Notice of objection - Minister's response
Robin M. Hunter
Goodyear Canada Inc.
450 Kipling Avenue
Toronto ON M8Z 5E1
Dear Robin Hunter:
I am responding to the notice of objection and request for a board of review addressed to my predecessor, the Honourable Peter Kent, that you filed on December 14, 2011, on behalf of Goodyear Canada Inc., regarding the proposed Order to add N,N’-mixed phenyl and tolyl derivatives of 1,4-benzenediamine (CAS RN. 68953-84-4; “BENPAT”) to the List of Toxic Substances in Schedule 1 of the Canadian Environmental Protection Act, 1999 (CEPA 1999) published in the Canada Gazette, Part I, on October 15, 2011.
As set out in section 333 of CEPA 1999, the mandate of a board of review would be to inquire into the nature and extent of the danger posed by BENPAT.
The basis for the conclusion of the assessment that BENPAT is entering or may enter the environment in a quantity or concentration or under conditions that have or may have an immediate or long-term harmful effect on the environment or its biological diversity is the very high persistence of BENPAT in environmental media, its high toxicity to aquatic organisms at low exposure concentrations and that, once released into the environment, BENPAT may be expected to be found in water at levels that may cause harm to organisms. As required under CEPA 1999, the Government applied precaution and weight of evidence in conducting its screening assessment of BENPAT.
I have fully and carefully considered your submission and request to establish a board of review. I am of the view that your Notice did not bring forth any new scientific data or information that would support a change in the conclusion of the assessment. I have therefore decided not to establish a board of review.
The Government of Canada is committed to consulting with all stakeholders, such as your company, and with the public on the development of risk management options. All issues raised in the context of these consultations will continue to be considered in an open and transparent manner.
I appreciate your bringing the concerns of Goodyear Canada Inc. to our attention, and look forward to working with you in the future on matters related to the environment or human health that are of interest to your company.
I appreciate having had this opportunity to respond to your concerns.
c.c.: The Honourable Rona Ambrose, P.C., M.P.
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