Industrial Chemical Intermediates and The Chemical Management Plan

0 Comments

On July 15, 2024, the Government of Canada registered Order 2024-87-23-01 under the Canadian Environmental Protection Act (CEPA), amending the Domestic Substances List (DSL) in response to concerns from the Minister of the Environment and the Minister of Health about the potential toxicity of three specific substances: oxirane, [(2-propenyloxy)methyl]- (CAS RN 106-92-3), “AGE”, oxirane, [(2-methylphenoxy)methyl]- (CAS RN 2210-79-9) “o-CGE”, and 1,3,5-triazine-2,4,6(1H,3H,5H)-trione, 1,3,5-tris(oxiranylmethyl)- (CAS RN 2451-62-9) “TGIC”.

AGE is primarily used in commercial applications as a resin intermediate and it may also be used as a stabilizer of other chemicals, resins and rubbers. The substance rapidly degrades in the environment. o-CGE can be used in a variety of do-it-yourself consumer applications (flooring adhesives, epoxy flooring coating products for garage floors, epoxy finishing resins for sealing/finishing surfaces [including hobby and craft paints or adhesives]) and epoxy compound for making moulds or decorative items. The predominant use of TGIC is as a cross-linking agent in the formulation of polyester resins used in the manufacture of polyester powder coatings. TGIC may be used as an adhesive and sealant substance, chemical filler or additive in the manufacture of paints and coatings, adhesives and sealants, or formed metal articles, including automotive parts.

Internationally, in the United States, AGE is reported to be used as an industrial chemical intermediate in adhesive and sealant manufacturing, synthetic rubber manufacturing, paint and coatings manufacturing and food packaging. TGIC is used as a component in food packaging materials in the United States. In the European Union (EU), AGE is used at industrial sites and in manufacturing.

This amendment is part of the Chemicals Management Plan (CMP), initiated by the Government of Canada in 2006, which aims to mitigate risks associated with exposure to hazardous substances through assessments and regulatory actions. The order removes the three identified substances from the DSL and places them into Part 2, where their use will trigger significant new activity (SNAc) notifications under specific conditions.

For instance, significant new activities for AGE require notification if it is manufactured or imported in consumer products or cosmetics at concentrations equal to or greater than 0.1% by weight, with exceptions for research and development substances intended solely for export. Similar notification requirements apply to o-CGE and TGIC when used in specific concentrations in consumer products and cosmetics. Companies proposing significant new activities must submit comprehensive information to the Minister, including a detailed description of the activity, expected annual quantities, data on potential adverse effects, and documentation of communications with other government agencies..

Canada (SOR/2024-161) July 31, 2024