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Canadian Environmental Law Association and Ecojustice Proposal to Add Ten Substances to the National Pollutant Release Inventory

Environment Canada's Response

April 2013-July 2015

Environment Canada has evaluated the proposal from the Canadian Environmental Law Association and Ecojustice to add ten substances to the National Pollutant Release Inventory (NPRI). Based on this evaluation, none of these ten substances meet all of the NPRI decision factors for addition. As such, Environment Canada is rejecting the nomination of these substances, and they will not be considered further for addition to the NPRI unless additional information is received in the future that suggests they meet the decision factors

A. Status Update and Environment Canada's Response (July 2015)

B. Status Update (October 2014)

C. Status Update (April 2014):

D. Consultation Plan (April 2013):

A. Status Update and Environment Canada's Response

Rejection of Glycidol and Phenolphthalein

Environment Canada has indicated that glycidol (CAS RN 556-52-5) and phenolphthalein (CAS RN 77-09-8) do not meet the decision factors for the addition of substances to the NPRI, since facilities do not contribute significant releases of these substances to the environment. No comments have been received on Environment Canada’s intention to reject the nomination of these substances. Therefore, these substances will not be considered further for addition to the NPRI, unless additional information is received in the future that suggests they meet the decision factors.

Rejection of Four Nitroarenes

Environment Canada has evaluated the following four nitroarenes against the NPRI decision factors:

  • 1,6-Dinitropyrene (CAS RN 42397-64 -8)
  • 1,8-Dinitropyrene (CAS RN 42397-65-9)
  • 6-Nitrochrysene (CAS RN 7496-02-8)
  • 4-Nitropyrene (CAS RN 57835-92-4)

Based on the evaluation, as described below, Environment Canada informed stakeholders and the proponent that it intends to reject nomination of these substances. No comments have been received on Environment Canada’s intention to reject the nomination of these substances. Therefore, these substances will not be considered further for addition to the NPRI, unless additional information is received in the future that suggests they meet the decision factors.

While the substances meet decision factor 1, they do not meet the decision factors 2 and 3, as summarized below. Additional considerations are also summarized below.

  1. Does the substance meet NPRI criteria:        

(a) Is the substance manufactured, processed or otherwise used in Canada?

Yes. These substances are incidentally manufactured during incomplete combustion processesFootnote2. However, these four nitroarenes are not on the Domestic Substances List which indicates that they are not manufactured in, imported into or used in Canada on a commercial scale.

(b) Is the substance of health and/or environmental concern?

Yes. Polycyclic aromatic hydrocarbons (PAHs) as a class were assessed to determine if they are “toxic”Footnote11, were determined to meet the criteria of section 64 of the Canadian Environmental Protection Act, 1999 (CEPA 1999), and were added to the List of Toxic SubstancesFootnote28. The class of substances that was assessed did not include any PAH derivativesFootnote29. The four nitroarenes that are proposed for addition to the NPRI are PAHs derivatives, which have not yet been assessed under section 64 of CEPA 1999. However, nitro-substituted PAH derivatives can be more toxic than their parent PAHs.

These four nitroarenes are reasonably anticipated to be human carcinogensFootnote2, which meets the health portion of this decision factor.

(c) Is the substance released to the Canadian environment?

Yes. These substances are incidentally manufactured and released during incomplete combustion processes. Nitroarenes are normally found in particulate emissions from a variety of combustion processes, most notably diesel exhausts.

(d) Is the substance present in the Canadian environment?

Yes. Once released into the atmosphere, many nitro-PAHs are highly persistent in the environment and can be transported long distances from their original source.

2.         Do facilities contribute significant releases of the substance?

No. The majority of nitroarenes are associated with particulate emissions in gasoline and diesel exhausts, which are mobile sources. Mobile sources are likely to far outweigh releases from facilities. For example, releases of the four nitroarenes from diesel and gasoline engines in Canada are estimated to be from about six to 140 times the estimated releases from coal-fired electric power generation. Footnote33

3.         Does inclusion of the substance support one or more of the objectives of the NPRI?

No. Since the NPRI is an inventory of point sources and not area or mobile sources, and since mobile sources are not required to be reported to the NPRI, including nitroarenes in the NPRI will not support the objectives of the NPRI.

