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Summary of Overarching Public Comments received on site-restricted Low Boiling Point Naphthas Draft Screening Assessment Report for the Petroleum Sector Stream Approach

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Overarching comments on the draft screening assessment report for Petroleum Sector Stream Approach (PSSA) site-restricted low boiling point naphthas (LBPNs) to be addressed as part of the Chemicals Management Plan were provided by Chemical Sensitivities Manitoba and Canadian Environmental Law Association, and the Canadian Petroleum Products Institute.

A summary of comments and responses is included below, organized by topic:

TopicSummarized/Rolled-up CommentSummarized/Rolled- up answer
Precautionary PrincipleThe Government is requested to use Section 71(1)c of the Canadian Environmental Protection Act, 1999 (CEPA 1999) to fill any data gaps for chemicals and apply the precautionary principle.

The screening assessment of the site-restricted LBPNs was based on available data. This assessment has been reviewed and clarified to more accurately reflect the information sources on which the decisions were based.

These substances are hazardous, however, environmental and general population exposure to these substances is not expected, and therefore harm to the environment or human health is not expected.

The precautionary principle should be used where valid data is lacking, such as bioaccumulation.

In conducting screening assessments, weight of evidence and precaution are applied, as required under CEPA 1999. Screening assessments consider multiple sources of available data, obtained through various methods, ranging from mandatory surveys to searches of publically available literature. In addition, a weight-of-evidence approach is applied to the evaluation of these data. This considers the relevance, strengths and uncertainties of the information obtained. While the precise chemical composition of the low boiling point naphthas (LBPNs) addressed in this assessment is uncertain, the Government of Canada has determined that these are all intermediate streams within refineries or upgraders, and as such do not leave industrial facilities. Additional materials, such as process flow diagrams, have been added to the assessment report to support this conclusion.

These substances are hazardous and new activities that were not identified in the assessment could lead to these substances meeting the criteria of section 64 of CEPA 1999. Therefore, the Government of Canada plans to implement the SNAc provisions under CEPA 1999 for these substances. This would require that any proposed new manufacture, import, or use outside of a petroleum refinery or upgrader facility be subject to further assessment, to determine if the new activity requires further risk management consideration.

Significant New Activity (SNAc) provisionThe use of the SNAc provision may not be adequate for substances found to have low exposure but high hazard potentials.The existing uses of these substances have not been identified as being a concern in the screening assessment process. A SNAc would require that any new manufacture, import, or use of these substances, outside of a petroleum refinery or upgrader, be subject to further assessment to determine if the new activity requires further risk management consideration.
The Government of Canada should consider other options for risk management beside the SNAc provisions, or other options within the SNAc provision.

The Government of Canada is considering the use of the SNAc provisions under CEPA 1999 because current uses of these substances are not proposed to meet section 64 criteria. The objective of a SNAc provision is to ensure that an assessment of a proposed new activity is conducted to determine if risk management measures are required.

The Government of Canada will consult with stakeholders during the development of measures to address new activities associated with these substances. Options for the design of a SNAc Notice will be considered.

Risk assessments should indicate how SNAc Notices apply to the export of substances.Potential future export activities involving the substance will be taken into account in the design of the SNAc and the notification requirement it contains.
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