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Consultation Document for the Proposed Risk Management Measure for Tetrabutyltin


3 Existing Risk Management Activities for Tetrabutyltin

3.1 Canada

Ministerial Condition No. 13618 is in place for tetrabutyltin under paragraph 84(1)(a) of CEPA 1999. The Ministerial Condition imposes conditions restricting its use and prescribing handling and disposal procedures to control its release to the environment. At present, one company processing tetrabutyltin is subject to the conditions. As the Code of Practice will incorporate the requirements of the Ministerial Condition already in place and will now apply to all importers, distributers, manufacturers and users of tetrabutyltin in Canada, the Ministerial Condition would no longer be necessary and therefore Environment Canada will consider rescinding it once the Code of Practice is in place.

Although tetrabutyltin is not believed to be persistent in the environment, it is expected to degrade, producing tributyltins. As a precursor to persistent and bioaccumulative compounds that have the potential to cause environmental harm, tetrabutyltin is, in itself, considered to have potential to cause harm. Furthermore, commercial grades of tetrabutyltin may contain tributyltins as impurities. Therefore, the proposed Code of Practice for tetrabutyltin is intended to reduce potential environmental releases of tetrabutyltin along with any release of tributyltins present as an impurity or resulting from the degradation of tetrabutyltin.

It should be noted that Environment Canada is currently proposing a separate risk management action that would prohibit the manufacture, use, sale and offer for sale, and import of tributyltins. Stakeholders will have an opportunity to provide comments on the proposed regulatory proposal for tributyltins. To that effect, a separate consultation document is also available to stakeholders.

3.2 International

No risk management actions for tetrabutyltin have been proposed by other countries at this time.