| Summarized comment | Summarized response |
|---|
| Stakeholders support the approach to manage risks to methylenediphenyl diisocyanates (MDIs) in certain spray polyurethane foam (SPF) products. | Noted. |
| The stakeholder does not agree with the selection of a code of practice as an effective risk management instrument. | The Government of Canada published the Risk Management Approach which identified a code of practice as the selected risk management instrument. The publication was subject to a 60-day public comment period. A code of practice was selected as a means to create standardized information and recommendations. The code of practice sets out recommendations for any person who manufactures, imports, or sells spray polyurethane foam products to promote safe use and handling in order to help reduce exposure of Canadians to MDIs. The Code will be periodically reviewed to verify its effectiveness in meeting the risk management objectives. |
| The stakeholder would like risk management actions to address all uses of MDIs. | The screening assessment concluded certain MDIs meet the criteria for “toxic” as set out in section 64 of the Canadian Environmental Protection Act, 1999. A risk was identified for MDIs in low-pressure two-component SPF products. As such, the risk management objective is to reduce exposures to Canadians from MDIs in these products. |
| The stakeholder would like risk management actions to address all chemical substances used in spray polyurethane foam products. | The screening assessment concluded certain MDIs meet the criteria for “toxic” as set out in section 64 of the Canadian Environmental Protection Act, 1999. A risk was identified for MDIs in low-pressure two-component spray polyurethane foams products. As such, the risk management objective is to reduce exposures to Canadians from MDIs in these products. |
| The stakeholder noted a lack of clarity and specificity in the code of practice regarding the hazards of MDIs, leading to an ineffective risk management instrument. | The screening assessment identified inadequate margins of exposure for respiratory sensitization. A code of practice was selected as a means to create standardized information and recommendations to reduce inhalation exposure of Canadians to spray polyurethane foam products containing MDIs. The code of practice has been revised to provide more clarity and specificity on the recommended practices to promote safe and proper use of the products. Examples and guidance have been added to the content of the code where appropriate. |
| The stakeholder states the risk management instrument was developed with no public consultation process. | The Government of Canada published the Risk Management Approach which identified a code of practice as the selected risk management instrument. The Risk Management Approach was subject to a 60-day public comment period. A collaborative approach was used to develop this risk management instrument with potentially implicated parties. The proposed code of practice was also subject to a 60-day public comment period following publication. The list of publications associated with MDIs is available online. |
| The stakeholder expressed concerns over the lack of occupational exposure considerations. | Occupational exposure has not been included in the risk assessments and risk management under the Chemicals Management Plan; however, the Government of Canada is exploring approaches to modernize chemicals management, including how to better integrate occupational safety into the Chemicals Management Plan. |
| The stakeholder would like the Government of Canada to promote and publicize information on potential alternatives to MDIs in spray polyurethane foam products. | It is noted in the Risk Management Approach that some products do not contain MDIs, and a possible alternative to using SPF products oneself is to have a professional install the product. Health Canada’s Healthy Home campaign provides information to Canadians on chemical safety in the home, including for do-it-yourself projects. |
| The stakeholder would like Chemical Abstracts Service (CAS) registry numbers to be included in the Schedule 1 listing. | Generally, Schedule 1 substance listings do not use CAS numbers. |
| The stakeholder is supportive of the reporting requirements. | Noted. |
| The stakeholder suggested a dynamic reference to the Consumer Chemicals and Containers Regulations, 2001. | The Code of Practice may be revised if the Regulations change (if necessary). |
| The stakeholder would like language on reviews of the code of practice to be more specific with regard to timing. | The Government of Canada has published a performance measurement evaluation strategy in response to the report of the Commissioner of the Environment and Sustainable Development (CESD). Reviews of the code of practice may be considered in conjunction with the priorities and timelines of the performance measurement evaluation strategy. |
| The stakeholder noted that materials on safety practices, and safe use and handling may originate from many sources. | The Government of Canada has revised the reporting requirements for the code of practice to include a question about sources of information and materials. |
| The stakeholder would like further guidance on declaration of adoption of the code and the reporting information, including timelines. | The Government of Canada has made changes to the declaration and reporting information to provide additional guidance and clarity. |
| The stakeholder is supportive of the flexibility in timing to report changes related to the implementation of the code of practice. | The Government of Canada collaborated with stakeholders to develop practical timing for the implementation of the code of practice. |
| The stakeholder would like risk management to address carcinogenicity. | The screening assessment identified inadequate margins of exposure for respiratory sensitization only. The code of practice aims to reduce inhalation exposure of Canadians to spray polyurethane foam products containing MDIs. |
