Summary of Public Comments Received on the Draft Screening Assessment Report for the Epoxy Resin Group

Official Title: Summary of Public Comments Received on the Draft Screening Assessment Report for the Epoxy Resin Group

Comments on the draft Screening Assessment Report (dSAR) for the Epoxy Resin Group to be addressed as part of the Chemicals Management Plan (CMP) were provided by KAND EHS Services Inc., Chemistry Industry Association of Canada (CIAC), and Canadian Consumer Specialty Products Association (CCSPA).

A summary of comments and responses are provided below, organized by topic:

1. New information and data updates

Summarized Comment Summarized Response
In section 2.7.2.1, the conversion of EC3 5.7% into an exposure threshold of 1,425 µg/cm3 seems to be incorrect.   The calculation was reviewed and is correct. No changes were made.

2. Methodology

Summarized Comment Summarized Response
The dSAR provides a fair and reasonable representation of the potential conditions that exist in Canada. Noted.

3. Sources and releases

Summarized Comment

Summarized Response

The substances do not include residual monomers, such as bisphenol A or epichlorohydrin.

Noted.

The quantities used for the paints and coatings formulation release scenario and the application scenario seem excessively conservative. Apply more accurate, evidence-based values.

The presented risk quotients are an over estimation of the potential risk.

The quantities used for these scenarios are based on information obtained through industry surveys. Since some of this information is confidential business information (CBI), a range of data is used in the screening assessment to protect confidentiality. The values used for these scenarios represent the high end of the range and may overestimate the potential risk. Further refinement of the estimates is not required because no risk was identified.

4. Risk characterization

Summarized Comment Summarized Response
The primary exposure scenario for DGEBA was calculated from food and drink cans lined with epoxy-based coatings but elsewhere in the assessment, this scenario is considered insignificant. Although exposure to DGEBA epoxy resins from food sources is not expected, unreacted DGEBA in some can linings could potentially migrate into the food. Therefore, oral exposure to DGEBA is considered the primary source of exposure because dermal and inhalation exposures are not expected.

5. Conclusion

Summarized Comment Summarized Response
It is positive that the dSAR recognizes that the substances will not cause cancer and are not harmful to the reproductive process or developing fetuses. Noted.
Although our review identified some minor concerns, the draft assessment is a fair and reasonable representation of the potential conditions that exist in Canada for these substances and the findings and recommendations are supported. Noted.

6. Consultation and stakeholder engagement

Summarized Comment Summarized Response
It is acknowledged that additional information that was submitted by stakeholders was used in the assessment. Noted.
Assistance is offered, should additional information be required.   Noted.
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