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

Comments on the Draft Screening Assessment (dSAR) and Risk Management Scope for Triarylmethanes, assessed under the Chemicals Management Plan (CMP), were submitted by BASF, Canadian Consumer Specialty Products Association (CCSPA), Color Pigments Manufacturers Association, Inc (CPMA), Forest Products Association of Canada (FPAC) and National Council for Air and Stream Improvement, Inc (NCASI).

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

Overarching

Summarized commentSummarized response
Additional information, if pertinent could be provided.Noted.
Data previously submitted for MAPBAP acetate can be used for Basic Violet 4.Information submitted on MAPBAP acetate was considered. No changes were made to the screening assessment.
Information supplied under a voluntary submission of usage and exposure information was considered in the risk assessment.Noted.
The proposed conclusion for C.I. Pigment Blue 61 was supported based on the information in the assessment.Noted.

Methodology

Summarized commentSummarized response
Additional details are needed on the probabilistic approaches for each ecological exposure scenario presented.  Further information on the retention rates used would help to better understand the risk assessment conclusion.
Additional information submitted was considered and the screening assessment was revised to provide more detail on the input parameters used in the exposure scenarios.

Risk management

Summarized commentSummarized response
Information sharing along the supply chain is necessary so users of chemical substances may be informed when a substance is declared toxic. At least one facility suspects they have been using a certain triarylmethane dye, but as the formulations are trade secrets, its identity is unknown.

It is recognised that supply chain transparency can pose a challenge in many sectors, including the pulp and paper sector.

When appropriate, the Government of Canada intends to apply the steps outlined in the Approach to disclose confidential information and promote transparency in chemicals management to release certain information publicly, taking into account the requirements of CEPA. This could occur in situations where it is in the interest of public health, public safety or the protection of the environment.

We also encourage users of products and chemicals to pursue disclosure requirements through their procurement processes with their suppliers. 
The risk management tool should target only the manufacturers and importers of these substances and not the users.The full life cycle of the substances will be considered in the development of risk management options.

New information and data

Summarized commentSummarized response
Information was provided on the number of pulp and paper facilities using certain dyes and the proportions of triarylmethanes in dye mixtures, to inform data gaps and proposed risk management actions.Additional information submitted was considered and the screening assessment was revised. This information will be taken into consideration in the development of any risk management actions.
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