Summary of public comments received on the draft screening assessment and risk management scope for chlorocresol

Comments on the Draft Screening Assessment and Risk Management Scope for chlorocresol, assessed under the Chemicals Management Plan (CMP), were submitted by Consumer Health Products Canada, Lanxess Corporation and an individual.

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

Occupational exposure

Summarized commentSummarized response
Occupational exposure standards and health effects from long-term exposures at work should be considered in the screening assessment. Screening assessments conducted under the Canadian Environmental Protection Act, 1999 (CEPA) are based on the best available data. Under the Chemical Management Program (CMP), risk assessments focus on the risk of exposure to the general population, rather than risk of exposures in the workplace. Hazards related to chemicals used in the workplace are defined within the Workplace Hazardous Materials Information System (WHMIS).The Government of Canada is currently working with the provinces and territories to explore ways to enhance the protection of workers from exposure to chemicals by integrating and leveraging the information, tools, and/or technical expertise of the CMP and Health Canada’s Workplace Hazardous Products Program. For more information, please visit: An Integrated Strategy for the Protection of Canadian Workers from Exposure to Chemicals; publication date: 2019-07-11.

Ecological assessment

Summarized commentSummarized response
The commenter notes that chlorocresol biodegrades in water and soil. Due to lack of diffusion to sediment, persistence in sediment is not likely to be critical. Information submitted regarding biodegradation and persistence is consistent with the data used in the Ecological Risk Classification of organic substances approach. Data considered in the approach can be found in the supporting document available from eccc.substances.eccc@canada.ca.

Conclusions

Summarized commentSummarized response
The draft screening assessment indicates that topical natural health products and pharmaceuticals indicated for short-term use have adequate safety data to minimize any uncertainties. By definition, this would mean that they do not meet criteria of section 64(c) of CEPA, although it is not stated explicitly in the report.The conclusion in the screening assessment applies to the substance as a whole, not individual uses of the substance. The proposed risk management for this substance will focus on cosmetics, as that is the source of the highest exposure/potential concern for Canadians.

Alternatives

Summarized commentSummarized response
The commenter suggests using natural alternatives in place of chlorocresol in formulations to reduce chlorocresol exposure from cosmetics and over-the-counter ointments. The commenter notes several natural alternatives. While alternatives were not considered within the screening assessment, the Government of Canada considers substitutes and alternatives whenever possible during the development of risk management approaches under the CMP. This includes consideration of adequate and relevant information on the economic, social, and environmental implications for Canada, when available. 

Risk management

Summarized commentSummarized response
Risk management actions on the use of chlorocresol in cosmetics and over-the-counter products should be considered.The proposed risk management activities focus on the source of the highest exposure/potential concern identified in the risk assessment, which is cosmetics containing chlorocresol (refer to Risk Management Approach).The Government of Canada is committed to consulting extensively with all affected stakeholders as part of the risk management process.
The Government of Canada should consider proposing a restriction on the use of chlorocresol to 0.1% in cosmetics in lieu of a prohibition.
The Government of Canada should consider allowing chlorocresol for short-term use in natural health and over-the-counter products.
Risk management action on chlorocresol should be limited to cosmetics as they meet criteria of section 64(c) of CEPA.
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