Summary of public comments received on the draft assessment for Alkanolamines and Fatty Alkanolamides Group.

Comments on the Draft Assessment for Alkanolamines and Fatty Alkanolamides Group, assessed under the Chemicals Management Plan (CMP), were submitted by Canadian Consumer Specialty Products Association, Canadian Vehicle Manufacturers’ Association, IBM Canada, and an individual.

Summarized public comments and responses are provided below, organized by topic:

General comments

Comment summary 1: Commenters stated that they appreciate the opportunity to submit comments on the draft screening assessment for the Alkanolamines and Fatty Alkanolamides Group.

Response 1: Noted.

Comment summary 2: Stakeholder agrees with conclusion of assessment.

Response 2: Noted.

Uses

Comment summary 3: Additional consumer, industrial and commercial use patterns and quantity information were provided for consideration.

Response 3: The additional information submitted was compared to existing information in the assessment, and it was taken into consideration in the finalization of the assessment.

As some of the use pattern and quantity information submitted relates to industrial or commercial uses, it should be noted that assessments conducted under the Canadian Environmental Protection Act, 1999 (CEPA) focus on risks of exposure of the general population, including disproportionately impacted populations. Hazards related to chemicals used in the workplace are defined within the Workplace Hazardous Materials Information System (WHMIS). The Government of Canada recognizes that it is the responsibility of the federal, provincial and territorial occupational health and safety organizations to coordinate legislation for the safe use of chemicals in the workplace. We are working to support this role by integrating the information, tools, and/or technical expertise of the CMP and Health Canada’s Workplace Hazardous Products Program. All substances assessed under the CMP are subject to future evaluation if new, significant information is received that indicates a need for further consideration.

Comment summary 4: Concerns were expressed by a stakeholder that the use of alkanolamines in carbon capture and sour gas treatment will result in increased use quantities.

Response 4: The assessment takes into consideration information from all available sources when selecting the concentration used in the estimation of exposure. Assessments do not include all possible exposure estimates; rather, exposure estimates are presented for sentinel scenarios that are considered representative and result in the highest exposure to the general population.

Should new information become available indicating increased exposure to the environment and/or human health, it would be considered in the Identification of Risk Assessment Priorities approach to determine if further action is needed.

Risk characterization

Comment summary 5: The stakeholder notes that the ecological risk characterization appears to have a high level of uncertainty due to the “professional judgement” that was used to characterize hazard and exposure for some substances.

Response 5: Precaution is applied in assessments conducted under CEPA, most notably in the use of protective approaches and assumptions when there is uncertainty. For more information, please refer to the Application of weight of evidence and precaution in risk assessment.

The ecological risk classification of organic substances (ERC) approach uses a weight-of-evidence approach based on multiple lines of evidence to help minimize the potential for both over- and under-classification of hazard and exposure, and of subsequent risk classifications.

For the four organic substances of Unknown or Variable Composition, Complex Reaction Products and Biological Materials (UVCBs) in this assessment, a conservative representative chemical structure was chosen to represent each of the UVCB substances to fill in some data gaps. However, a manual, judgment-based approach using read-across from close analogues was required to generate other data and for overall hazard and exposure conclusions. Wording in the assessment has been modified to clarify this. These low-hazard UVCBs were closely checked for risk classification consistency and were still subject to determination of the potential for over- and under-estimation of risk.

Comment summary 6: Further information and clarification regarding the ecological risk conclusions, environmental persistence and bioaccumulation should be provided.

Response 6: Based on the information considered under the ERC approach, the substances in the Alkanolamines and Fatty Alkanolamides Group were classified as having low ecological exposure potential and ultimately low potential for ecological risk. This characterization took some aspects of environmental fate into consideration (for example., chemical half-lives in various media and biota, partition coefficients, and fish bioconcentration data). The potential effects and how they may manifest in the environment were not further investigated due to the low risk of these substances. On the basis of current use patterns, these substances are unlikely to be resulting in concerns for the environment in Canada.

Data on the environmental persistence and bioaccumulation for the substances considered in the assessment can be found in the supporting document referenced in the assessment and titled Supporting documentation: data used to create substance-specific hazard and exposure profiles and assign risk available from substances@ec.gc.ca.

Risk management

Comment summary 7: Stakeholders remain available should further input be required in the development of follow-up activities.

Response 7: Consultation with stakeholders is an essential part of the chemicals management process. ECCC and HC intend to apply the Significant New Activity (SNAc) provisions of CEPA to ethanol, 2,2′-iminobis- (DEA), dodecanamide, N,N-bis(2-hydroxyethyl)- (LDE), amides, coco, N,N-bis(hydroxyethyl) (CDE) and ethanol, 2,2′,2″-nitrilotris- (TEA). The SNAc provisions would require that the Government be notified of certain proposed new activities related to the substances, and that the new activity be assessed before being undertaken. The SNAc Notice of Intent will be published in the Canada Gazette, Part I, for a 60-day public comment period where stakeholder feedback is encouraged.