Summary of public comments received on the draft screening assessment for silver and its compounds
Comments on the draft Screening Assessment for Silver and its Compounds, assessed under the Chemicals Management Plan (CMP), were submitted by the Canadian Consumer Specialty Products Association, the Canadian Fuels Association, the Mining Association of Canada, and Prism Powder Coatings Inc.
Summarized public comments and responses from the Government of Canada are provided below, organized by topic.
Overarching comments
| Summarized comment | Summarized response |
|---|---|
| Efforts made under the Chemicals Management Plan to improve screening assessment approaches for metals (e.g., consideration of background concentrations, natural enrichment, and factors influencing bioavailability and the dissolved fraction of total concentrations) are appreciated. As well, the effort in addressing challenges within certain datasets (e.g., those with a prevalence of non-detect data and elevated detection limits compared to the predicted no-effect concentration) adds important context and understanding of the complexities of metals in the environment and increases the quality of screening assessments. | Noted. |
| We agree with the proposed conclusion of the draft screening assessment that the seven substances in the Silver and its Compounds Group do not meet any of the criteria set out in section 64 of the Canadian Environmental Protection Act, 1999 (CEPA). | Noted. |
| The draft screening assessment is balanced and representative of relevant public hazard and exposure pathway information. | Noted. |
Uses and sources
| Summarized comment | Summarized response |
|---|---|
| The draft screening assessment indicated that silver may be used in a range of products available to consumers in Canada, including pesticides. However, silver is not registered as a pesticide for the purpose of antimicrobial active ingredients and end-use products under the Pest Control Products Act (PCPA). There are hundreds of products for retail in Canada that contain silver for the expressed intent as acting as an antimicrobial (e.g., wound bandages, fabric clothes). Clarification on the use of silver as a pesticide is sought. |
Silver is not a registered active ingredient under the PCPA. A product treated with silver as an antimicrobial material preservative requires registration with Health Canada’s Pest Management Regulatory Agency (PMRA) before it can be imported, sold, distributed or used in Canada. The Information Note – Treated Articles provides guidance to manufacturers, distributors and importers of pesticide treated articles sold and used in Canada and explains the regulatory requirements for articles that have been treated with antimicrobial preservatives. There are pest control products that contain silver, but not as an active ingredient or for a pesticidal function. Changes were made to the screening assessment to specify that silver is used as a formulant in registered pest control products. |
Follow-up activities
| Summarized comment | Summarized response |
|---|---|
| The Canada Gazette publication provided notice from the Government of Canada that options for follow-up activities to track changes in commercial use patterns of exposure to the subject substances are being considered. It is recommended that Environment and Climate Change Canada (ECCC) and Health Canada (HC) continue to rely on the National Pollutant Release Inventory (NPRI) data that are collected annually from emitters. If additional monitoring is justified and desired, we recommend that ECCC and HC work collaboratively with reporting parties to develop reasonable tracking measures that are commensurate with the risk of increased exposure, without adding undue administrative burden to ECCC, HC or the reporting parties. | Noted. |
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