At the technical workshop we raised severalpressing issues at the beginning - including the lack of significant risk control measures (regulations) in the Risk Management (RM)Approaches. Environment Canada (EC) officials proposed another meeting re RM in the future, and expressed the fact that Risk Assessment (RA) and RM are carried out as separate processes - which is good. We were snowed with information, ( 82 pages of PowerPoint slides - two per page) but both departments definitely tried their best to inform. We had a long discussion about the use of analogues in Batch 5 - I don't know if everyone was satisfied with the use of analogues, especially to remove substances from PBiT designations, but EC emphasized that they may use many analogues for a single substance for various endpoints.
We raised the issue of cumulative risk to the environment or human health. Mehran Allee, Manager CMP screening risk assessments(SRAs) for Health Canada (HC) noted he did not like the term, and that there would be no time for cumulative risk assessments under the timelines they have. I mentioned the National Research Council has this year released a report on how cumulative risk assessment should be used for phthalates. Again HC surprised us by saying that staff has been instructed not to consider new data in the assessments because of time limitations, and MA needs to review the raw data on new references. We are trying to clarify this point. Apparently the six week period for assessments is self-imposed and this may be resulting in too fast a process in some cases, however in our opinion important new peer-reviewed and published studies should be considered in the process.
We also raised the fact that occupational exposures are not included in the screening risk assessments. HC replied that setting standards for occupational exposures is primarily a provincial responsibility, and that they meet with provincial representatives. We suggested at least a paragraph in the SRAs providing some guidance on workers' exposures as the EU has done for the PBDEs.
HC reported that all 66 chemical substances that were categorized based on hazard to health have three types of toxicity (hazard)data, which they consider complete for their purposes. The fact that hazard data were available is probably how these chemicals got onto the highest priority list - "the less we know about a chemical, the safer it appears." The medium priority chemicals are lacking data, but these gaps might be addressed under the Inventory Update, which may assess classes of chemicals together. My feeling is that Health Canada should start with a Section 71 Notice now. There could be a slim chance of this (see reference to possible upcoming meeting ). Unlike other jurisdictions, a definition of "toxic" under CEPA 99 involves both toxicity and exposure potential - the primary focus of the CMP Challenge to date is to improve information on exposure only.
HC gave a detailed presentation on the exposure assessment and for D4 and D5 siloxanes, and how the exposures in the submitted analysis for D5 were lower than those originally determined and reported in the draft SAR. and for Vinyl Acetate which went through a peer scientific review and was accepted.
We proposed a transparent CMP policy paper on how chemical substances deemed toxic, or not toxic, under provisions of CEPA could be revisited if and when new data are available - there seemed to be some agreement with this.
Also I received a call from Minister Aglukkaq's office regarding the letter signed by several organizations on the lack of CMP policies to improve toxicity (hazard) data. I will be receiving a letter next week regarding a meeting to discuss this issue with Karen Lloyd and perhaps others at HC. Timely. Apparently we will not be meeting with the Minister.
