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Proposed Risk Management Approach
Sulfuric Acid, Dimethyl Ester
Chemical Abstracts Service Registry Number (CAS RN)
Table of Contents
- Why we need action
- Current used and industrial sectors
- Presence in the canadian environment and exposure sources
- Overview of existing actions
- Proposed objectives
- Proposed risk management
- Consultation approach
- Next steps / Proposed timeline
1.1 Categorization and the Challenge to Industry and Other Iinterested Stakeholders
The Ministers have conducted a screening assessment under section 68 of the Canadian Environmental Protection Act, 1999 (CEPA 1999) (Canada 1999) to assess whether the following substance is "toxic" or capable of becoming "toxic" as meeting one or more of the criteria as set out in section 64 of the Act: Sulfuric Acid, Dimethyl Ester, Chemical Abstract Service Registry Number (CAS RN)1 77-78-1. This substance will be referred to throughout this document as "dimethyl sulfate".
This substance was identified in the categorization of the Domestic Substances List as a high priority for action under the Challenge. Dimethyl sulfate was identified as presenting an intermediate potential for exposure (IPE) to individuals in Canada and had been classified by other agencies on the basis of carcinogenicity and genotoxicity. Since dimethyl sulfate did not meet the criteria for persistence or bioaccumulation or inherent toxicity to aquatic organisms, the focus of this assessment relates to human health aspects.
The information-gathering authority in section 71 of CEPA 1999 is used to gather specific information where it is required. The information that is collected will be used to make informed decisions and appropriately manage any risks that may be associated with these substances.
1.2 Final Screening Assessment Report Conclusion for Diethyl Sulfate
A notice summarizing the scientific considerations of a final screening assessment report was published by Environment Canada and Health Canada in the Canada Gazette,Part I, for dimethyl sulfate on August 1, 2009 under paragraphs 68(b) and 68(c) of CEPA 1999. The final screening assessment report (Canada 2009a) concluded that dimethyl sulfate is entering or may be entering the environment in a quantity or a concentration or under conditions that constitute or may constitute a danger in Canada to human life or health.
Based principally on the weight of evidence assessments of international and other national agencies, the critical effect for the characterization of risks to human health for dimethyl sulfate is carcinogenicity. Increased incidence of tumours was observed in multiple species of experimental animals exposed via inhalation or subcutaneous injection. Tumours were also observed in pups of rats exposed to dimethyl sulfate during pregnancy. Dimethyl sulfate was also consistently genotoxic in a range of in vivo and in vitro assays and is a strong DNA alkylating agent. While the mode of induction of tumours by dimethyl sulfate has not been fully elucidated, it cannot be precluded that the tumours observed in experimental animals have resulted from direct interaction with genetic material.
On the basis of the carcinogenicity of dimethyl sulfate, for which there may be a probability of harm at any level of exposure, it is concluded that dimethyl sulfate is a substance that may be entering the environment in a quantity or concentration or under conditions that constitute or may constitute a danger in Canada to human life or health.
The final screening assessment report also concluded that dimethyl sulfate does not meet the criteria for persistence and does not meet the criteria for bioaccumulation, as defined by the Persistence and Bioaccumulation Regulations made under CEPA 1999. The presence of dimethyl sulfate in the environment results primarily from human activity.
For further information on the final screening assessment report conclusion for dimethyl sulfate, refer to the final screening assessment report, available at http://www.chemicalsubstanceschimiques.gc.ca/challenge-defi/batch-lot_4_e.html.
1.3 Proposed Measure
As a result of a screening assessment of a substance under section 68 of CEPA 1999, the substance may be found to meet one or more of the criteria under section 64 of CEPA 1999. In that case, either Minister can provide information and make recommendations respecting any matter in relation to the substance. The Ministers may propose to take no further action with respect to the substance, add the substance to the Priority Substances List (PSL) for further assessment, or recommend the addition of the substance to the List of Toxic Substances in Schedule 1 of the Act. In this case, the Ministers proposed to recommend the addition of Dimethyl sulfate to the List of Toxic Substances in Schedule 1. As a result, the Ministers will develop a regulation or instrument respecting preventive or control actions to protect the health of Canadians and the environment from the potential effects of exposure to this substance.