Additional Considerations

The process for modifying the NPRI allows for additional considerations to be evaluated, specifically: “Efforts will be made to implement reasonable measures to reduce burdens (and costs) without compromising the integrity of the NPRI.” There are no published emission factors to estimate releases of these substances. Published emission factors are used as the basis of estimate for approximately 33% of NPRI PAH reports. Source testing is the most frequently used basis of estimate (39%) with the other bases making up the remaining 28% of reports.

The lack of representative emission factors presents issues for point source facilities in estimating emissions. Facilities and standard setting organizations, or governments, might need to develop and then apply standard stack tests for all PM emissions, and standard nitroarene extraction methods in the process of developing emission estimates. At this time, the costs of developing standardized source testing outweigh the benefits of gathering information on releases of these substances through the NPRI, particularly because the majority of nitroarene releases are expected to come from mobile sources.

B. Status Update (October 2014)

Environment Canada has evaluated glycidol and phenolphthalein against the NPRI decision factors, given recent information that has become available for these substances. Based on the evaluation, Environment Canada intends to proceed as indicated in the following table. The table also provides the rationale for the decision on how to proceed.

Status Update (October 2014)
SubstancePath ForwardRationale

Glycidol

CAS RN: 556-52-5

Number in proposal: #2

Synonym: oxiranemethanol

Rejection of the nomination
  • Glycidol is on the Domestic Substances List (DSL) and was therefore in commerce in Canada during 1984-1986. DSL Inventory Update 1 results indicate that this substance was manufactured in or imported into Canada in 2008 at a total of less than 1 000 kg/year. Footnote1, Footnote2However, based on the limited total quantity in commerce, facilities do not contribute significant releases of glycidol.
  • This substance is reasonably anticipated to be a human carcinogen Footnote2, and therefore is of health concern.
  • The Final Screening Assessment of Substances from Phase One of the Domestic Substances List Inventory Update concluded that glycidol requires further assessment due to human health considerations Footnote2. However, the timelines and approach for risk assessment activities for this substance have not yet been determined.
  • In conclusion, glycidol is manufactured, processed or otherwise used in Canada (although the small quantities involved would require a reduced threshold to require reporting) and is of health concern. However, since facilities do not contribute significant releases, the nomination of glycidol is rejected. Should this substance be assessed to be “toxic,”Footnote11 in the future, or additional information becomes available that suggests that industrial releases are significant, addition to the NPRI can be reconsidered at that time.

Phenolphthalein

CAS RN: 77-09-8

Number in proposal: #5

Synonym: Isobenzofuranone, 3,3-bis(4-hydroxyphenyl)-

Rejection of the nomination
  • Phenolphthalein is on the DSL and was therefore in commerce in Canada during 1984-1986. This substance was included in the CEPA 1999 section 71 notice for the DSL Inventory Update Phase 2 Footnote25. Data submitted in response to the notice indicate that phenolphthalein is not manufactured, processed or otherwise used at facilities in Canada. Given this new information, facilities are not expected to contribute significant releases of the substance.
  • This substance is reasonably anticipated to be a human carcinogen Footnote2,
  • In conclusion, phenolphthalein is not manufactured, processed or otherwise used at facilities in Canada, and, although it is of health concern, its nomination is rejected.

Nitroarenes

Analysis and consultations on the possible addition of the four nominated nitroarenes will continue and will take place in the context of an overall review of the NPRI reporting requirements for all polycyclic aromatic hydrocarbons, under the ongoing review of the NPRI substance list.

C. Status Update (April 2014)

 Glycidol

A decision on whether to add glycidol (CAS RN 556-52-5) to the list of NPRI substances was deferred pending additional information from two sources:

In June 2013, Environment Canada and Health Canada published the Rapid Screening of Substances from Phase One of the Domestic Substances List Inventory Update – Results of the Draft Screening Assessment.

