Methylenediphenyl Diisocyanate and Diamine (MDI/MDA) Substance Grouping

Certain methylenediphenyl diisocyanate and diamine (MDI/MDA) substances are among those identified as priorities for action for the second phase of the Chemicals Management Plan (CMP). The selection of these MDI/MDA substances for action is based on the categorization process completed in 2006 and on new information received as part of the first phase of the CMP. Formaldehyde, polymer with benzenamine (CAS RN 25214-70-4) was not initially prioritized for screening assessment but was added to the MDI/MDA Substance Grouping because of its similarity to the other methylenediphenyl diamine (MDA) substance in the Grouping. The Government of Canada concluded that the 5 methylenediphenyl diisocyanate (MDI) substances may be considered harmful to human health because of possible exposure from the use of certain do-it-yourself low pressure two-component spray polyurethane foam products.

Proposed code of practice

In April 2019, a Proposed Code of Practice for Certain Methylenediphenyl Diisocyanates in Low-Pressure Two-Component Spray Polyurethane Foam Products was published in the Canada Gazette, Part I: Vol. 153, No. 14 – April 6, 2019 for a 60-day public comment period ending on June 5, 2019.

This proposed code of practice aims to reduce exposure of the general population to MDIs resulting from the use of low-pressure two-component spray polyurethane foam (SPF) products containing MDIs that are available to consumers by setting elements of best practices and recommendations for any person who manufactures, imports, or sells low-pressure, two component SPF products containing MDIs available to consumers in order to:

  • provide general information to users on safe use and handling
  • communicate general information concerning health and safety procedures, including appropriate personal protective equipment
  • facilitate access to training materials to help promote proper use
  • provide retailers with general information to help promote safe use and handling

The Government of Canada has worked collaboratively with stakeholders to leverage knowledge and expertise to develop the proposed code of practice as an effective and practical risk management tool.    

Adding substances to Schedule 1

Five MDI substances have been added to Schedule 1.

Applying Significant New Activity provisions

View the Significant New Activity Publications under the Canadian Environmental Protection Act, 1999.

The 2 MDA substances assessed may be addressed through the application of Significant New Activity (SNAc) provisions. A notice of intent has been published. For additional guidance on submitting information required as part of SNAc notifications, please see the Guidelines for the Notification and Testing of New Substances: Chemicals and Polymers.

Summary of publications

MDI/MDA substances
Group of substances CAS RN Chemical substance Final order and RIAS Public comment on the draft screening assessment Final screening assessment Proposed risk management approach SNAc application
MDI 101-68-8 Benzene, 1,1'-methylenebis[4-isocyanato- HTML HTML HTML HTML None
2536-05-2 Benzene, 1,1'-methylenebis[2-isocyanato-
5873-54-1 Benzene, 1-isocyanato-2-[(4-isocyanatophenyl)methyl]-
9016-87-9 Isocyanic acid, polymethylenepolyphenylene ester
26447-40-5 Benzene, 1,1'-methylenebis[isocyanato-
MDA 101-77-9 Benzenamine, 4,4'-methylenebis- None None HTML
25214-70-4 Formaldehyde, polymer with benzenamine
Timelines
Date Activity
May 15, 2019 Publication in Canada Gazette, Part II, of the final order adding five MDI substances to Schedule 1 of the Canadian Environmental Protection Act, 1999 (CEPA 1999).
April 6, 2019 Publication in Canada Gazette, Part I and start of 60-day public comment period on the Proposed Code of Practice for Certain Methylenediphenyl Diisocyanates in Low-Pressure Two-Component Spray Polyurethane Foam Products.
June 17, 2017 Publication in Canada Gazette, Part I, of a proposed order adding 5 MDI substances to Schedule 1 of CEPA 1999 and start of a 60-day public comment period.
June 10, 2017 Publication in Canada Gazette, Part I of a notice of intent to amend the DSL to apply the SNAc provisions of CEPA 1999 to 2 MDA substances and start of a 60-day public comment period.
June 10, 2017 Publication in Canada Gazette, Part I of the final screening assessment decisions under subsection 77(6) of CEPA 1999, release of Government's Proposed Risk Management Approach  for MDI Substances and start of 60-day public comment period on the proposed risk management approach.
August 16, 2014 Publication in Canada Gazette, Part I and start of 60-day public comment period on (a) the draft screening assessment and (b) the Risk Management Scope for MDI Substances.
December 17, 2012 Deadline for submission of any voluntary information by interested stakeholders.
October 16, 2012 Deadline for submission of information for the section 71 notice (without an extension).
June 16, 2012 Release of the section 71 notice with respect to certain MDI/MDA substances and the accompanying technical documents.
If needed, information gathering tools could be used to inform potential risk management actions.

Final screening assessment and risk management approach

In June 2017, the Final Screening Assessment for the MDI/MDA Substance Grouping was released and the related notice was published in the Canada Gazette, Part I: Vol. 151, No. 23 - June 10, 2017.

The final screening assessment concluded that the 5 MDI substances are harmful to human health as set out in section 64(c) of CEPA 1999 but are not harmful to the environment. It also concluded that the 2 MDA substances are not harmful to the environment or to human health. Therefore the Minister of the Environment and the Minister of Health proposed to add the 5 MDI substances to Schedule 1 of the act.

A proposed risk management approach for these 5 MDI substances was also released on this date for a 60-day public comment period. This document builds on the previously released risk management scope, and outlines, in more depth, the risk management actions for these substances, including the choice of risk management instruments.

In August 2014, the Draft Screening Assessment for the MDI/MDA Substance Grouping was released and the related notice was published in the Canada Gazette, Part I: Vol. 148, No. 33 - August 16, 2014. A risk management scope was also released in conjunction with this publication.

Information gathering

Mandatory survey - section 71 notice

In June 2012, a notice was issued in the Canada Gazette, Part I: Vol.146, No.24 - June 16, 2012 under section 71 of CEPA 1999. This notice applied to 8 substances; specifically, 7 substances that are part of the MDI/MDA Substance Grouping, and one substance (phenol, methyl-) that is part of the Internationally Classified Substance Grouping. The notice was issued in order to gather updated data on the manufacture, import and uses of these substances for the year 2011. It is important to note that formaldehyde, polymer with benzenamine (CAS RN 25214-70-4), included in the notice, was not initially identified in the MDI/MDA Substance Grouping. However, information was collected on this CAS RN as it was believed to be a commercially relevant mixture containing benzenamine, 4,4'-methylenebis- (CAS RN 101-77-9).

A compilation of the non-confidential data received on methylenediphenyl diisocyanate and diamine (MDI/MDA) and methylphenol substances in response to the section 71 notice, including information submitted on a voluntary basis, is available via the Government of Canada Open Data Portal. Along with the compilation, a non-confidential information summary provides general information on the volume of information received and the substances, activities, substance functions, commercial uses and sectors most often reported.

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