The final report did not conclude that dimethyl sulfate meets the Toxic Substances Management Policy (TSMP) provisions regarding virtual elimination. As a result, dimethyl sulfate will not be subject to the virtual elimination and will be managed using a lifecycle approach, to prevent or minimize its release into the environment.
2.1 Substance Information
Dimethyl sulfate is part of the chemical grouping discrete organics and the chemical subgrouping esters.
Table 1 presents other names, trade names, chemical groupings, the chemical formula, the chemical structure and the molecular mass for dimethyl sulfate.
|Chemical Abstracts Service Registry Number (CAS RN)||64-67-5|
|DSL Name||Sulfuric acid, diethyl ester|
|Inventory names 2||Sulfuric acid, dimethyl ester (TSCA, DSL, ENCS, AICS, SWISS, PICCS, ASIA-PAC, NZIoC)|
Dimethyl sulfate (ECL, TAIWAN)
Dimethyl sulphate (EINECS)
Sulfuric acid dimethyl ester (ECL)
METHYL SULFATE (PICCS)
SULFURIC ACID DIMETHYLESTER (PICCS)
|Other names||Dimethyl monosulfate|
NSC 56194, UN 1595, UN 1595 (DOT)
|Major chemical class or group||Sulfates|
|Major chemical sub-class||Esters|
|Simplified Molecular Input Line Entry System (SMILES)||O=S(=O)(OC)OC|
|Molecular mass||126.13 g/mol|
3. Why we need action
3.1 Characterization of Risk
Based principally on the weight of evidence assessments of several international agencies (IARC 1974, 1979, 1987, 1999; European Commission 2000; US EPA 1994; NTP 2005), a critical effect for characterization of risk to human health for dimethyl sulfate is carcinogenicity, for which a mode of induction involving direct interaction with genetic material cannot be precluded. Although there are limitations to many of the individual studies, collectively, the evidence is considered sufficient, as dimethyl sulfate is a strong alkylating agent that has induced tumours in multiple species of experimental animals, and consistently induced genotoxic effects in a range of in vivo and in vitro assays (Canada 2009a).
With respect to non-cancer effects, comparison of the critical non-neoplastic effect concentration in chronically exposed experimental animals (i.e., 2.6 mg/m3) with the upper-bounding estimate of general population exposure via inhalation (the expected principal route of exposure), based on modelled ambient air concentrations (i.e., approximately 1 ng/m3), results in a margin of exposure of about 2 600 000. This margin would only be an order of magnitude lower if this upper-bounding estimate of population exposure is compared to the concentration associated with genetic damage in short-term studies of experimental animals (i.e., 0.24 mg/m3). It is noteworthy, though, that this modelled estimate of exposure is based on the reporting limit for direct emissions of dimethyl sulfate to the environment and does not take into account potential formation of the substance in sulfur based emissions from coal- or oil-fired energy generating facilities. However, the potential contribution of this source to ambient concentrations is not quantifiable. Thus, in light of the conservative nature of the estimates of exposure in the ambient environment, and taking into consideration the rapid hydrolysis of dimethyl in the atmosphere, the margin of exposure for non-cancer effects for the general population is likely adequately protective to account for uncertainties in the database (Canada 2009a).
4. Current used and industrial sectors
According to data submitted in response to the section 71 notice under CEPA 1999, no companies in Canada reported manufacturing dimethyl sulfate in a quantity greater than or equal to the threshold of 100 kg for the 2006 calendar year. However, importation of approximately 1000 kg into Canada was reported for the same year (Environment Canada 2008).
According to data submitted under section 71 of CEPA 1999, dimethyl sulfate is used in Canada as a pharmaceutical intermediate. No Challenge questionnaire submissions or other voluntarily submitted data under the Challenge were received (Environment Canada 2008).
However, available scientific and technical literature indicate that dimethyl sulfate is mainly used in the chemical and pharmaceutical industry. Dimethyl sulfate is a powerful alkylating agent used in the preparation of a wide variety of substances and products, especially dyes, agricultural chemicals, drugs and other specialty products. Methylation of phenols to make ether serves as an intermediate in the manufacture of commercial products such as pesticide, dyes and fragrances. Methylation with amine to make quaternary ammonium salts is used as a surfactant, fabric softener and flocculant in water treatment such as sewage sludge control (McCormack 2000; Du Pont 2002; HSDB 2008). However, use of dimethyl sulfate as a reagent in the synthesis of quartenary ammonium salts to be used as surfactants in agricultural chemicals and fabric softeners is not identified in Canada. Also, no information was found on its use as a flocculant in wastewater treatment in Canada.
