Summary of public comments received on the screening assessment for seven hydrocarbon-based substances
Official title: Summary of public comments received on the screening assessment for seven hydrocarbon-based substances
Comments received from the public on the draft Screening Assessment for Seven Hydrocarbon-based Substances to be addressed as part of the Chemicals Management Plan (CMP) were provided by Canadian Consumer Specialty Products Association (CCSPA) and Canadian Network for Human Health and the Environment (CNHHE).
A summary of comments and responses is included below, organized by topic:
1. New information and data updates
| Summarized comment | Summarized response |
|---|---|
| The seven hydrocarbon-based substances assessed in this draft screening assessment do not appear as a group in the most recent list of substances in the third phase of CMP. It would be helpful to cross-reference these seven substances with the published groupings. | The Government of Canada aims to provide consistent information and messaging. However, substance groups and group names may be revised during the risk assessment process. The screening assessment was updated to clarify which substances have been included in this assessment. |
| It was difficult to evaluate the draft screening assessment because there was a lack of data for all seven hydrocarbon-based substances. While the screening assessment states that the substances are not entering the environment in quantities or concentrations or under conditions that have or may have an immediate or long‐term harmful effect on the environment, the comment “No information on the quantity of these petroleum refinery wastes generated in Canada was identified” was also used several times. | As there is a low level of exposure to these substances among human populations and the environment, there is considered to be sufficient data to assess the potential environmental and health risks for these substances. |
| Identify any collaborative or funded university research to find a use for slop oil. | The CEPA Risk Assessment Program at Health Canada and Environment and Climate Change Canada is not aware of any collaborative or funded university research on this subject. |
| Naphtha has a rapid volatilization rate. The greenhouse gas (GHG) concentration of this volatile organic compound (VOC) should be considered in Canada’s contribution to the global warming potential, as described in the United Nations’ Intergovernmental Panel on Climate Change (IPCC) fifth assessment report. | Noted. |
2. Sources and releases
| Summarized comment | Summarized response |
|---|---|
| The main concern with releases of sulphidic caustic is the extreme pH value (13-14). Consider avoiding releases to nearby water bodies by capturing all the sulphidic caustic on site. | Substances with extreme pH values, such as sulphidic caustic are harmful to aquatic life. As such, any release of these substances in wastewater must comply with regulations that specify the required pH range for treated water. |
| Consider the discharge of naphtha waste from wastewater treatment plants to water bodies rather than assume that all naphtha waste is reclaimed at the refinery. | The screening assessment considered releases of naphtha wastes to be minimal, because the refinery reclaims naphtha waste for re-processing. |
3. Ecological effects
| Summarized comment | Summarized response |
|---|---|
| The European Chemicals Agency (ECHA) has noted that montan-wax fatty acids ethylene esters may cause long-term harmful effects to aquatic life. Consider investigating this claim in a Canadian context. | Very little information on montan-wax fatty acids ethylene esters is available from the ECHA. This substance was subject to ECCC’s Ecological Risk Classification of Organic Substances approach. Based on information considered under this approach, this substance was found to have a low hazard and low exposure potential. The Government of Canada has mechanisms in place, such as the Identification of Risk Assessment Priorities, to monitor new information on substances. |
4. Risk characterization
| Summarized comment | Summarized response |
|---|---|
| Releases of substances should be quantified before stating that they are not entering the environment in a quantity that could cause harm. | Releases of these substances are limited and a quantitative approach was not required to characterize risk. This was confirmed through literature searches, communications with subject matter experts, and internal databases searches. |
| Montan wax is expected to be found in wastewater because it is used in products available to consumers, including cosmetics, automotive products, household cleaning products, and food packaging materials. The Government of Canada should measure montan wax levels in wastewater to verify this assumption. | Montan wax is not expected to be present in treated wastewater because it tends to be removed by bonding with other solids before it is released from wastewater treatment facilities. Furthermore, while results of the Environment and Climate Change Canada (ECCC) Ecological Risk Classification of Organic Substances (ERC) approach were not used in this assessment, the ERC also found that montan-wax has a low hazard and low exposure potential. |
5. Occupational exposures
| Summarized comment | Summarized response |
|---|---|
| The greatest hazard associated with these substances is their explosive potential. Consider quantifying their use in the workplace to better protect Canadian workers from this occupational health and safety hazard. | Explosive hazards associated with use of these substances in Canadian workplaces are addressed by occupational safety regulations. Screening assessments focus on exposure to the general population, rather than exposures and risks in workplaces. However, when available and relevant, hazard information from occupational settings is considered in the screening assessment. |
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