Public comment process on risk assessment documents

Fact sheet series: Topics in risk assessment of substances under the Canadian Environmental Protection Act, 1999 (CEPA 1999)

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The public comment process

Under CEPA 1999, the following types of risk assessment documents must be published in the Canada Gazette for a 60-day public comment period:

  • screening assessments (section 74)
  • reviews of decisions of other jurisdictions (section 75)
  • Priority Substances List assessments (section 76)

Other risk assessment-related documents, including state of the science reports and science approach documents, may also be published in the Canada Gazette and may have a 60-day public comment period.

The importance of public comments

The public comment period is an important step in the risk assessment process as it is the opportunity for interested parties to provide feedback on the assessment. Stakeholders might indicate what they think was done well or provide constructive feedback so that the assessment can be strengthened from a scientific or communication perspective. Comments may be provided that identify any inaccuracy in the assessment or that provide input on whether the approaches used and conclusions proposed are considered appropriate. The public comment period is also a critical point in the process to provide new and relevant information that may not have been considered in the draft risk assessment.

Health Canada and Environment and Climate Change Canada carefully review all comments and information received, and changes are made to the risk assessment during its finalization, as appropriate. For example, if additional environmental monitoring or biomonitoring information is provided during the public comment period for a draft screening assessment, this may inform exposure estimates. This may result in replacing conservative assumptions used in the absence of data. This additional information, for example, could reduce the number of exposure scenarios of concern, or conversely lead to the addition of new scenarios.

Types of public comments

Comments can span a range of issues related to the risk assessment, and they can be general or technical in nature. During the 60-day public comment period, any person may self-identify as a stakeholder wishing to be further consulted and engaged and submit any kind of information that is relevant to the substances included and assessed in the risk assessments. Some general comments may include:

  • Was the assessment conducted in an open and transparent manner?
  • Is there additional or key information that was not included in the assessment that may have an impact on the conclusion?

More technical comments may ask:

  • Were vulnerable populations appropriately identified?
  • Were key sources of exposure and hazard studies included?
  • Were critical uncertainties identified?
  • Was the risk characterization and possible risk management appropriate?

Providing comments on risk assessment documents that are posted for public comment is done by citing the Canada Gazette, Part I, the date of publication of the notice, and sending the submission:

  • by email to: substances@ec.gc.ca
  • by mail to: Executive Director, Program Development and Engagement Division, Environment and Climate Change Canada, Gatineau, Quebec K1A 0H3
  • by fax to: 819-938-5212.

Comments may also be submitted to the Minister of the Environment, using the online reporting system available through Environment and Climate Change Canada's Single Window.

Publication of public comments and responses

Once comments are received, they are organized and consolidated. Comments are summarized and responses are prepared in clear, concise, and non-technical language, prior to publication on the Government of Canada Website, Canada.ca.

Comments are not directly attributed to the individual that submitted them; however, a list of the stakeholder groups/organizations is typically provided with the summary of public comments and responses. If data or details on studies were submitted, Health Canada and Environment and Climate Change Canada acknowledge that the data were provided and that they were considered in finalizing the risk assessment.

The summary of public comments and responses is published simultaneously with the final risk assessment on Canada.ca.

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