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.

Adding substances to Schedule 1

Five MDI substances have been proposed to be added to Schedule 1.

Applying Significant New Activity provisions

View the Comprehensive Listing of Substances that are Subject to a Significant New Activity Provisions.

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 Proposed 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
If needed, information gathering tools could be used to inform potential risk management actions.
June 17, 2017 Publication in the Canada Gazette of a proposed order adding 5 MDI substances to Schedule 1 and start of a 60-day public comment period.
June 10, 2017 Publication in the Canada Gazette of a notice of intent to amend the DSL to apply the SNAc provisions of the Canadian Environmental Protection Act, 1999 (CEPA 1999) to 2 MDA substances and start of a 60-day public comment period.
June 10, 2017 Publication in Canada Gazette of the final screening assessment decisions under subsection 77(6) of CEPA 1999, release of Government's Proposed Risk Management Approach Document for MDI substances and start of 60-day public comment period on the proposed risk management approach document.
August 16, 2014 Publication in Canada Gazette and start of 60-day public comment period on (a) the draft screening assessment and (b) the Risk Management Scope Document 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.

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 (PDF version – 1,789 K).

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. 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 document 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 document, 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 (PDF Version - 937 K).  A risk management scope document was also released in conjunction with this publication.

Background

Section 71 notice (mandatory survey)

In June 2012, a notice was issued in the Canada Gazette, Part I: Vol.146, No.24 - June 16, 2012 ( PDF Version - 3,671 K) 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. Every person to whom this notice applied was required to comply with the Notice no later than 5 p.m. EDT, October 16, 2012.

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. Information was however 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).

Submissions received for MDI/MDA Substance Grouping
Type of response Number of submissions
Mandatory section 71 notice 112
Requests for extension of the deadline for section 71 notice responses granted 40
Declaration of stakeholder interest 29
Voluntary data submissions (for example, studies, additional information) 33
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