Summary of public comments received on the draft screening assessment for benzoxazole, 2,2'-(1,4-naphthalenediyl)bis- (Fluorescent brightener 367)

Fluorescent whitening agents (FWAs) are regarded as poorly biodegradable. 

Considering the low solubility and log K_ow values ranging from 4 to 7.5 for fluorescent brightener 367, it can be concluded that it has high potential of bioaccumulation. Therefore, more research needs to be carried out on environmental fate and bioaccumulation of fluorescent brightener 367. 

• The Ecological Risk Classification of Organic Substances (ERC) approach (ECCC 2016a) was used to characterize the potential exposure to the environment from fluorescent brightener 367. 
• According to the persistence and bioaccumulation data used in the ERC approach, the substance has a critically long overall persistence and is highly bioaccumulative. However, fluorescent brightener 367 was not identified in environmental media in Canada. Significant releases to the environment in Canada are not expected due to the low quantity of fluorescent brightener 367 imported into or manufactured in Canada (less than 100 kg) according to information submitted in response to a CEPA section 71 survey during the 2011 calendar year (Environment Canada 2013). As a result of the low exposure potential of this substance, its environmental fate and bioaccumulation were not further investigated. 

Fluorescent brightener 367 is a Fluorescent Whitening Agent (FWA). FWAs are used for whitening and brightening materials. One of the largest source of FWAs is detergent products, such as laundry soaps and cleaning agents.

The screening assessment focused on fluorescent brightener 367 (CAS RN 5089-22-5) and does not consider other fluorescent brighteners or fluorescent whitening agents. Key sources of exposure to the Canadian population were found to be from the use of certain nail polishes. No evidence of other uses, such as in laundry soaps or cleaning agents was identified in Canada.

Laundry wastewater is the largest contributor of fluorescent brighteners to wastewater systems. Since traditional water treatment technologies are still unable to completely degrade and remove fluorescent brightener 367, the substance shows a huge potential of bioaccumulation in food chains through water systems and thereby impacting human health and wildlife. Laundry detergent manufacturers should take proper precautions for disposal or accidental release of fluorescent brightener 367 into environment.

According to research studies, it was observed that there is a correlation between fluorescent brighteners and fecal coliform (anaerobic bacteria) levels in aquatic environments.

Although it has been concluded that fluorescent brightener 367 does not enter the environment in a concentration which is harmful to human health, the assessment fails to consider exposure from release into the environment from the use and manufacturing of laundry detergents, as well as plastic compounding companies or importers.

No evidence was found to suggest that fluorescent brightener 367 is used as a fluorescent brightener in laundry detergent or laundry cleaning products in Canada or that it is imported into Canada by plastic compounding companies or importers. 

The correlation between fluorescent brighteners and fecal coliform levels in aquatic environments is not relevant to the assessment of fluorescent brightener 367. Release of fluorescent brightener 367 to environmental media from the identified uses is expected to be low.

Some alternative substances are suggested for use instead of fluorescent brightener 367 as a fluorescent brightener. 

Based on available information, the screening assessment concluded that current levels of exposure do not pose a risk to the general population or the environment. Given that no risk was identified and therefore no risk management actions are being proposed, no consideration of substitutes or alternatives was undertaken. 

Public awareness is mandatory to avoid any accidental exposure of infants to fluorescent brightener 367 from cosmetic products and laundry detergents. 

The screening assessment concluded that current levels of exposure do not pose a risk to Canadians. The margins of exposure were considered adequate to account for any uncertainties, and this includes variability within the population (i.e., infants). In addition, exposure to nail polish is not expected for infants. No evidence of fluorescent brightener 367 use in laundry detergent was identified.  

Occupational exposure limits should also be taken into consideration since minor dermal irritation was reported by researchers (without proper data). 

Manufacturers should maintain proper precautions following occupational exposure limits and disposal of the same into environment.

Screening assessments conducted under the CMP focus on risks and exposure to the general population, rather than risks of exposures in the workplace. Hazards related to chemicals used in the workplace are defined within the Workplace Hazardous Materials Information System (WHMIS).

The Government of Canada is currently working with provinces and territories to explore ways to enhance the protection of workers from exposure to chemicals by integrating and leveraging the information, tools, and/or technical expertise of the CMP and Health Canada’s Workplace Hazardous Products Program. 

More data is required to determine the release, environmental fate and toxicity of fluorescent brightener 367. 

Screening assessments are based on the best available data. New information can be submitted through several mechanisms defined under specific sections of CEPA 1999 and other legislation.