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Notice of Objection to the Proposed Addition of Hexachlorobutadiene to the Virtual Elimination List
Minister's Response to Concerns Raised by Halogenated Solvents Industry Alliance, Inc.
Mr. Stephen Risotto
Halogenated Solvents Industry Alliance, Inc.
1300 Wilson Boulevard, 12th floor
Arlington VA 22209
Dear Mr. Risotto:
As the Minister responsible for the administration of the Canadian Environmental Protection Act, 1999, I am responding to your request for the establishment of a Board of Review, which was contained in your October 14, 2003 letter to Mr. James Riordan of my department, and in which you expressed your opposition to the proposed addition of hexachlorobutadiene (HCBD) to the Virtual Elimination List under the Act.
I have fully and carefully considered your Notice of Objection. The information that you present with respect to declining levels of HCBD does not alter our conclusion that HCBD is persistent and bioaccumulative in accordance with Canadian regulations, that the presence of HCBD in the environment results primarily from human activities, and that HCBD is not a naturally occurring radionuclide or a naturally occurring inorganic substance.
I note that, in your letter, you understood Environment Canada officials to suggest that an updated assessment of HCBD might conclude that the substance no longer meets the criteria for designation as toxic under paragraph 64(a) of CEPA 1999. I assure you that I remain confident that the conclusion of toxicity and the science on which it was based are sound.
As your letter does not provide any additional information with respect to the nature and extent of the danger posed by HCBD, I am not satisfied that the establishment of a Board of Review is warranted, and I therefore deny your request.
With respect to the specific concerns raised in your letter, a document summarizing and responding to all comments received during the 60-day comment period will be posted in early spring on the "CEPA Environmental Registry" Web site. You will be contacted directly when the document is available.
I look forward to continued dialogue between industry and Environment Canada, as we work to address concerns related to HCBD and other toxic substances.
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