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APPENDIX 9 : Draft Framework for Alternate Thresholds (ATH) for NPRI

NPRI Consultation Meeting
October 5-6, 2004

Introduction

  • Importance of having the Framework
  • Development of the Framework - the work progress through previous years leading to the completion of current version

Framework Overview

  • Categorize candidate substances that would require ATHs
  • Identify the decision factors in determining the need for ATHs
  • Describe types of ATHs for candidate substances
  • Establish criteria in selecting acceptable ATH levels

Candidate Substances for ATH

  • Category 1:
    1. Substances that have been slated for virtual elimination under sub-section 65(3) of CEPA 1999, or under Track 1 of the Toxic Substances Management Policy (TSMP)
    2. Substances that are considered persistent and bio-accumulative (defined by two different B,P levels)
  • Category 2: Substances that have been determined to be toxic under CEPA, and where ATHs are required, to support the risk management action
  • Category 3: Other substances that merit consideration and are not adequately captured by the conventional 10-tonne MPO threshold

Decision Factors Used to Assess the Need for ATH

  1. Science-based justification
  2. Costs and benefits

Science-Based Justification Criteria

  • Credible reviews of chemical hazard or risk information by other jurisdictions (if international, must be relevant to Canadian situation)
  • Ensure tracking of small releases that might be of significance locally or regionally - it is expected these releases from sources would exceed the established ATH

Costs and Benefits Criteria

  • Qualitative analysis as opposed to a full-scale socio-economic analysis (i.e. quantitative cost-benefit analysis)
  • Costs:
    • Additional facilities would be impacted, resulting into increasing resource requirements on
      • NPRI,
      • Other EC programs, and
      • Reporters
    • Associated costs to promote the reporting capability
  • Benefits:
    • Provision of valuable information for users
    • Potential environmental and human health benefits derived from the improved info.

Types and Levels of ATH

  • MPO threshold
    • For a substance that is primarily commercial chemical, or contaminant in product or chemical
    • Need to examine the 1% concentration exemption
    • ATH can be 5, 50, 500, or 3,000 kg.
  • Release-based threshold,e.g.PAHs, CACs
  • Activity-based threshold, e.g. D/F, HCB

Principles of Selecting ATHs

  • Determine the appropriate capture rate of releases from facility-based sources for each ATH level, if the data are available
  • Minimize reporting burden provided that the ATH would meet data reporting needs
  • Work towards harmonization with domestic and international programs

Proposals for the ATH Selection

  • 5 kg or 50 kg for Category 1(b) substances
  • Chosen thresholds for Category 1(a) and Category 2 substances should support risk management activities
  • For CEPA Toxics, EC will be able to provide information required in order to apply for the Framework
  • For Category 3 - need to examine on a case-by-case basis

Next Steps

  • Finalize the ATH document by the end of the calendar year
  • Plan for next year the addition and/or modification of substances that would fall into Categories 1 and/or 2
  • ATH for Category 3 substances evaluated on a case-by-case basis, using the Framework

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