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Toluene Diisocyanates – Responses to Comments
Responses to Stakeholders' Comments on the
Working Document for the Potential Pollution Prevention Planning Notice for the Urethane and Miscellaneous Foam Sector (excluding Polystyrene)
and on the
Proposed Pollution Prevention Planning Notice in Respect of Specified Substances on Schedule 1 of the Canadian Environmental Protection Act, 1999, Implicated within the Polyurethane and Other Foam Sector (except Polystyrene)
Under Part 4 of the Canadian Environmental Protection Act, 1999 (CEPA 1999)
Plastics and Rubber Section
Chemical Production Division
Toluene Diisocyanates (TDI) were found to meet one or more of the criteria set out in section 64(c) of the Canadian Environmental Protection Act, 1999 (CEPA 1999) on July 5th, 2008. Under the Act, a proposed Risk Management Instrument must be published in the Canada Gazette, Part I, by July 3, 2010.
Environment Canada is developing a sector-based Pollution Prevention (P2) Planning Notice for the Polyurethane and Other Foam Sector (except Polystyrene). The first substances to be addressed by the proposed instrument are Toluene Diisocyanates (TDI), which collectively refer to 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). This sector P2 Planning Notice will allow the addition of other substances on Schedule 1 of CEPA 1999, as may be required in the future, with substance-specific risk management objectives and requirements.
A working document containing the elements of the proposed Notice was drafted and distributed via email for comments to all industry stakeholders within the Urethane and Miscellaneous Foam sector (excluding Polystyrene). This email consultation on the Working Document for the P2 Planning Notice for the Urethane and Miscellaneous Foam Sector (excluding Polystyrene) occurred from November 12, 2009, to December 23, 2009 (30 working days).
As part of the consultation process, Environment Canada hosted a meeting with stakeholders to discuss comments received from stakeholders on the working document and to present the draft Proposed P2 Planning Notice for discussion and comments. A total of 18 participants representing various stakeholder groups from the industry, non-governmental organizations and aboriginal groups took part in the consultation workshop held in Ottawa on March 22, 2010.
This document outlines the various comments received from stakeholders on the Working Document and on the draft Proposed P2 Planning Notice, and how they have been considered and addressed during the development of the Proposed P2 Planning Notice.
The comments received are presented in two parts: Part I includes comments on the overall approach and Part II includes comments on the content of the Core Part and the Substance-specific Part of Working Document and the draft P2 Planning Notice. The comments are further organized by issues according to their nature and to the section of the Working Document and draft Proposed P2 Planning Notice to which the comment is related.
All comments received were taken into account and, where appropriate, modifications have been reflected in the Proposed Pollution Prevention Planning Notice published in Canada Gazette, Part I, on July 3, 2010.
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