Consultation document: proposed risk management for non-pesticidal uses of tributyltin: chapter 4

4 Proposed Risk Management Measure for Non-Pesticidal Uses of Tributyltins

It is proposed to add tributyltins to the Prohibition Regulations to prohibit their manufacture, use, sale, and offer for sale and import in Canada. Annex A summarizes the main elements of the Prohibition Regulations. The prohibition of tributyltins will not apply to instances where the substance is incidentally present. For example, tributyltins may be present as an impurity (i.e. incidental presence) in other organotin compounds, such as tetrabutyltin, mono- and dibutyltins. Hence, the following would not be affected by the proposed amendment as per section 4 of the Prohibition Regulations:

It is noted that it is currently not possible to eliminate these trace amounts, and there are no known associated releases to the environment from these activities.

Furthermore, although it is proposed to add tributyltins to the Prohibition Regulations, these regulations specify that they do not apply to substances that are contained in a control product within the meaning of section 2 of the PCPA (i.e. a pesticide regulated under the PCPA).

Adding tributyltins to the Prohibition Regulations will prevent their reintroduction in any non-pesticidal uses in Canada.

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