The public comment period ended in August 2013 and a final screening assessment report will be prepared and is expected to be published in 2014. Since the conclusions of the draft report are subject to change based on new information or input received during consultations, it was decided to wait until the final assessment report before proceeding with consideration of the addition of this substance. When the final screening assessment report is published, Environment Canada will decide whether to reject the nomination of glycidol for addition to the NPRI or to refer the addition of glycidol to the stakeholder consultation process. Depending on the timing of publication of the final screening assessment report, this decision may be made in advance of the 2016 reporting year, or may need to be deferred further to 2018.

Phenolphthalein

A decision on whether to add phenolphthalein (CAS RN : 77-09-8) to the NPRI substances list was deferred pending the results from the Notice with respect to certain substances on the Domestic Substances List (Domestic Substances List Update, Phase 2). The deadline for submissions was September 4, 2013, with additional information being submitted until December 2013. Submissions are being processed by Environment Canada and results are expected to become available in 2014. Results for phenolphthalein will be used to determine if this substance meets the decision factors for consideration of changes to the NPRI, and whether to reject the nomination of phenolphthalein for addition to the NPRI or to refer the addition of phenolphthalein to the stakeholder consultation process. Depending on the timing for availability of the results, this decision may be made in advance of the 2016 reporting year, or may need to be deferred further to 2018.

Nitroarenes

Environment Canada has referred the nomination of the following four nitroarenes to the stakeholder consultation process:

  • 1,6-Dinitropyrene (CAS RN : 42397-64 -8)
  • 1,8-Dinitropyrene (CAS RN : 42397-65-9)
  • 6-Nitrochrysene (CAS RN : 7496-02-8)
  • 4-Nitropyrene (CAS RN : 57835-92-4)

Early engagement on the proposed addition of these substances to the NPRI was conducted with the NPRI Multi-Stakeholder Work Group in June 2013. Comments from the Work Group indicate that more information is needed in order for them to properly make recommendations on these substances, and that no new information is available since Work Group discussions on these substances for the 1999 reporting year. Since these substances are reported to the U.S. Toxics Release Inventory (TRI) as part of a group listing for polycyclic aromatic hydrocarbons, the TRI does not provide any substance-specific information on the quantities of these four substances released or disposed of in the U.S. If it was available, TRI information could be used to assess the value of adding them to the NPRI and the potential impacts of doing so.

Given current timelines and priorities for the upcoming NPRI Canada Gazette Notice for 2014 and 2015, and the lack of new information, these substances will therefore not be considered for addition for the 2014 reporting year. Consultations will continue on their possible addition starting with the 2016 reporting year and may take place in the context of an overall review of the NPRI reporting requirements for all polycyclic aromatic hydrocarbons under the ongoing review of the NPRI substance list.

Rejection of Four Substances

Environment Canada has indicated that the following four nominated substances do not meet the decision factors for addition of substances to the NPRI, since they are not in commerce in Canada:

  • 2,2-bis(Bromomethyl)-1,3-propanediol (CAS RN : 3296-90-0)
  • Methyl eugenol (CAS RN : 93-15-2)
  • Nitromethane (CAS RN : 75-52-5)
  • Tetrafluoroethylene (CAS RN : 116-14-3)

No comments have been received on Environment Canada’s intention to reject the nomination of these substances. Therefore, these substances will not be considered further for addition to the NPRI, unless additional information is received in the future that suggests they meet the decision factors.

D. Consultation Plan (April 2013)

Summary

The Canadian Environmental Law Association (CELA) and Ecojustice submitted a proposal to Environment Canada to add ten substances to the National Pollutant Release Inventory. Each of the substances was evaluated according to the established decision factors for consideration of changes to the NPRI. This document summarizes the evaluation and indicates how Environment Canada intends to proceed for each of the ten substances.

Based on the evaluation, Environment Canada intends to reject the nomination of four of the ten substances since they are not manufactured, processed or otherwise used in Canada and therefore do not meet the decision factors for consideration of changes to the NPRI.

Environment Canada intends to defer the decision on two of the substances until additional information becomes available, which is expected to occur during 2013-2014. Environment Canada will use this information to evaluate the substances according to the NPRI decision factors to decide how the Department intends to proceed.

