Summary of public comments received on the draft screening assessment for the phenol-formaldehyde resins group

Comments on the Draft Screening Assessment for the Phenol-Formaldehyde Resins Group, assessed under the Chemicals Management Plan, were submitted by the Toy Association and the Canadian Toy Association, Canadian Consumer Specialty Products Association, and the Canadian Network for Human Health and the Environment.

Summarized public comments and responses are provided below, organized by topic:


Summarized comment Summarized response
As stated in the draft screening assessment, most polymers used in toys are traditional thermoplastic resins; however, there are minor uses of phenol-formaldehyde resins (PFR) in some toys for electric/electronic components where heat resistance or flame retardance is necessary. The safe use of PFR in these ways has been well documented over the years. Overall, the stakeholder supports the proposed assessment conclusion. Noted.
Assistance is offered, should additional information be required.  Noted.

Human health assessment

Summarized comment Summarized response
The assessment does not consider occupational hazards or possible informed substitutes. The “non-toxic” assessment leaves the impression these chemicals pose little if any hazard, which is not true. Screening assessments conducted under the Canadian Environmental Protection Act, 1999 are based on the best available data. The assessment focused on potential risks from exposure to the general population, rather than occupational exposure. Hazards related to chemicals used in the workplace are defined within the Workplace Hazardous Materials Information System (WHMIS). Mechanisms such as the Identification of Risk Assessment Priorities process are used to monitor new information on substances.
Literature search indicates that the Canadian government’s assessment of these resins is not in line with the hazards that manufacturers are declaring in the European Union, which includes asthmagen properties and dermal sensitization. The assessment acknowledges the data gaps, but does not address them in the assessment. It is recommended that the assessment take a more preventative approach and declare all the resins to be toxic because of their skin and respiratory effects (and, in some cases, other reported health effects). Proper assessment of oC-A-PF and NaPS-BPSF should be suspended until there is more information for a scientific decision that incorporates the precautionary principle. It is not expected that members of the general population will be exposed to the reactive form of the polymer which is able to induce dermal sensitization, or which can be inhaled and act as an asthmagen. These health concerns are associated with manufacturing or occupational exposures. This assessment evaluates the risks associated with exposures from products available to consumers. Hazards related to chemicals used in the workplace are defined within the Workplace Hazardous Materials Information System (WHMIS).
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