January 1, 2007

Ottawa commits $300M to speed review of chemicals under new management plan

By: Mark Sabourin

The federal government has announced that it intends to commit $300 million over the next four years to implement a new Chemicals Management Plan. The plan targets a total of some 4,000 chemical substances that may pose a risk to human health or the environment.

These substances were chosen for assessment from the Domestic Substances List, a compilation of some 23,000 substances used in, manufactured in or imported into Canada for commercial purposes in quantities greater than 100 kg per year between 1984 and 1986. Over a seven-year period, all of these substances were categorized in terms of health or environmental risk, and, except for the list of 4,000, were determined to be in need of no further action. Substances not included in the Domestic Substances List were not reviewed, since these are already managed as "new substances" under the New Substances Notification Regulations.

The 4,000 substances slotted for further review are those that are considered to pose the greatest potential for exposure to individuals in Canada; or those that are persistent and/or bioaccumulative, and deemed to be inherently toxic to humans or non-human organisms.

From the list of 4,000, the government has chosen an initial 200 substances for industry comment, a process referred to as "Challenge to Industry." At three-month intervals starting February 2007, the government will publish profiles of these substances, in batches of 15 to 30, giving industry and other stakeholders six months to comment and to provide any additional information they may have in their possession. The government will then review the information and decide whether further action is required.

Following each batch challenge period, government scientists will have a maximum of 6 months to review the information provided, explains Health Canada spokesperson Jason Bouzanis. The government will then decide what actions are to be taken through an expedited application of the Canadian Environmental Protection Act (CEPA).

Possible outcomes include further consideration for risk management or a decision to conduct a more in-depth Priority Substances List Assessment. Ultimately, a substance could be added to the list of toxic substances in Schedule 1 of CEPA.

This review process has already been tested in a pilot program initiated in 2000. A total of 123 substances were assessed in that pilot program, and the information gleaned from that process has been used to develop the review process that will be initiated in early 2007.

Included in the first batch of substances are several isomers or derivatives of napthalene, oxirane, benzene, peroxide and propanedinitrile. A complete list of the 200 substances can be found by following the link entitled Challenge to Industry on the program's Web site, www.chemicalsubstances.gc.ca. The site also contains a searchable database of all of the substances slated for further assessment, showing the grounds for their categorization.

Of the approximately 4000 substances identified through the categorization, a total of 500 are considered high-priority, says Bouzanis. Two hundred of those will be part of the initial Challenge to Industry effort. Of the remaining 300, 200 are thought not to be in commerce or to be in very limited use. Bouzanis says they will be subject to Significant New Activity Controls, under which industry will required to provide data to Health Canada and Environment Canada before the substances can be extended to other uses. The balance have already been assessed or are specific to the petroleum industry and will be assessed and managed as a group.

As to the balance, 2,300 were identified as medium-priority, and 1,200 were deemed low-priority.

The 1,200 low-priority substances will be assessed quickly, with results expected to be released in the spring of 2007, says Bouzanis. Work on medium-priority substances will begin after completion of all high priorities. In the meantime, the government will work with industry to develop sector-based approaches for sound management of the substances.

In announcing the Chemicals Management Plan, the government stated that "the plan takes immediate action to regulate chemicals that are harmful to human health or the environment." However, no timeline has been offered for assessment or regulation of the full list, and indeed, the government suggests that "further work may also determine there is no concern to human health and the environment for some of these substances."

Bouzanis says that, in addition to the $300 million funding boost for the program, new tools and processes in place mean that evaluations will increase "from about 10 per year to hundreds." There's a much greater focus on data considered critical, says Bouzanis, and the amount of work done and the associated documentation are tailored to the complexity of the potential issues related to exposure.

Canada is the first country to have categorized all of its known substances in terms of potential risk to human health or the environment. A similar process has been underway for some years in Europe, under the auspices of the OECD. Undertaking an investigation only of high-production-volume chemicals (those produced or imported at levels greater than 1,000 tonnes per year), a final list of 4,843 substances was compiled from national inventories. From this list, 1,000 substances were selected as priorities for investigation, with the completion of initial hazard assessments scheduled for 2004.

"All nations face the same challenge with respect to managing their legacy chemical substances," says Bouzanis. "The Chemical Management Plan is a regulatory regime that will produce results much quicker than others. We would welcome other countries to examine our approach."

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