For the remaining four substances, Environment Canada intends to refer the nominations to the NPRI Multi-Stakeholder Work Group for consultations. Consultations on these four substances will take place during 2013.

Changes to the NPRI based on this proposal may be implemented starting with the 2014 reporting year, or a later reporting year, depending on the input received during consultation and depending on the availability of new information.

Background

On April 20, 2012, Environment Canada received a proposal from the Canadian Environmental Law Association and EcojusticeFootnote1 to add ten substances to the National Pollutant Release Inventory commencing no later than the 2014 reporting year:

  1. 2,2-bis(Bromomethyl)-1,3-propanediol (CAS RN : 3296-90-0)
  2. Glycidol (CAS RN : 556-52-5)
  3. Methyl eugenol (CAS RN : 93-15-2)
  4. Nitromethane (CAS RN : 75-52-5)
  5. Phenolphthalein (CAS RN : 77-09-8)
  6. Tetrafluoroethylene (CAS RN : 116-14-3)
  7. 1,6-Dinitropyrene (CAS RN : 42397-64 -8)
  8. 1,8-Dinitropyrene (CAS RN : 42397-65-9)
  9. 6-Nitrochrysene (CAS RN : 7496-02-8)
  10. 4-Nitropyrene (CAS RN : 57835-92-4)

Six of the substances were proposed for addition to Part 1A of the NPRI Substance List (#1-6 above). NPRI Part 1A substances must be reported by facilities where (a) employees work a total of ≥ 20,000 hours (or activities to which the employee threshold does not apply take place); and (b) the total amount of the substance that is manufactured, processed or otherwise used (including incidentally) is ≥ 10 tonnes.

The proposal also calls for the addition of four nitroarenes (#7-10 above), which are nitro substituted derivatives of polycyclic aromatic hydrocarbons (PAHs), to Part 2 of the NPRI substance list. Part 2 substances must be reported by facilities where (a) employees work a total of ≥ 20,000 hours (or activities to which the employee threshold does not apply take place); and (b) the quantity of PAHs that are incidentally manufactured and released, disposed of or transferred for recycling, plus the quantity contained in tailings is ≥ 50 kilograms. Part 2 substances must also be reported for facilities where wood preservation using creosote takes place, regardless of quantities and regardless of the number of employees.

In summary, the rationale for adding these substances to the NPRI, as stated in the proposal, is:

  1. Each of these substances have been classified as “reasonably anticipated to be human carcinogens” by the U.S. National Toxicology Program (NTP) in their Report on Carcinogens Footnote2.
  2. All of these substances were added to the U.S. Toxics Release Inventory (TRI) Footnote3, which is the U.S. equivalent to the NPRI.
  3. Environment Canada has committed to participate in an Action Plan to Enhance Comparability of Pollutant Releases and Transfer Registers [PDF 2.45 MB], which encourages Canada, the U.S. and Mexico “to add chemicals that appear on the lists in the other countries, as appropriate, taking into account national circumstances Footnote4.”

Process for Modifying the National Pollutant Release Inventory

Proposals to make changes to the NPRI are evaluated according to an established process Footnote5 that requires the evaluation of the following five decision factors:

  1. Does the substance meet NPRI criteria:
    • (a) Is the substance manufactured, processed or otherwise used in Canada?Footnote6, Footnote7
    • (b) Is the substance of health and/or environmental concern?Footnote7
    • (c) Is the substance released to the Canadian environment?
    • (d) Is the substance present in the Canadian environment?
  2. Do facilities contribute significant releases of the substance?
  3. Does inclusion of the substance support one or more of the objectives of the NPRI?
    • (a) Identify priorities for action;
    • (b) Encourage voluntary action to reduce releases;
    • (c) Allow tracking of progress in reducing releases;
    • (d) Improve public understanding; and
    • (e) Support targeted regulatory initiatives.
  4. Is the substance reported elsewhere? If it is, is there additional value in reporting to the NPRI?
  5. Is the substance already in the NPRI in some form? If it is, is there additional value in including it in another form?

