Summary of Public Comments received on the Challenge substance for the 3 Monoazo Solvent Dyes; Solvent Red 1 (CAS 1229-55-6), Solvent Orange 7 (CAS 3118-97-6) and Solvent Red 3 (CAS 6535-42-8) Draft Screening Assessment Report for Batch 6


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Comments on the draft screening assessment report for the 3 Monoazo Solvent Dyes to be addressed as part of the Chemicals Management Plan Challenge were provided by Chemical Sensitivities Manitoba and Canadian Environmental Law Association.

A summary of comments and responses is included below, organized by topic:

  • Risk Assessment
Summary table
TopicCommentResponse
Risk AssessmentThere is an over reliance on a limited number of analogues in the assessments of bioaccumulation and inherent toxicity of 13 pigments and dyes in Batch 6.Due to the lack of experimental data for the subject chemicals in Batch 6, the available empirical data for analogues (including Disperse Orange 30 and Disperse Blue 79), were used for the assessment of 3 monoazo solvent dyes to fill the data gaps. Expert judgment has been applied when using analogue data for predicting the environmental fate and ecological effects of the subject chemicals.

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