Summary of public comments received on the draft screening assessment and risk management scope for the Alkyl Halides Group
Comments on the draft Screening Assessment and Risk Management Scope for the Alkyl Halides Group, assessed under the Chemicals Management Plan (CMP), were submitted by the Canadian Consumer Specialty Products Association and another stakeholder.
Summarized public comments and responses are provided below, organized by topic:
Conclusion
Comment summary 1: Stakeholders support the conclusions of the assessment.
Response 1: Noted.
Comment summary 2: Suggests that additional data could strengthen the conclusion for 1-bromopropane.
Response 2: The conclusion was based on the best available exposure and hazard data including data from secondary sources. A literature search update was conducted; however, no important studies were found. The level of detail provided, availability of data, and transparency of the source/author of the data help determine which data to include.
Comment summary 3: Suggests including more information on the carcinogenicity, reproductive and genotoxic effects of trans-1,2-dichloroethene. Also questions whether trans-1,2-dichloroethene should be concluded to be toxic (criteria in section 64 of the Canadian Environmental Protections Act, 1999 [CEPA]).
Response 3: Assessments are based on the best available data. All substances assessed under the CMP are subject to future evaluation if new, significant information is received that indicates a need for further consideration. A literature search update was also conducted; however, no important studies were found. Trans-1,2-dichloroethene was not concluded to be toxic based on comparison of health effects with estimates of exposure to products (Margin of Exposure).
Related link: Margin of Exposure
Related link: CEPA, section 64
Comment summary 4: Stakeholders suggest that research on potential substitutes for both 1-bromopropane and trans-1,2-dichloroethene would be beneficial.
Response 4: A systematic evaluation of the hazard of alternatives was not carried out. Alternatives to 1-bromopropane were outlined in the Risk Management Scope document.
Related link: Risk Management Scope
Comment summary 5: Occupational exposure to 1-bromopropane and trans-1,2-dichloroethene may cause long-term health effects.
Response 5: Assessments conducted under CEPA focus on risks of exposure of the general population, including disproportionately impacted populations. Hazards related to chemicals used in the workplace are defined within the Workplace Hazardous Materials Information System (WHMIS). The Government of Canada recognizes that it is the responsibility of the federal, provincial and territorial occupational health and safety organizations to coordinate legislation for the safe use of chemicals in the workplace. We are working to support this role by integrating the information, tools, and/or technical expertise of the CMP and Health Canada’s Workplace Hazardous Products Program. All substances assessed under the CMP are subject to future evaluation if new, significant information is received that indicates a need for further consideration.
Vulnerable populations
Comment summary 6: More data is needed to assess the effects of 1-bromopropane and trans-1, 2-dichloroethene on vulnerable populations.
Response 6: The human health assessment took into consideration groups of individuals within the Canadian population who, due to greater susceptibility or greater exposure, may be more vulnerable to experiencing adverse health effects.
Certain subpopulations are routinely considered throughout the risk assessment process, such as infants, children, and people of reproductive age. For instance, age-specific exposures are routinely estimated, and developmental and reproductive toxicity studies are evaluated for potential adverse health effects.