Next steps

Based on the evaluation of a proposal according to the decision factors, there are three possible options to proceed according to the established process for modifying the NPRI:

  1. Rejection of the nomination or recommendation;
  2. Referral of the nomination or recommendation to the stakeholder consultation process; or
  3. Deferral of a decision on how to proceed, pending additional information or resources.

Following receipt of the CELA/Ecojustice proposal, Environment Canada evaluated each of the ten substances against the NPRI decision factors. Based on the evaluation, Environment Canada intends to proceed as indicated in the following table. The table also provides the rationale for the decision on how to proceed.

Consultation Plan

For the four substances where Environment Canada intends to proceed by rejecting the nomination, no further analysis or consultation will be done, unless new information on the manufacture, process or other use of the substance in Canada is obtained.

For the two substances where Environment Canada intends to proceed by deferring a decision, the process for modifying the NPRI will be followed once the specified information becomes available (i.e., evaluation against the decision factors, followed by rejection or referral of the nomination to consultations, or a further deferral of a decision). Further evaluation of the addition of these substances may occur for the 2014 reporting year or a later reporting year, depending on when the required information becomes available.

Environment Canada intends to refer four nitroarenes to stakeholder consultations, in consideration for the possible addition of these substances to the NPRI starting with the 2014 reporting year. The consideration of this change will occur in accordance with the established process for modifying the NPRI Footnote5. Environment Canada will develop a proposed path forward and position on which formal consultation will occur. Consultations are expected to take place during 2013 using a paper-based approach with the NPRIMulti-Stakeholder Work Group and other stakeholders, including the public.

Consultation Plan
SubstancePath ForwardRationale

2,2-bis
(Bromomethyl)-1,3-propanediol
Chemical Abstracts Service Registry Number(CAS RN): 3296-90-0
Number in proposal: #1
Synonym: BBMP


and

Tetrafluoroethylene
CAS RN: 116-14-3
Number in proposal: #6
Synonym: Ethene, tetrafluoro-

Rejection of the nomination
  1. These substances are not in commerce in CanadaFootnote8,Footnote9,Footnote10 and therefore do not meet NPRI decision factors 1(a), 1(c) and 2.

  2. These substances are reasonably anticipated to be human carcinogens Footnote2, which meets the health portion of NPRI decision factor 1(b).

  3. Both decision factors 1(a) and 1(b) must be met for a substance to be added to the NPRI. Since 1(a) is not met for these substances, their nomination will be rejected.

  4. These substances were assessed to determine if they are “toxic,”Footnote11 but did not meet the criteria of section 64 of the Canadian Environmental Protection Act, 1999 Canadian Environmental Protection Act, 1999 (CEPA 1999)Footnote8.

  5. A Significant New Activity Notice (Significant New Activity (SNAc)) for these substances was published in 2011Footnote12, Footnote13. Should they re-enter commerce in Canada, Environment Canada will be notified, and addition to the NPRI can be reconsidered at that time.

Methyl eugenol
CAS RN : 93-15-2
Number in proposal: #3
Synonym: Benzene, 1,2-dimethhoxy-4-(2-propenyl)-
Rejection of the nomination
  1. This substance is not in commerce in CanadaFootnote14, Footnote15,Footnote16 and therefore do not meet NPRI decision factors 1(a), 1(c) and 2.

  2. This substance is reasonably anticipated to be a human carcinogen Footnote2, which meets the health portion of NPRI decision factor 1(b).

  3. Both decision factors 1(a) and 1(b) must be met for a substance to be added to the NPRI. Since 1(a) is not met for methyl eugenol, its nomination will be rejected.

  4. Methyl eugenol was determined to be “toxic”Footnote11according to the criteria of section 64 of CEPA 1999 on the basis that it may constitute a danger in Canada to human life or health due to its presence in personal care products, cosmetics and citronella oil personal insect repellentsFootnote14, Footnote17. It therefore meets the health concern portion of decision factor 1(b), but does not meet the environmental concern portion of 1(b).

  5. Health Canada will propose a phase out plan for personal insect repellents containing citronella oil, which contains methyl eugenolFootnote18.

