Notice of objection filed by Chlorinated Paraffins Industry Association (additional comments)

June 17, 2009

Executive Director
Existing Substances Division
Environment Canada
Gatineau, Quebec K1A 0H3

Via Email: Existing.Substances.Existantes@ec.gc.ca

RE: Evaluation of the Bioaccumulation of Chlorinated Paraffins; Information for Consideration on the Proposed Order to Add Chlorinated Paraffins to Schedule 1 of the Canadian Environmental Protection Act (CEPA), 1999 (Canada Gazette, Part I, September 20, 2008)

Dear Minister of Environment:

The Chlorinated Paraffins Industry Association (CPIA)1 previously commented on, and submitted a Notice of Objection to, the September 20, 2008, notice in Canada Gazette, Part I, regarding Environment Canada's (EC) Proposed Order to add Chlorinated Paraffins (CPs) to the List of Toxic Substances in Schedule 1 of the Canadian Environmental Protection Act (CEPA), 1999 (the "Proposed Order"). This letter is to alert EC to several recent developments on the issue of bioaccumulation potential for CPs that have transpired since CPIA filed its comments and Notice of Objection last year.

Bioaccumulation is an important aspect of Canada's assessment of CPs, especially since it is a criterion for determining whether a chemical should be place on the Virtual Elimination (VE) list. CPIA would like EC to consider the following important recent developments related to the bioaccumulation of mid-chain chlorinated paraffins (C14-C17) and the long-chain chlorinated paraffin product (C18-C20), which as CPIA previously reported, to the best of our knowledge is not used in Canada.

CPIA continues to believe that Canada's own Risk Assessment should support the conclusion that LCCPs do not meet the criteria for CEPA toxic for either human health or the environment, including not meeting the criterion for bioaccumulation. CPIA also believes that EC should wait to consider this important new data on bioaccumulation potential that is being developed for MCCPs, before taking the significant step of placing MCCPs on the VE list. CPIA would welcome the opportunity to further discuss this matter with the appropriate officials.

Please let me know if we can provide any further clarification about this supplemental information or CPIA's original comments.

Sincerely,

Robert J. Fensterheim
Director

Attached:
1) Protocol for OECD305 Study of radiolabelled Chlorinated Tetradecane(C14 CP). Available in PDF Format (128 KB)

1 The Chlorinated Paraffins Industry Association (CPIA) represents manufacturers of chlorinated paraffins from around the world.

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