Reaction products of 2-propanone with diphenylamine (PREPOD): response to comments on proposed notice

Comments received and Environment and Climate Change Canada’s responses.  

Section 1 of the notice: Definitions

Comment: What is considered an industrial effluent?

Response: To add clarification, a definition for “industrial effluent” has been added to section 1 (definitions) of the notice.

Section 2 of the notice: Person or class of persons required to prepare and implement a plan

Comment: The Tire and Rubber Association of Canada (TRAC) and the U.S. Tire Manufacturers Association (USTMA) have indicated that their shared tire manufacturing members in Canada and the United States do not use PREPOD to manufacture tires or in their tire manufacturing facilities.

Response: No comment.

Background

The final screening assessment report for PREPOD, published in the Canada Gazette, Part I, on September 10, 2011, concluded that PREPOD is “toxic” as defined under the Canadian Environmental Protection Act, 1999 (CEPA). The substance was added to the List of Toxic Substances in Schedule 1 of CEPA on December 14, 2016.

A proposed pollution prevention (P2) planning notice in respect of PREPOD was published in the Canada Gazette, Part I, on July 14, 2018 for a 60-day comment period. Three comments were received from industry. Similar comments have been grouped and answered with a single response. All comments received were taken into consideration, and, where appropriate, reflected in the final P2 planning notice.

The final notice was published on June 15, 2019.

The Notice requires facilities to prepare and implement P2 plans including factors to consider in the risk management of nitrogen oxides (NOX), sulphur dioxide (SO2) and volatile organic compounds (VOCs).