Identification of chemicals and polymers as risk assessment priorities

The Government of Canada recognizes that new tools and information continue to be generated that could help inform the identification of additional substances of potential concern for human health or the environment.  These substances may then be prioritized for assessment under the Canadian Environmental Protection Act, 1999 (CEPA). Therefore, a regular review of available information for the purposes of prioritization is undertaken by Environment and Climate Change Canada (ECCC) and Health Canada (HC). Results are used to inform the selection of assessment priorities proposed for CEPA’s Plan of Priorities. The Plan of Priorities sets out an approach describing planned activities for addressing substances in Canada over the next several years.

The overall approach for prioritization is outlined in the Approach for the identification of chemicals and polymers as risk assessment priorities under Part 5 of CEPA and an updated summary is provided in a fact sheet on identifying priorities for assessment under CEPA. This cyclical and flexible approach involves a systematic compilation and review of information from a large number of information sources that allows for the consideration of new data and methods as they become available. It enables the Government of Canada to communicate how emerging issues are tracked, and to identify and prioritize substances requiring further work. Stakeholders are consulted on initiatives that derive from the collection and analysis of data under this approach, including consultation on the Plan of Priorities.

For the purposes of selecting priorities for the Plan of Priorities, ECCC and HC primarily focus on identifying new information that would constitute indicators of hazard and/or exposure for the following types of substances:

• substances that are hazardous to human health or the environment, including carcinogens, mutagens, reproductive toxicants, as well as endocrine disrupting substances 
• substances that are impacting populations or environments that may be at increased risk due to either greater exposure or greater susceptibility  
• substances with the potential to contribute to cumulative risks  
• very hazardous substances that are capable of long-range transport (VH-LRT) 
• substances with known hazardous properties that are used in products available to consumers; and 
• potential substitutes for substances with known toxicity  

In addition, any person may request that the Ministers of Environment and of Health assess a substance under section 76(1) of CEPA to determine whether it is toxic or capable of becoming toxic. Once received, the Ministers evaluate the request to determine if there is sufficient evidence to add the substance to the Plan of Priorities. Instructions on how to submit a request, and a list of requests received with the rationale for accepting or denying the request, can be found on the Request to assess a substance under the Canadian Environmental Protection Act, 1999 web page.

Results of prioritization exercises

The results of previous prioritization exercises, as well as further scoping on each substance or group, were taken into consideration when identifying substances for the proposed Plan of Priorities.

• Results of the 2019 review
• Results of the 2017-18 review
• Results of the 2016 review
• Results of the 2015 review

Substances identified as priorities for assessment

The list of substances proposed to be prioritized for assessment and their rationales is available. The specific chemicals expected to be included in each of these assessments is also available. The list of chemicals will be updated periodically to reflect completed priorities and to add or remove chemicals as more information is collected  through the assessment process, which may impact the scope of the assessment.

Activities to inform assessment approaches and future prioritization

To support future prioritization of substances and assessment activities, additional scoping may be conducted on various substances or topics of potential concern. This may include the development of an approach or plan. The following activities and initiatives may be pursued in relation to assessing, controlling or otherwise managing risks to the environment or human health posed by substances (as per CEPA 73(1)b):

• botanical extracts
• nail salons
• pharmaceuticals in the environment

Botanical extracts

Botanical extracts are complex chemical mixtures and are present in a wide variety of products used by consumers (for example, massage oils, hair oil, breath freshener, room spray, fragrances, wound treatment). Plant-derived extracts have many components that can be extracted from different parts of a plant (for example, leaves, seed, stem, flower, root, fruits, woods, barks, grass, gum, tree blossoms, bulbs, flower buds). The amount of these main components can be affected by various factors, such as plant origin, species, temperature, soil, and geography. In addition, many of these extracts have different chemotypes (that is, different major chemical components produced from plants with the same genus and species). Therefore, the extracts from these plants may be chemically different even though their origin is the same. Additionally, many different extracts can contain the same components, which can lead to combined exposures or cumulative effects when multiple products are used. Certain components of these botanical extracts have shown adverse effects on human health, including endocrine activity and carcinogenicity. Also, there have been a number of poisonings reported in the literature involving various botanical extracts, including in Canada.  