  6. A SNAc for this substance was published in 2012 Footnote19,Footnote20. Should it re-enter commerce in Canada, Environment Canada will be notified and addition to the NPRI can be reconsidered at that time.
Nitromethane
CAS RN : 75-52-5
Number in proposal: #4
Synonym: Methane, nitro-
Rejection of
the nomination
  1. This substance is not in commerce in CanadaFootnote21Footnote22Footnote23 and therefore does not meet NPRI decision factors 1(a), 1(c) and 2.
  2. This substance is reasonably anticipated to be a human carcinogen Footnote2, which meets the health portion of NPRI decision factor 1(b).

  3. Both decision factors 1(a) and 1(b) must be met for a substance to be added to the NPRI. Since 1(a) is not met for nitromethane, its nomination will be rejected.

  4. Nitromethane was assessed to determine if it is “toxic”Footnote11, but did not meet the criteria of section 64 of CEPA 1999Footnote21.

  5. The screening assessment report indicated that nitromethane would be considered for inclusion in Phase 2 of the Domestic Substances List Inventory Update Inventory Update phase (DSLIU2), but a decision was made not to include this substance. Should information become available that nitromethane re-enters or will re-enter commerce in Canada, Environment Canada can reconsider the addition of this substance to the NPRI.

Glycidol
CAS RN : 556-52-5
Number in proposal: #2
Synonym: oxiranemethanol
Defer decision pending additional information (results from section 71 notice and results of risk assessment, which are expected to be available in 2013)
  1. Glycidol is on the DSL and was therefore in commerce in Canada during 1984-1986. However, there is no current information on whether or not this substance is still in commerce in Canada.

  2. This substance is reasonably anticipated to be a human carcinogen Footnote2, which meets the health portion of NPRI decision factor 1(b).

  3. A Canadian Environmental Protection Act, section 71 notice was issued to collect data regarding manufacturing, import and use of this substance from Canadian industryFootnote24. The data will be used to assess glycidol to determine whether it meets the criteria of section 64 of CEPA 1999. The assessment report is expected to be published in 2013.

  4. The section 71 data and risk assessment results are necessary in order to evaluate this substance against the NPRI decision factors and to determine if glycidol should be considered for addition to the NPRI.

Phenolphthalein
CAS RN : 77-09-8
Number in proposal: #5
Synonym: Isobenzofuranone, 3,3-bis(4-hydroxyphenyl)-
Defer decision pending additional information (results from the DSLIU2 section 71 notice, which will be collected by September 4, 2013)
  1. Phenolphthalein is on the DSL and was therefore in commerce in Canada during 1984-1986. However, there is no current information on whether or not this substance is still in commerce in Canada.

  2. This substance is reasonably anticipated to be a human carcinogen Footnote2, which meets the health portion of NPRI decision factor 1(b).

  3. This substance is included in the CEPA 1999 section 71 notice for the Domestic Substances List Inventory Update phase 2"(DSLIU2)Footnote25. Data on the manufacture and import of substances, including Phenolphthalein, is required to be reported to Environment Canada by September 4, 2013.

  4. The DSLIU2 data will indicate whether or not this substance is still in commerce in Canada and in what quantities, which will inform the evaluation of this substance against the NPRI decision factors to determine if phenolphthalein should be considered for addition to the NPRI.

Nitroarenes:

  • 1,6-Dinitropyrene
  • CAS RN : 42397-64-8
    Number in proposal: #7


  • 1,8-Dinitropyrene
  • CAS RN : 42397-65-9
    Number in proposal: #8


  • 6-Nitrochrysene
  • CAS RN : 7496-02-8
    Number in proposal: #9


  • 4-Nitropyrene
  • CAS RN : 57835-92-4
    Number in proposal: #10
Referral of the nomination to the stakeholder consultation process
  1. These four nitroarenes are not on the DSL and are therefore subject to the New Substances Notification Regulations(Chemicals and Polymers) reporting requirementsFootnote26Footnote27. Data is not available on the current manufacture or import of these substances. However, they are incidentally manufactured and released by incomplete combustion processes Footnote2, which meets decision factors 1(a) and (c).

