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Pollution Prevention Planning Consultations

Toluene Diisocyanates

Update on the development of the Proposed Pollution Prevention Planning Notice

The Working Document for the P2 Planning Notice for the Urethane and Miscellaneous Foam Sector (excluding Polystyrene) was drafted, and an email consultation with urethane and miscellaneous foam sector (excluding polystyrene) companies occurred from November 12, 2009, to December 23, 2009 (30 working days).

A multi-stakeholder workshop was held on March 22, 2010, to review the proposed approach. Comments received on the working document and on the draft proposed P2 Planning Notice were considered in the development of the Proposed P2 Planning Notice that was published in Canada Gazette, Part I on July 3, 2010, for a 60-day public comment period.

Summary of Working Document for Toluene Diisocyanates

On July 5, 2008, the Ministers of Environment and Health published their final assessment report on toluene diisocyanates (TDIs) [2,6-Toluene Diisocyanate (CAS RN 91-08-7); 2,4-Toluene Diisocyanate (CAS RN 584-84-9); and the Mixture of 2,6-Toluene Diisocyanate and 2,4-Toluene Diisocyanate (CAS RN 26471-62-5)], under subsection 77(6) of the Canadian Environmental Protection Act, 1999 (CEPA 1999), in Part I of the Canada Gazette.

This assessment report indicated that TDIs are considered “toxic” as defined in paragraph 64(c) of CEPA 1999, and recommended they be added to the List of Toxic Substances under CEPA 1999.

In Canada, more than 85% of TDIs are used in the manufacture of flexible polyurethane foam, with final products in household furniture and automotive upholstery, mattresses, pillows, packaging and carpet underlay. TDIs or TDI derivatives are also used in the manufacture of semi-flexible and semi-rigid polyurethane foam (used in automotive panels, padding and bumpers); polyurethane-modified alkyd paints and coatings, including automotive and marine paint, wood varnish, floor treatment, wire and powder coating; and in sealants, adhesives and elastomers. Polyurethane cast elastomers based on TDIs may be used in wheels, rollers and conveyors. TDIs are also used in the production of coatings for textiles (for durability and waterproofing) and paper production.

A Risk Management Approach (RMA) outlining the risk management initiatives considered by the Government of Canada to control TDI releases and exposure to Canadians was also published on July 5, 2008 on the Chemical Substances website.

The risk management objective proposed in the RMA is to achieve the lowest level of TDI releases to the environment that is technically and economically feasible. To achieve this objective, the risk management instrument initially considered was a regulation or guidelines prescribing maximum TDI concentrations at air stack exhaust sources to control and reduce TDI industrial releases to the environment from the foam industry.

Based on further information gathered, a sector-based Pollution Prevention (P2) Planning Notice is considered to be the most appropriate risk management instrument for TDIs. Environment Canada is now developing a sector-based P2 Planning Notice under Part 4 of CEPA 1999. It will require the Urethane and Miscellaneous Foam Sector (excluding Polystyrene) to prepare and then implement P2 plans for TDIs.

This will allow the characterization of TDI releases for each facility and provide operators the flexibility to select and implement the Best Available Technology Economically Achievable (BATEA) to address both stack and fugitive emissions in the context of individual circumstances. Furthermore, industry will be able to update their plan at any time, and also can build on an existing plan, as long as their plan meets the requirements of the Notice.

This sector P2 Planning Notice will allow the addition of other toxic substances, as may be required in the future, with substance-specific risk management objectives and requirements.

The first step of the development of the Notice is the development of a Working Document that describes all of the key elements of the P2 Planning Notice.  The purpose of this document is to allow Environment Canada to establish a dialogue with stakeholders to ensure that the proposed instrument is efficient and effective in achieving the objectives stated in the Risk Management Approach. 

The Working Document for the P2 Planning Notice for the Urethane and Miscellaneous Foam Sector (excluding Polystyrene) is drafted, and email consultation with urethane and miscellaneous foam sector (excluding polystyrene) companies is occurring from November 12, 2009, to December 23, 2009 (30 working days).  

Comments received on this working document will be considered in the development of the Proposed P2 Planning Notice for the Urethane and Miscellaneous Foam Sector (excluding Polystyrene) with respect to TDIs that will be published in Canada Gazette, Part I not later than July 5, 2010, for a 60-day public comment period.

A document with the response to comments received during the email consultation on the Working Document for the P2 Planning Notice will be published on the same date as the Proposed P2 Planning Notice.

Contacts

For further information regarding this working document and related consultations, please contact:

José Babonnaud
A/Head of Rubber Sector
Chemical Production Division
Environment Canada
Place Vincent Massey, 19th Floor
351 St. Joseph Boulevard
Gatineau QC  K1A 0H3
pgpc-cmp.dppc-cpd@ec.gc.ca

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