Consultation Document: Proposed Risk Management for 2,4,6-TTBP under the Chemicals Management Plan

4. Existing Risk Management Actions

4.1 Canada (federal, provinces and territories)

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.

4.2 International

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 HPVchemicals (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.