  2. Polycyclic Aromatic Hydrocarbons (PAHs) as a class were assessed to determine if they are “toxic”Footnote11, were determined to meet the criteria of section 64 of CEPA 1999and were added to the List of Toxic SubstancesFootnote28. However, the class of substances that was assessed did not include any PAH derivativesFootnote29. The nitroarenes that are proposed for addition to the NPRI are PAHs derivatives, which have not yet been assessed under section 64 of CEPA 1999.

  3. These four nitroarenes are reasonably anticipated to be human carcinogens Footnote2, which meets the health portion of NPRI decision factor 1(b).

  4. 1,6-dinitropyrene and 1,8-dinitropyrene were originally considered for addition to the NPRI in 1999 but were dropped from consideration because of a lack of evidence supporting their additionFootnote30. Since that time, no further information regarding the manufacture and release of these substances has been obtained.

  5. There are 29 substances currently listed on Part 2 of NPRI, including 25 PAHs, three heterocyclic aromatic hydrocarbons (HACs)Footnote31 and one PAH derivativeFootnote32. NPRI reporting criteria for PAHs are based on the incidental manufacture of PAHs.

  6. Based on carcinogenicity, incidental manufacture, and release, these substances are expected to meet NPRI decision factors 1 and 2 and should therefore be referred to consultations.

Footnotes

Footnote 1

Proposal by the Canadian Environmental Law Association and Ecojustice to Add Ten Substances to the NPRI

Return to footnote 1

Footnote 2

U.S. Department of Health and Human Services (2011).

Return to footnote 2

Footnote 3

U.S. Environmental Protection Agency (2010). Addition of National Toxicology Program Carcinogens, Final Rule

Return to footnote 3

Footnote 4

Commission for Environmental Cooperation (2002). Action Plan to Enhance Comparability of Pollutant Releases and Transfer Registers [PDF 2.45MB]

Return to footnote 4

Footnote 5

Environment Canada (2011). Modifying the National Pollutant Release Inventory – A Guide to the Procedures to Follow When Submitting Proposals and a Description of the Stakeholder Consultation Process

Return to footnote 5

Footnote 6

This includes the incidental manufacture, process or other use of a substance as a by-product.

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Footnote 7

The first two criteria [1(a) and 1(b)] are intended to be absolute, i.e., in order to be added to the NPRI, a substance must be manufactured, processed or otherwise used in Canada, and be of health and/or environmental concern.

Return to footnote 7

Footnote 8

Environment Canada (2011). Screening Assessment for 53 Substances with High Hazard Potential on the Domestic Substances List

Return to footnote 8

Footnote 9

Environment Canada (2006). Notice with respect to certain inanimate substances (chemicals) on the Domestic Substances List. Listed as “1,3-Propanediol, 2,2-bis(bromomethyl)-” and “Ethene, tetrafluro-”.

Return to footnote 9

Footnote 10

The CEPA 1999 section 71 notice applied to any company that manufactured (including incidental manufacture) or imported a total quantity greater than 100 kgof these substances, whether alone, in a mixture, in a product or in a manufactured item during 2008. There were no reports of industrial activity (import or manufacture) with respect to these substances in Canada, above the reporting threshold of 100 kg, during 2008.

Return to footnote 10

Footnote 11

“Toxic” is defined in terms of risks that substances pose to the environment or to human health, and substances are assessed using the criteria from section 64 of CEPA 1999.

Return to footnote 11

Footnote 12

Environment Canada (2011). Environment Canada (2011). Notice of intent to amend the Domestic Substances List under subsection 87(3) of the Canadian Environmental Protection Act, 1999 to indicate that subsection 81(3) of this Act applies to 53 substances

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Footnote 13

The significant new activities notice requires that information be reported to Environment Canada for any proposed activity involving more than 100 kg of the substance in a calendar year.

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Footnote 14

Environment Canada and Health Canada (2010). Environment Canada and Health Canada (2010). Screening Assessment for the Challenge: Benzene, 1,2-dimethoxy-4-(2-propenyl)- (Methyl eugenol) Chemical Abstracts Service Registry Number 93-15-2

Return to footnote 14

Footnote 15

Environment Canada (2009). Environment Canada (2009). Notice with respect to Batch 9 Challenge substances. Listed as “Benzene, 1,2-dimethoxy-4-(2-propenyl)-”.

