On 18 November, in a significant move to protect both the environment and public health, the Government of Canada unveiled the Certain Products Containing Toxic Substances Regulations. This groundbreaking initiative is part of the broader Chemicals Management Plan (CMP), which aims to evaluate and reduce  risks posed to the environment and human health by potentially harmful chemical substances. 

Upgraded Management of Harmful Chemicals 

Under the Canadian Environmental Protection Act (CEPA), substances that are considered toxic to the environment or human health are subject to strict regulations. The CMP, backed by CEPA, gives the Governor in Council the authority to enact regulations to reduce the risks associated with these toxic substances. 

Focus on Coal Tars and their Distillates 

The proposed regulations particularly focus on coal tars and their distillates. These substances, which consist of  complex mixtures of hydrocarbon and other chemicals, are essential for the production of various materials like creosote, crude naphthalene, and coal tar pitch and oils. They are also used in certain veterinary and human pharmaceuticals. 

Key Objectives of the New Regulations 

The primary goal of these new regulations is to ban the manufacture, import, and sale of specific coal tar-based sealant products and sealants containing Polycyclic Aromatic Hydrocarbons (PAH) above 1,000 ppm. This is a proactive measure to prevent ecological damage and reduce health risks associated with these toxic substances in Canada. 

Implementation Timeline and Exceptions 

By January 1, 2025, the regulations will prohibit the manufacture and import of certain sealant products containing coal tars and PAHs above the 1,000 ppm threshold. Exemptions include products manufactured for export only or in transit through Canada, and those manufactured under a specific permit. The ban extends to pavement and roofing sealant products and, for coal tars, includes industrially applied sealants on various materials. 

The sale and offer of these products will be prohibited by June 30, 2025, with certain temporary exemptions. Notably, coal tar-based industrial sealants will be exempt until January 1, 2028. 

Integration of 2-BE Regulations 

The new regulations will also incorporate the existing 2-Butoxyethanol Regulations (2-BE Regulations), to improve their consistency with the current legislative draft. However, the core requirements for permitting and record-keeping under the 2-BE Regulations will remain unchanged. 

Enforcement Measures 

Enforcement of these regulations, under CEPA's Compliance and Enforcement Policy, will be stringent to ensure compliance with the new standards. This move reflects Canada's commitment to a healthier environment and public safety and underscores the government's proactive approach to chemicals management. 

The Canadian Environmental Protection Act, 1999 (CEPA), under its vigilant section 68, recently underwent a comprehensive assessment by the Environment Ministry and the Health Ministry. This review focused on a group of 13 substances, known collectively as the Titanium-containing Substances Group. The aim was to determine their potential environmental and health impacts. This article discusses the findings of this assessment and what they mean for Canada. 

What are these Titanium-containing Substances? 

Titanium, a naturally occurring metal, forms the core of these 13 evaluated substances. They range from well-known compounds such as titanium dioxide (TiO2), used in a variety of consumer products, to more complex chemicals such as titanium tetrachloride and tetrahydroxytitanium. The 13 chemicals are listed in the table below. 

Assessment Methods and Key Findings: 

The inter-ministerial team employed the Ecological Risk Classification of Inorganic Substances (ERC-I) method, which focuses on both hazard and exposure levels, to assess ecological risks. This innovative approach combined predictive models, water quality data, and various statistical metrics. The conclusion? These 13 substances are unlikely to cause significant  damage to the ecosystem. 

Human Health and Exposure 

The assessment extended beyond ecological impacts, to explore potential health risks to Canadians. The main sources of human exposure to these substances include air, water, food, and consumer products. Notably, food emerged as a major source of titanium exposure for the general population. Intriguingly, titanium was barely detectable in blood samples from the Canadian population, suggesting minimal health risks at current exposure levels. 

Specific Risks and Safety Thresholds 

Going deeper, the study identified a no-observed-adverse-effects level (NOAEL) for systemic exposure to titanium, taking into account various health endpoints. Moreover, for inhalation exposure, the study identified non-cancerous respiratory effects as the primary concern but deemed these to be unlikely at current exposure levels in the general population. 

Conclusion 

Encouragingly, this comprehensive study suggests that the 13 substances in the Titanium-containing Substances Group do not meet the CEPA criteria for being environmentally or health hazardous under current conditions. This conclusion represents a critical step in the understanding and management of these substances in Canada, ensuring a balance between use and safety.