Notice of objection filed by Chlorinated Paraffins Industry Association

November 19, 2008

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

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

RE: 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 submits these comments in response 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"). The CPIA further submits a Notice of Objection and hereby requests pursuant to section 333 of CEPA, that the Minister convene a Board of Review to assess the proposed action and the appropriateness of proceeding with the CEPA Toxic designations for all CPs.

These comments and Notice of Objection are based on an extensive evaluation of the August 30, 2008 Follow-up Canadian CP Risk Assessment. As the attached comments will document, there does not appear to be an objective justification to support the proposed CEPA Toxic designations. CPIA's objection is based on many factors which can succinctly be characterized as follows:

In addition to the lack of supporting evidence, the proposal does not clearly define the specific substances covered. This is evidenced by the stated inability to ascribe CAS numbers to the listing. The CPIA fails to understand this difficulty given that the affected compounds are presumably those that are on the Domestic Substance List. If Canada proceeds with the listing, it is incumbent on Canada to clearly identify the specific compounds covered. The CPIA would welcome the opportunity of further discussing this matter with the appropriate officials. Please do not hesitate to contact me if I can provide any clarification.

Sincerely,

Robert J. Fensterheim
Executive Director

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

2 While nutrition surveys and guidelines indicate that it is typical to introduce solid foods between the ages of 4 and 6 months, these are typically simple cereals and pureed vegetables - not cheese, potato crisps, jams, and other foods included in the exposure assessment by Campbell (1980).

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