Some botanical extracts have previously been assessed, such as the Acyclic, Monocyclic, and Bicyclic Monoterpenes Group, the Monocyclic and Bicyclic Sesquiterpenes Group, and methyl eugenol, some of which have been concluded to be posing a risk to human health under CEPA. However, given that so many extracts contain the same components, assessing them individually has not allowed for consideration of cumulative risks. 

Given the complexity of identifying the many components of these oils, along with their possible range of concentrations and human health effects, activities are proposed to identify data needs, to conduct information gathering, research, and monitoring, and to determine priorities for assessment or risk communication. 

Nail salons

Nail salons are predominately small businesses providing clients with nail services such as nail filing and polishing, artificial nail application, and other hand- and foot-care treatments. These treatments make use of a large assortment of products, such as glues, polishes, removers, and emollients, that are formulated for either professional or consumer use. These products can contain chemicals such as flame retardants, solvents and plasticizers. Due to the number of nail services being offered and the wide variety of products being used, there is the potential for combined or cumulative exposure to some of these chemicals. Many of the chemicals used in nail salon products are volatile and are associated with skin, eye, and respiratory tract irritation, as well as chronic effects including reproductive harm or cancer.  

Workers and people who frequent nail salons may be more vulnerable to experiencing adverse health effects from exposure to certain substances due to their potential for greater susceptibility or greater exposure. Most nail salon workers are women, racialized, and recent immigrants who may work long hours and not receive proper training for health and safety measures. Workplace conditions such as ventilation, availability of protective equipment, and products used may vary. Focus on nail salons provides an opportunity to develop methods and approaches to expand risk assessment under CEPA to incorporate certain workplace exposures to protect workers and support Federal, Provincial, and Territorial occupational health and safety regulators.

Given the breadth of products and chemicals involved in this workplace, activities are proposed to develop methods, conduct research and monitoring, and determine priorities for assessment or risk communication.

Pharmaceuticals in the environment

Pharmaceuticals contain ingredients that are designed to be biologically active in humans, livestock and companion animals, or farmed aquatic organisms (aquaculture). When pharmaceuticals are released into the environment, for example, during manufacture, use or disposal, even very small concentrations have the potential to affect organisms inhabiting the receiving environment. People may also be exposed to pharmaceuticals indirectly through contact with the environment, such as ingestion of drinking water. Some pharmaceuticals have endocrine disrupting properties. Some have common environmental exposure scenarios. For example, municipal wastewater may contain mixtures of pharmaceuticals from multiple sources, many of which are released on a continual basis but poorly removed during wastewater treatment, and therefore may have the potential to cause cumulative effects. 

Pharmaceutical substances are required to be notified and undergo a pre-market evaluation by Health Canada for efficacy and direct impacts to human health under the Food and Drugs Act (F&DA).  CEPA’s New Substances Notification Regulations provide the framework for the environmental assessment of new substances used in or intended for use in pharmaceuticals. For pharmaceutical substances that are already in commerce in Canada, several have already been assessed individually under CEPA for their potential risk to human health (that is, through indirect exposure of the general population from environmental media, such as drinking water or air) and the environment.  However, challenges have been acknowledged with assessing and managing pharmaceutical substances on an individual basis, especially from an ecological perspective.

Development of a whole-of-government approach that is flexible, adaptive, and innovative would help to proactively manage and prevent the risks posed by releases of pharmaceuticals to the environment, while simultaneously ensuring access to the benefits provided by those pharmaceuticals. This approach will be informed by assessments of pharmaceutical substances prioritized in the Plan of Priorities.