Response to comments on proposed Prohibition of Certain Toxic Substances Regulations: chapter 3


Short Chain Chlorinated Alkanes

Topic Comment Summary Response
Use in Paints An industry association stated that medium-chain chlorinated alkanes are used in paints found in pools. Since short-chain chlorinated alkanes are found in trace amounts in medium chain chlorinated alkanes, they suggested than an exemption should be provided for the use of paints found in pools. Short-chain chlorinated alkanes are not used intentionally in paints within Canada; however they may be incidentally present in small amounts.  In such instances, the prohibition on manufacture, use, sale, offer for sale and import of short-chain chlorinated alkanes would not apply.
International Jurisdictions Several industry associations mentioned that the Government of Canada should align their Regulations on short-chain chlorinated alkanes with those of the United States, the European Union, and globally. Further consultation should be taken before continuing with the proposed prohibition. Canada’s actions on short-chain chlorinated alkanes are consistent with those of other jurisdictions.  Short-chain chlorinated alkanes are already banned in Europe and the US EPA proposed new controls in March, 2012 to further address the manufacturing, processing, distribution in commerce and use of short-chain chlorinated alkanes.  Short-chain chlorinated alkanes have also been added to the Protocol on Persistent Organic Pollutants to the Convention on Long-range Transboundary Air Pollution. In addition short-chain chlorinated alkanes have been nominated for addition to the Stockholm Convention on POPs.
General Comments An industry association questioned whether there are appropriate test methods to determine whether short-chain chlorinated alkanes are present. Environment Canada has worked in collaboration with industry on developing test methods to determine whether or not SSCAs are present. Certain test methods for metal working fluids have been completed and other test methods are under development.
A non-governmental organization noted that based on assessments, all chlorinated alkanes meet the criteria of toxic under Section 64 of the Canadian Environmental Protection Act, 1999 (CEPA, 1999). When does the Government of Canada expect to develop options for the management of the remaining chlorinated alkanes? The Government of Canada is in the process of evaluating  potential options for the management of chlorinated alkanes containing 14-20 carbon atoms (medium and long chain chlorinated alkanes).
A non-governmental organization suggested that regulatory measures should be developed to address the full life cycle of short-chain chlorinated alkanes and to identify safe alternatives. The Regulations aim to minimize potential releases by prohibiting the manufacture, use, sale, offer for sale or import of short-chain chlorinated alkanes or any products containing short-chain chlorinated alkanes. Also, the monitoring of short-chain chlorinated alkanes is occurring under a comprehensive monitoring and surveillance strategy for all substances under the Chemicals Management Plan. This monitoring will be used to determine whether further action needs to be taken to address the potential releases of short-chain chlorinated alkanes from other sources.
An industry association stated that the raw materials used to make medium-chained chlorinated alkanes usually specify the short-chain chlorinated alkanes content to 1%, thus the 0.5% reporting threshold is difficult to meet. The intent of this reporting requirement is to gather information on the incidental presence of short-chain chlorinated alkanes in medium-chain chlorinated alkanes.  This information will be used to assess the potential need to take action to address potential exposure or release where short-chain chlorinated alkanes are incidentally present.  While it may be difficult to meet the 0.5% threshold, it should be noted that the European Regulation on Registration, Evaluation, Authorization and Restriction of Chemicals requires reporting if short-chain chlorinated alkanes are present in a concentration above 0.1%.
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