4. Existing Risk Management Actions

2,4,6-TTBP is an alkylphenol and such substances are required to be labelled as "Class 9 – Environmentally Hazardous Substances, Liquid, NOS (Not Otherwise Specified)" pursuant to the Transportation of Dangerous Goods Regulations.

Fuels that may contain 2,4,6-TTBP as an additive are managed through various existing regulations, codes of practice, guidelines, and best industry practices in place in Canada, such as:

• the Environmental Emergency Regulations (CEPA 1999), under which gasoline is listed;
• Onshore Pipeline Regulations, 1999 (National Energy Board);
• Storage tank requirements for fuel products (e.g. CCMEEnvironmental Code of Practice for Underground and Above Ground Storage Tank Systems, Ontario Fire Code, Ontario Liquid Fuels Regulation (O.Reg. 217/01), New Brunswick "Petroleum Product Handling and Storage Regulation", Alberta Fire Code)
• Transportation requirements for fuel products (e.g. Transportation of Dangerous Goods Act).

For a more comprehensive list of federal, provincial and territorial measures, please see Appendix A.

Japan is the only country to have banned the import, manufacture, sale and use of 2,4,6-TTBP. Other countries have included the substance on lists for assessment/evaluation purposes. For instance, 2,4,6-TTBP is included on the OECD's list of HPV chemicals (available in PDF Format, 1.1MB) and on the U.S. EPA's HPV Challenge Program. The U.S. EPA published a screening-level hazard characterization document on the Alkylphenols category (of which 2,4,6-TTBP is part of) in September 2009, but has not yet completed a risk-based decision document, which would assign a priority level for further work.