Other products such as photographic chemicals and flavours are also produced from alkylation reaction of dimethyl sulfate with nitrogen, oxygen or sulfur. Dimethyl sulfate may also be used as an agent for sulfonation, as a solvent, a stabilizer, or a catalyst for the production of other organic chemicals (Du Pont 2002).
This chemical is currently not used in cosmetics, but it is not officially prohibited or found on Health Canada's Cosmetic Ingredient Hotlist, (a list of restricted and prohibited substances in Canada) (Health Canada 2008a). In Canada, dimethyl sulfate is not registered as an active ingredient or formulant in pest control products (PMRA 2008). Dimethyl sulfate is not listed in the Drug Product Database, the Natural Health Products Ingredients Database nor the Licensed Natural Health Products Database; therefore, it is not used in Canada as a direct medicinal or non-medicinal ingredient in pharmaceuticals, natural health products or veterinary drugs. It has not been identified as being present in these products during initial screening exercises. However, as dimethyl sulfate is used in the manufacture of a chemical intermediate that is used in pharmaceuticals and possibly in natural health products or veterinary drugs, it is possible that dimethyl sulfate may be present in these products as an impurity. The Controlled Products Regulations established under the Hazardous Products Act requires that this substance be disclosed on the Material Safety Data Sheet that must accompany workplace chemicals when it is present at a concentration of 0.1% or greater as specified on the Ingredient Disclosure List (Health Canada 2008b). In Canada, dimethyl sufate is not approved as a food additive nor has it been used in food packaging materials or incidental additives used in food-processing plants.
5. Presence in the canadian environment and exposure sources
5.1 Releases to the Environment
Dimethyl sulfate is not manufactured in Canada and domestic supply is met by imports. Emissions of dimethyl sulfate into the environment may occur during its use as a methylating agent in the preparation of a wide variety of intermediates and end products. Production and processing of dimethyl sulfate normally occur in closed systems (EURAR 2002), and no monitoring data on emissions are available (Canada 2009a).
Fugitive emission or venting during the handling, transport or storage of dimethyl sulfate could also be a source of emission to the atmosphere. Direct release to the environment from the methylation process is possible; however, only a small fraction of dimethyl sulfate would likely be released to the environment from disposal as it is mainly used as a chemical intermediate in a closed system (EURAR 2002; Canada 2009a).
The burning of coal/fuel containing sulfur (such as at power plants) may also contribute to the formation of dimethyl sulfate (Japar 1990; EURAR 2002). Based on tests performed in the mid- 1980s, dimethyl sulfate had been detected in the particulate matter and the gas phase of plumes downwind of coal and oil-fired power plants, suggesting that this substance may be a product of atmospheric reaction of SO2 with organics in the aerosol (Hanson et al. 1985; Eatough et al. 1986). The chemistry regarding its formation and fate is still uncertain. However, any dimethyl sulfate in the atmosphere is likely to be washed out in rain and rapidly hydrolyzed. In addition, sulfur dioxide emissions in Canada have decreased by more than 45% since 1980, and fossil fuels currently used for energy generation have a much lower sulfur content (Environment Canada 2002a; Canada 2009a).
There has been no reportable release of dimethyl sulfate under the National Pollutant Release Inventory (NPRI) since 2001, with on-site releases to air of 4 and 13 kg reported in 2000 and 1999, respectively (NPRI 2008). In recent information gathered under the section 71 notice under CEPA 1999 for dimethyl sulfate, no companies reported having released this substance in 2006 (Environment Canada 2008; Canada 2009a).
5.2 Exposure Sources
In the environment, dimethyl sulfate results primarily from anthropogenic sources. This chemical may enter the environment during its production and industrial use as a methylating agent in the preparation of a wide variety of intermediates and end products (HSDB 2008). Waste products from industries may contain dimethyl sulfate; however, this chemical can decompose prior to disposal (IPCS 1985).
