on the findings of that assessment and best available information, no further assessment under CEPA is warranted at this time. |
| Further assessment of the exposure and risk to the general public from the lead and mercury substances in this approach is requested. | Lead and Mercury and its compounds are on the list of substances on Schedule 1 to CEPA. This enables the Government of Canada to take preventative or control actions to minimize exposure from these substances to humans and the environment, without the need for new assessments. Recently, the Government of Canada published reports evaluating the effectiveness of the risk management actions taken to date for mercury and lead. |
Risk management
| Summarized/rolled-up comment | Summarized/rolled- up response |
|---|---|
| Suggestion to change the Schedule 1 listing for cadmium to “Cadmium and its compounds” and nickel to “Nickel and its compounds” based on current evidence. |
Inorganic cadmium compounds and Oxidic, sulphidic, and soluble inorganic nickel compounds are on the list of substances on Schedule 1 to CEPA. This reflects the concerns identified at the time of the assessment and continues to cover current concerns, allowing the Government of Canada to take preventive and control actions to minimize exposure from nickel to humans and the environment, without the need for new assessments. Additional risk assessment or risk management activities may be undertaken in the future if new information becomes available on these substances. As noted above, cadmium was identified in the 2017-2018 IRAP review for further scoping. New information on cadmium substances not available at the time of assessment can be included in this process. |
| The current risk management for lead needs updating, to reduce the exposure of the general public to lead. There is need for an assessment to the general public that takes into consideration lead exposures from lead in materials used in food preparation and serving, lead in ammunition, lead in fishing sinkers and jigs, and the cumulative effects of iodine and lead. |
In 2013, the Government of Canada published a comprehensive Risk Management Strategy for Lead, which outlined the ongoing and planned control actions for lead to protect human health and the environment. The Government recently published a report evaluating the performance of the risk management actions taken for lead and the progress made to achieve the human health and environmental objectives set out in the Risk Management Strategy. The report concluded that although progress has been made in reducing the risks of lead to human health and the environment, additional efforts are needed such as managing risks related to the use of consumer products containing lead. Based on the results in this report, the Government of Canada will continue its efforts in three main areas: monitoring lead levels in key environmental media as well as biomonitoring, managing risks associated with lead, and communicating with the public. Cumulative chemical effects may be considered during assessment, when data are available to indicate a common mode of action or synergistic effects of chemicals. |
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