Return to footnote 15

Footnote 16

The CEPA 1999 section 71 notice applied to any company that manufactured (including incidental manufacture) or imported a total quantity greater than 100 kgof methyl eugenol; or any company that used a total quantity greater than 1,000 kg of methyl eugenol, whether alone, in a mixture, in a product or in a manufactured item during 2006. In response to the notice, methyl eugenol was not reported to be manufactured in Canada in 2006, and a total of less than 100 kgwas imported into Canada in 2006.

Return to footnote 16

Footnote 17

Environment Canada (2010). Order Adding Toxic Substances to Schedule 1 to the Canadian Environmental Protection Act, 1999

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Footnote 18

Environment Canada and Health Canada (2010). Proposed Risk Management Approach for Benzene, 1,2-dimethoxy-4-(2-propenyl)-(Methyl eugenol)

Return to footnote 18

Footnote 19

Environment Canada (2012). Notice of intent to amend the Domestic Substances List under subsection 87(3) of the Canadian Environmental Protection Act, 1999 to indicate that subsection 81(3) of that Act applies to four substances

Return to footnote 19

Footnote 20

The significant new activities notice requires that information be reported to Environment Canada for any proposed activity involving more than 100 kg of the substance in a calendar year.

Return to footnote 20

Footnote 21

Environment Canada and Health Canada (2010). Screening Assessment for the Challenge Methane, nitro- (Nitromethane) Chemical Abstracts Service Registry Number 75-52-5

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Footnote 22

Environment Canada (2009). Notice with respect to Batch 8 Challenge substances. Listed as “Methane, nitro-”.

Return to footnote 22

Footnote 23

The CEPA 1999 section 71 notice applied to any company that manufactured (including incidental manufacture) or imported a total quantity greater than 100 kgof nitromethane; or any company that used a total quantity greater than 1,000 kg of nitromethane, whether alone, in a mixture, in a product or in a manufactured item during 2006. In response to the notice, nitromethane was not reported to be manufactured at a quantity above the reporting threshold of 100 kg in 2006. Importation activities (whether alone, in a mixture, in a product or in manufactured items) were reported to be in the range of 100-1,000 kg in 2006.

Return to footnote 23

Footnote 24

Environment Canada (2009). Listed as “oxiranemethanol”.

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Footnote 25

Environment Canada (2012). Notice with respect to certain substances on the Domestic Substances List. Listed as “1(3H)-Isobenzofuranone, 3,3-bis(4-hydroxyphenyl)-”.

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Footnote 26

New Substances Notification Regulations (Chemicals and Polymers) (SOR/2005-247)

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Footnote 27

Any person who intends to import or manufacture a new substance (i.e., a substance that is not on the Domestic Substances List(DSL) in Canada in a quantity of 1,000 kg or more per calendar year must submit a notification to the New Substances Program prior to importing or manufacturing the substance. However, the New Substances Notification Regulations requirements do not apply to the incidental manufacture of substances as by-products of the combustion of fossil fuels.

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Footnote 28

Environment Canada and Health Canada (1994). Priority Substances List Assessment Report: Polycyclic Aromatic Hydrocarbons [PDF 297 KB]

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Footnote 29

Polycyclic Aromatic Hydrocarbons(PAH) derivatives are PAHs where an alkyl or other radical is introduced to the ring.

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Footnote 30

Environment Canada (1999). Third Report of the National Pollutant Release Inventory Ad Hoc Work Group on Substances

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Footnote 31

Return to footnote31 Heterocyclic aromatic hydrocarbons Heterocyclic Aromatic Hydrocarbons(HAC) are PAHs where any one carbon atom in a ring is replaced by a nitrogen, oxygen, or sulphur atom. The three HACs currently listed on the NPRI are dibenz(a,h)acridine, dibenz(a,j)acridine and 7H-dibenzo(c,g)carbazole.

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Footnote 32

1-nitropyrene.

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Footnote 33

Cheminfo Services Inc. (2014). Potential for Emissions of Selected Nitroarenes in Canada. Final Report.

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