There were no measured concentrations of dimethyl sulfate in environmental media in Canada or elsewhere except for two ambient air studies in the United States from 1983. No recent data on concentrations of dimethyl sulfate from air in the vicinity of coal- and oil-fired plants have been identified and it is likely that levels in emissions from such plants would be lower than those reported previously. However, in view of the large differences in release volumes between the United States and Canada and the apparent decreasing trend in emissions over the years, as well as the likely decreases in the industrial emissions of sulfur-based potential precursor compounds, the United States data was not considered suitable as a basis for estimating current Canadian ambient air levels. In addition, despite the fact that there are no monitoring data for dimethyl sulfate in water or soil, concentrations in these media are likely to be negligible since the substance hydrolyzes very rapidly (Canada 2009a).
As no releases of dimethyl sulfate to the atmosphere were reported under the recent section 71 notice (Environment Canada 2008), conservative estimates of levels in air, water and soil were modeled. The predicted concentration of dimethyl sulfate in air is low, at approximately 1 ng/m3. Predicted concentrations in water and soil are negligible (much lower than 10-3 ng/L and 10-3 ng/g respectively) (ChemCAN 2003). Likewise the low log Kow value indicates that accumulation in the food chain is unlikely (Canada 2009a).
With respect to potential human exposure as a result of residual contaminants in formulated end products (e.g., perfumes, dyes and pharmaceuticals), no data on residuals were identified. Based upon the information provided under the recent section 71 notice issued in accordance with CEPA 1999, dimethyl sulfate is mainly used as an intermediate in a closed system and is not a component of consumer products; thus consumer exposure is expected to be negligible. The substance was also not included in the United States Household Products Database (HPD 2008; Canada 2009a).
Confidence in the relevant exposure database is considered to be very low to low, as it consists of modeled concentrations of dimethyl sulfate in air, water and soil. However, confidence is high that exposure of the general population to the substance is very limited, in light of the indication that it is not released to the general environment in Canada as well as its very reactive nature (Canada 2009a).
6. Overview of existing actions
6.1 Existing Canadian Risk Management
Dimethyl sulfate is subject to
- the Ingredient Disclosure List of the Controlled Products Regulations under the Hazardous Products Act, with a maximum concentration of 0.1% by weight. (Health Canada 2008b);
- the Export and Import of Hazardous Waste and Hazardous Recyclable Material Regulations. Dimethyl sulfate is on Part 2 of the hazardous recyclable material chemical list (Canada 2009b);
- reporting under theNational Pollutant Release Inventory(NPRI 2008); and
- the Regulations for the Prevention of Pollution from Ships and for Dangerous Chemicals established under the Canada Shipping Act (Canada 2001).
6.2 Existing International Risk Management
Dimethyl sulfate is subject to the U.S. Clean Air Act (US EPA 2008), under which it is listed as a hazardous air pollutant. It is also listed as a toxic substance under the California Safe Drinking Water and Toxic Enforcement Act (California EPA 2008). Various international jurisdictions have put in place occupational exposure limits and ambient air quality guidelines for dimethyl sulfate. Both the European Union (Commission of European Communities 2008) and New Zealand (Government of New Zealand 2006) prohibit its presence in cosmetics, and Sweden (Swedish Chemical Agency 2006) has classified it as a phase-out substance.
7.1 Alternative Chemicals or Substitutes
No information is available on alternative chemicals or substitutes.
7.2 Alternative Technologies and/or Techniques
No information is available on alternative technologies and/or techniques.
7.3 Socio-economic Considerations
Socio-economic factors have been considered in the selection process for a regulation and/or instrument respecting preventive or control actions, and in the development of the risk management objective(s). Socio-economic factors will also be considered in the development of regulations, instrument(s) and/or tool(s) as identified in the Cabinet Directive on Streamlining Regulation (Treasury Board of Canada Secretariat 2007) and the guidance provided in the Treasury Board document Assessing, Selecting, and Implementing Instruments for Government Action.
7.4 Children's Exposure
The Government of Canada considered, where available, risk assessment information relevant to children’s exposure to this substance. As part of the Challenge, the Government asked industry and interested stakeholders to submit any information on the substance that may be used to inform risk assessment, risk management and product stewardship. In particular, stakeholders were asked through a questionnaire if any of the products containing the substance were intended for use by children. Given the information received, it is proposed that no risk management actions to specifically protect children are required for this substance at this time.
8. Proposed objectives
8.1 Environmental or Human Health Objective
An environmental or human health objective is a quantitative or qualitative statement of what should be achieved to address environmental or human health concerns identified during a risk assessment. The proposed human health objective for dimethyl sulfate is to minimize, to the extent practicable, exposure to dimethyl sulfate, and hence risk to human health associated with this substance.
