Summary of public comments received on the draft screening assessment for the poly(amines) group

Comments on the Draft Screening Assessment (dSAR) for the Poly(amines) Group, assessed under the Chemicals Management Plan (CMP), were submitted by Canadian Consumer Specialty Products Association (CCSPA) and Canadian Network for Human Health and the Environment (CNHHE).

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

Overarching

Summarized comment

Summarized response

Assistance is offered, should additional information be required. 

Noted.

Information and data gaps

Summarized comment

Summarized response

There is little information available about the uses, functions, quantities and hazards of these poly(amines) in the report and in various sources, including the European Chemical Agency (ECHA) database and the Healthy Building Network’s DataCommons, and uncertain confidence in some of the information.  There is also little evidence of precaution in the assessment.

The evaluation of risk to human health is based on the approach outlined in the Second Phase of Polymer Rapid Screening.  Available information associated with evaluation of ecological risk is presented in the screening assessment.  It is considered that there is sufficient data available to conclude on these substances under the Canadian Environmental Protection Act, 1999 (CEPA).

What hazards do workers (for example, hairdressers, pulp and paper workers, wastewater treatment workers, fracking staff) face from using the personal care products?

Screening assessments conducted under CEPA are based on the best available data. Assessments 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).

Human health assessment

Summarized comment

Summarized response

Why is 2-propen-1-aminium, N,N-dimethyl-N-2-propenyl-, chloride, homopolymer (CAS RN 26062-79-3) listed in the US Environmental Protection Agency’s Endocrine Disruptor Screening Program (EDSP)?

The US EPA does not indicate the reason why each individual substance is included on their list, but they indicate that many are added as a result of high throughput screening in vitro assay and QSAR (quantitative structure–activity relationship) modelling.

Concerns were raised regarding urea, polymer with ammonia and formaldehyde (27967-29-9), as it may be an asthmagen, according to the Healthy Building Network’s DataCommons (DC) and is on the Living Building Red List and Perkins + Will’s list of substances to avoid in  buildings. Therefore this chemical should be considered a danger to human life or health under CEPA.

Exposure to the general public was determined to be low during the screening process; therefore, the health risks for inhalation are low.

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