Summary of Risk Assessment Conducted Pursuant to subsection 83(1) of the Canadian Environmental Protection Act, 1999
Significant New Activity Notification: Benzene, (chloromethyl)- (Benzyl Chloride), Chemical Abstracts Service Registry Number 100-44-7
Health Canada & Environment and Climate Change Canada
Benzene, (chloromethyl)-, Chemical Abstracts Service Registry Number (CAS RN) 100-44-7 (benzyl chloride), was identified during the categorization of the Domestic Substances List as a high priority for assessment. It underwent a screening assessment in Batch 6 of the Challenge (Canada 2009a), which was followed by a proposed Risk Management Approach document on November 28, 2009 (Canada 2009b). In the screening assessment, it was concluded that benzyl chloride met the criteria of section 64(c) of the Canadian Environmental Protection Act, 1999 (CEPA), meaning that it is a substance which is entering or may enter the environment in a quantity or concentration or under conditions that constitute or may constitute a danger in Canada to human life or health (Canada 1999). It was added to Schedule 1 of CEPA on December 21, 2011 (Canada 2011).
The risk management objective identified in the proposed Risk Management Approach document was to prevent increases in exposure to the substance. The risk management actions proposed for benzyl chloride included:
- a provision to notify the federal government, for the purpose of assessment, of any potential changes to the use pattern of benzyl chloride, through the Significant New Activity provisions under CEPA (Canada 2013);
- the addition of benzyl chloride to Schedule 1 of the Environmental Emergency Regulations under CEPA; and,
- the addition of benzyl chloride to the Cosmetic Ingredient Hotlist as prohibited for use in cosmetic products.
The substance is a chemical that can be classified as an aromatic chlorinated organic.
Significant New Activity Notification
In November 2013, the Government of Canada received a Significant New Activity Notification (SNAN) for a new activity involving benzyl chloride. The notifier proposed to import up to 3 600 kg of benzyl chloride to be used to form an amine base, with the benzyl chloride completely consumed in the process. The amine base is then used in the formulation of an inhibitor which is used in foundries in hydrochloric acid cleaning baths to inhibit acid fumes. No release to municipal wastewater is expected as the benzyl chloride is completely consumed in the formulation process.
Environmental Fate and Behaviour
The environmental fate and behaviour of the substance was described in the original screening assessment report (Canada 2009a). The substance is volatile (vapour pressure of 163.9 Pa) and water soluble (525 mg/L). The Henrys Law Constant is 41.8 Pa m³/mol. The log Kow was reported to be 2.30 and the log Koc is 2.71.Therefore, though it is expected to be moderately adsorptive, the substance is considered to be mobile in the environment.In addition, the substance meets the persistence criterion for air but does not meet the persistence criteria for water, soil or sediment, and it does not meet the bioaccumulation criteria as set out in the Persistence and Bioaccumulation Regulations (Canada 2000).
Based on the available hazard information, the substance is expected to have high acute toxicity in fish (LC50 < 1 mg/L) and moderate acute toxicity to daphnia (1–20 mg/L). The predicted no effect concentration was calculated to range between 1 and 10 µg/L. However, given the low use volumes and negligible exposure pathways resulting from the notified activity, low exposure is expected.
Based on conservative environmental release estimates to the aquatic environment, the use of the substance as proposed in the notification does not pose a risk to the environment, and therefore is not likely to cause ecological harm in Canada.
Human Health Assessment
Based on the information provided in the SNAN, there is no anticipated exposure to the general population that would occur as a result of this notified use. Consequently, it has been concluded that the notified use of the substance is not likely to pose a significant risk to the general population, and is therefore not likely to be harmful to human health.
No information received in this notification puts into question the prior determination that the substance meets the criteria set out under section 64(c) of CEPA. However, when used as notified, use of the substance in the production of an amine base in which benzyl chloride is completely consumed is not likely to present a significant risk to human health or the environment.
Based on the information provided in the notification, and the risk assessment analysis, this activity does not result in an increase in exposure to the general public and does not pose an additional risk to human health. Additionally, the substance does not pose an ecological risk. Therefore, no additional risk management is recommended for benzyl chloride.
As no specific concerns have been identified for this activity, the government is considering amending the existing SNAc requirements in relation to benzyl chloride to target only the use(s) of the substance that may result in potential exposure(s) of concern. However, the current Order remains in force until an amended order is registered and published in the Canada Gazette, Part II.
Canada. 1999. Canadian Environmental Protection Act, 1999. S.C. 1999, c.33 Canada Gazette, Part III, vol. 22, no. 3.
Canada. 2000. Canadian Environmental Protection Act, 1999: Persistence and Bioaccumulation Regulations. P.C. 2000-348, 29 March, 2000, SOR/2000-107.
Canada. 2011. Order adding a toxic substance to schedule 1 to the Canadian Environmental Protection Act, 1999. SOR/2011-286. Canada Gazette, Part II, vol. 145, no. 26, December 21, 2011.
Canada. 2013. Order 2013-87-05-01 Amending the Domestic Substances List, Canadian Environmental Protection Act, 1999. SOR/2013-66. Canada Gazette, Part II, vol. 147, no. 10, May 8, 2013.
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