8.2 Risk Management Objective
A risk management objective is a target expected to be achieved for a given substance by the implementation of risk management regulations, instrument(s) and/or tool(s). The proposed risk management objective for dimethyl sulfate is to minimize exposure to this substance.
9. Proposed risk management
9.1 Proposed Risk Management Instrument
As required by the Government of Canada's Cabinet Directive on Streamlining Regulation3 and criteria identified in the Treasury Board document entitled Assessing, Selecting, and Implementing Instruments for Government Action, the proposed risk management instrument(s) were selected using a consistent approach, and took into consideration the information that was received through the Challenge and other information available at the time.
In order to achieve the risk management objective and to work towards achieving the environmental or human health objective(s), the risk management being considered for dimethyl sulfate is a requirement for notification of the federal government regarding any proposed future uses. In addition the government will add dimethyl sulfate to the Health Canada Cosmetic Ingredient Hotlist, which is an administrative tool to help cosmetic manufacturers satisfy the provisions of section 16 of the Food and Drugs Act. Compliance with the provisions of section 16 are monitored, in part, through the mandatory notification provisions of section 30 of the Cosmetic Regulations under the Food and Drugs Act. Section 30 requires that all manufacturers and importers provide a list of a cosmetic’s ingredients to Health Canada.
Furthermore, the Government has assessed dimethyl sulfate in the event that it were to enter the environment as a result of an environmental emergency and has concluded that the substance meets one of the criteria set out in section 200 of CEPA 1999. However, the Government is not proposing to add this substance to the Environmental Emergency Regulations at this time since quantities in Canada are below the threshold of 4500 kg set through the Risk Evaluation Framework for sections 199 and 200 of CEPA 1999 (Environment Canada 2002b).
9.2 Implementation Plan
The proposed regulation or instrument will be published in the Canada Gazette, Part I, no later than August 2011, as per the timelines legislated in CEPA 1999.
Releases of dimethyl sulfate will continue to be monitored under the National Pollutant Release Inventory.
10. Consultation approach
The risk management scope for dimethyl sulfate, which summarized the proposed risk management under consideration at that time, was published on January 24, 2009. Industry and other interested stakeholders were invited to submit comments on the risk management scope during a 60-day comment period. Comments received on the risk management scope document were taken into consideration in the development of this proposed risk management approach document.
Consultation for the risk management approach will involve publication on August 1, 2009, and a 60-day public comment period.
The primary stakeholders include
- manufacturers and users of chemical intermediates containing dimethyl sulfate; and
- Health Canada and Environment Canada.
11. Next steps / Proposed timeline
|Electronic consultation on proposed risk management approach||August 1 to September 30, 2009|
|Response to comments on the risk management approach||At time of publication of proposed instrument|
|Consultation on the draft instrument||Fall/Winter 2009-2010|
|Publication of the proposed instrument||No later than August 2011|
|Formal public comment period on the proposed instrument||No later than October 2011|
|Publication of the final instrument||No later than February 2013|
Industry and other interested stakeholders are invited to submit comments on the content of this proposed risk management approach or provide other information that would help to inform decision making. Please submit comments prior to September 30, 2009 since the risk management of dimethyl sulphate will be moving forward after this date. During the development of regulations, instrument(s) and/or tool(s), there will be opportunity for consultation. Comments and information submissions on the proposed risk management approach should be submitted to the address provided below:
Chemicals Management Division
Gatineau Quebec K1A 0H3
Tel: 1-888-228-0530 / 819-956-9313
Fax: 1-800-410-4314 / 819-953-4936
California EPA. 2008. Office of Environmental Health Hazard Assessment. Safe Drinking Water and Toxic Enforcement Act. Available from: http://www.oehha.ca.gov/prop65/prop65_list/files/p65single091208.pdf
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2 National Chemical Inventories (NCI). 2007: EINECS (European Inventory of Existing Chemical Substances); and TSCA (Toxic Substances Control Act Chemical Substance Inventory).
3 Section 4.4 of the Cabinet Directive on Streamlining Regulation states that "Departments and agencies are to: identify the appropriate instrument or mix of instruments, including regulatory and non-regulatory measures, and justify their application before submitting a regulatory proposal".
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