Canada Gazette Part I, Vol. 144 No. 31, July 31, 2010
Submitted to:
Executive Director,
Program Development and Engagement Division,
Gatineau, Quebec K1A 0H3
E-mail: Existing.Substances.Existantes@ec.gc.ca
and
DSL Surveys Coordinator
Place Vincent Massey, 20th Floor
351 St. Joseph Boulevard
Gatineau, Quebec K1A 0H3
E-mail: DSL.surveyco@ec.gc.ca
Submitted by
Anna Tilman, IICPH
anna@iicph.org
September 27, 2010
Overview of Submission
This submission is with respect to two substances in Batch 8 of the Chemical Management Plan (CMP) as follows:
Benzene, 1-methyl-2-nitro (2-Nitrotoluene) CAS RN 88-72-2; and
- Butylated hydroxyanisole (BHA) CAS RN 25013-16-5
Canada Gazette Part I, Vol. 144 No. 31, July 31, 2010
The final screening assessment for 2-nitrotoluene has concluded that it meets the criteria for toxicity under Section 64© of the Canadian Environmental Protection Act 1999 (CEPA 1999). The risk management approach proposed is the implementation of Significant New Activity (SNAc) provisions under Section 81(3) of the Act and to add 2-nitrotoluene to the List of Toxic Substances, Schedule 1 (CEPA 1999).
IICPH supports the conclusion that 2-nitrotoluene is CEPA-toxic and the proposal to add it to the List of Toxic Substances. However, it has concerns that the assessment has concluded that 2-nitrotoluene is unlikely to cause ecological harm in Canada. Furthermore, it finds the proposed risk management approach fails to address serious potential health and environmental effects posed by this substance. This submission will present the case for a stronger, regulatory proposal for the risk management strategy for 2-nitrotoluene.
With respect to BHA, the final screening assessment concludes that it is not toxic under CEPA 1999, and thus, no risk management is required. IICPH does not support this conclusion and will argue the case for BHA to be declared toxic under CEPA 1999, on the basis of potential health and environmental effects.