Summary of public comments received on the draft screening assessment for Phosphoric Acid Derivatives Group
Comments on the draft Screening Assessment for the Phosphoric Acid Derivatives Group, assessed under the Chemicals Management Plan (CMP), were submitted by the Canadian Fuels Association and an individual.
Summarized public comments and responses are provided below, organized by topic.
Ecological assessment
| Summarized comment | Summarized response |
|---|---|
| The Government of Canada should consider providing more information in the screening assessment on the environmental fate of phosphoric acid and its derivatives. | Based on the information considered under the Ecological Risk Classification of organic substances approach, trixylyl phosphate was classified as having moderate ecological exposure potential on the basis of a long overall persistence (the sum of chemical half-lives in all media weighted by the mass fraction of the chemical as determined using a multimedia fate model) and a moderate reported use volume according to information reported under a section 71 survey. The other two substances (oleyl phosphate and CAS RN 119345-01-6) were classified as having a low exposure potential. This characterization took some aspects of environmental fate into consideration. On the basis of current use patterns, these substances are unlikely to be resulting in concerns for the environment in Canada. |
Human health assessment & use of alternatives
| Summarized comment | Summarized response |
|---|---|
The Government should consider providing more information in the screening assessment on the health effects of phosphoric acid used in soft drinks. Also, soft drink manufacturers should consider using substitutes of phosphoric acid or limiting its use. | This screening assessment focused on three phosphoric acid derivatives. Phosphoric acid itself will be assessed at a later date, as part of the Acids and Bases Group under the CMP. More information may be found here. |
Conclusions
| Summarized comment | Summarized response |
|---|---|
| The draft screening assessment is balanced and representative of relevant public hazard and exposure pathway information. We agree with the proposed conclusions. | Noted. |
Occupational exposure
| Summarized comment | Summarized response |
|---|---|
| The Government should consider providing more information on occupational exposures, including occupational threshold limits for these substances, which should be strictly followed by industries. | Screening assessments under the Canadian Environmental Protection Act, 1999, focus on risks of 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 the provinces and territories to explore ways to enhance the protection of workers from exposure to chemicals by integrating and leveraging the information, tools, and technical expertise of the CMP and Health Canada’s Workplace Hazardous Products Program. |
Follow-up activities
| Summarized comment | Summarized response |
|---|---|
Food packaging companies using phosphoric acid and its derivatives should test their packaging to ensure no leaching is occurring that could result in effects to human health through the migration to foods. Allowable tolerance and acceptable daily intake limits of phosphoric acid and its derivatives should be determined and strictly followed by industries using these substances as food additives and packaging industries. | In Canada, packaging materials in which food is sold must comply with safety provisions set out under section 4(1)a of the Food and Drugs Act, and Division 23 of the Food and Drug Regulations (FDR). The responsibility to ensure that the materials used in contact with foods comply with regulatory requirements lies with the food seller (for example, the food manufacturer, packager, distributor, processor, etc.). Migration limits are not established for chemicals used in food packaging as the safety assessment of food packaging materials are conducted on a case-by-case basis. |
When considering options for follow-up activities to track changes in exposure to trixylyl phosphate, it is recommended that the Government continue to rely on National Pollutant Release Inventory (NPRI) data. If additional monitoring is needed, it is recommended that the Government work with the reporting parties to develop reasonable tracking measures that match the risk of increased exposure, without adding undue administrative burden to the reporting parties or the Government. | The Government is committed to consulting with stakeholders when developing options for follow-up activities. |
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