Summary of public comments received on the draft screening assessment for the Fatty Acids and Derivatives Group

Comments on the draft Screening Assessment for the Fatty Acids and Derivatives Group, assessed under the Chemicals Management Plan (CMP), were submitted by the Canadian Consumer Specialty Products Association (CCSPA) and Pine Chemicals Association International, Inc.

Summarized public comments and responses from the Government of Canada are provided below, organized by topic:

1. Overarching comments

Summarized comment

Summarized response

Stakeholder appreciates the efforts of the Government and the focus on sound science for this risk assessment.

Noted.

Stakeholder is interested in viewing the latest list of substances in the third phase of CMP and the latest two-year rolling risk assessment publication plan in order to cross-reference substances being addressed under different activities.

 

An updated list of substances in the third phase of CMP (2018-2020) and an updated two-year rolling risk assessment publication plan were published on the CMP webpage on December 17, 2018.

 

The updated list of substances provides details on updated substance groups as well as information on where to find the relevant conclusions, when these have been published.

A stakeholder recommends that Chemical Abstract Service Registry Number (CAS RN) 61790-12-3 be referred to in the screening assessment as either “tall oil fatty acid” or “fatty acids, tall oil”, instead of “tall oil acid”, in order to avoid confusion with distillation feedstock, which is occasionally referred to as tall oil acid.

Changes were made to replace the “tall oil acid” with “tall oil fatty acid” in the screening assessment. 

A stakeholder recommends that CAS RN 61790-44-1 be referred to in this screening assessment report as “fatty acids, tall-oil, potassium salt”, instead of “potassium tallate”, in order to avoid confusion between high and low rosin tallates.

Suggested changes were made in the screening assessment.

 

2. Ecological assessment

Summarized comment

Summarized response

The stakeholder disagrees with the high hazard classifications of tall oil fatty acid and tall oil fatty acid, potassium salt, based on the approach applied in the ecological risk classification of organic substances, and recommends alternative sources of data. Data sources were identified and supporting arguments provided with regard to bioavailability, bioaccumulation potential, metabolism, biodegradation aquatic toxicity and the equivalent characteristics of these two substances in the aquatic environment.

Upon consideration of the new information, the bioconcentration potential of tall oil fatty acid and tall oil fatty acid, potassium salt have been decreased and the mode of action has been changed from reactive mode of action to narcosis-based. As a result, the hazard classifications of tall oil fatty acid and tall oil fatty acid, potassium salt, have been updated to low hazard, and the substances have been reclassified as having a low potential for harm to the environment.

3. Physical and chemical properties

Summarized comment

Summarized response

The vapor pressure estimates for dimer acid and trimer acid in Table 3-1 of the draft assessment are incorrect. The vapor pressure at ambient temperature should be negligible for both substances.

The vapor pressures for dimer acid and trimer acid in Table 3.1 have been updated.

4. Sources and uses

Summarized comment

Summarized response

Dimer and trimer acids are mainly produced from tall oil fatty acid and smaller amounts are produced from vegetable fatty acids.

Changes were made in the screening assessment to reflect this comment.

It is surprising that dimer acid is approved as a food additive in Canada, given that the US Food and Drug Administration does not approve dimer acid as a direct food additive.

There was an error in the draft screening assessment. This has been corrected in the screening assessment.

Stearic acid is not the source of dimer and trimer acid. The largest feedstock for dimer and trimer acids is tall oil, fatty acid. Smaller amounts are also produced by vegetable-derived oleic acid and oleic/linoleic acids.

Changes were made in the screening assessment to reflect this comment.

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