9/22/2011 8:58 AM
DATE: September 6, 2011
TO: Chlorinated Paraffin (CP) Customers
FROM: Dover Chemical Corporation
RE: Update on Canadian Chlorinated Paraffin (CP) Regulatory Activities
This past weekend, Health Canada (HC) released an updated human health assessment for long-chain chlorinated alkanes (also known as long-chain chlorinated paraffins – LCCPs). The updated health assessment concluded that LCCPs (C18-C38) are not CEPA toxic to human health. Specifically HC states in the assessment:
“Upper-bounding estimates of daily intakes of LCCPs by the general population of Canada are well below the established TDI, and therefore, it is proposed that LCCPs are not harmful to human health as defined in paragraph 64(c) of CEPA 1999.”
The complete updated health assessment is available at: http://www.chemicalsubstanceschimiques.gc.ca/challenge-defi/chlor-alkanes-eng.php#dra
Based on this update health assessment for LCCPs, Environment Canada (EC) and HC issued a notice in the Canada Gazette indicating that no further action will be taken on chlorinated alkanes >C20:
“Notice therefore is hereby given that the Ministers of the Environment and of Health propose to take no further action on chlorinated alkanes with the molecular formula CnHxCl(2n+2-x) in which 21 ≤ n ≤ 38 at this time.”
The full Canada Gazette noted can be read at: http://www.gazette.gc.ca/rp-pr/p1/2011/2011-09-03/html/notice-avis-eng.html#d105.
The reason for the slight difference in carbon-number range from the Health Canada assessment, which is C18-C38, and the Canada Gazette notice which is C21-C38, is due to the fact that Environment Canada is still apparently considering the regulation of chlorinated alkanes (paraffins) up to, and including, C20 as CEPA toxic to the environment. Dover Chemical in conjunction with the CP trade association – International Chlorinated Paraffins Industry Association (ICPIA) – is working to clarify and resolve any potential issues related this difference in order to ensure that all of Dover’s LCCP commercial products will not be subject to any further regulation in Canada.
ICPIA will be hosting a webinar on September 22, 20011 to review this most recent action on LCCP and other CP activities in Canada. A separate notice with the details of that webinar will be sent by ICPIA shortly. If you would like to be included in this webinar, please let Andrew Jaques of ICPIA know at email@example.com or 202-419-1500
Dover Chemical is also continuing to work closely with the regulators in Canada on the possible risk management regulation of medium-chain CPs (MCCPs). We anticipate that Environment Canada will be putting forward a proposed risk management rule on MCCPs in the near future and we will continue to seek assurances that this regulation will allow for the continued responsible use of MCCP by Canadian industry.
If you have questions or concerns, please contact Thomas Kelley of Dover Chemical Corporation at 330-365-3674 or firstname.lastname@example.org or Andrew Jaques of ICPIA at (202) 419-1504 or email@example.com.
Thomas Kelley – Global Business Director, Chlorinated Paraffins