Via Electronic Delivery Submission
September 29, 2010
Chemicals of High Concern
Minnesota Department of Health
Environmental Health Division
Site Assessment and Consultation Unit
P.O. Box 64975
St. Paul, MN 55164-0975
Dear Sir or Madam:
The Organic Peroxide Producers Safety Division (OPPSD) of the Society of the Plastics
Industry, Inc. (SPI) is the principle industry organization representing organic peroxide
producers in North America. We are contacting you regarding the Minnesota Department of
Health’s (MDH’s) chemicals of high concern (CHC) list.
Following an initial screening based primarily on modeling data, Environment Canada (EC)
released Preliminary Assessments (see Attachment 1) concluding that four organic peroxides
(i.e., CAS # 78-63-7, CAS # 1068-36-8, CAS # 6731-36-8 and CAS # 2155-25-3) were
presumed to be Persistent, Bioaccumulative and Inherently Toxic (PBiT) and thus "Toxic to the
Environment." EC challenged industry to provide data to rebut this presumption. OPPSD
conducted specialized testing and submitted corresponding reports to EC demonstrating that
these chemicals were not persistent under realistic conditions to which EC agreed. Additional
member reports demonstrated a lack of inherent toxicity. As a result, EC’s updated information
located at http://www.chemicalsubstanceschimiques.gc.ca/challenge-defi/index-eng.php reflects
that these compounds are no longer presumed to be PBiT and hence not "Toxic to the
Environment" under the Canadian Regulations. We recommend that you speak with our contact
at EC who can provide the EC perspective regarding the findings from these studies:
Ken Taylor
Executive Director, Existing Substances Division
Environment Canada
Place Vincent Massey
351 St. Joseph Blvd
Gatineau, Quebec, Canada K1A-OH3
Tel.: (819) 953-3976
E-mail:[email protected]
In addition, we would like to work with you to address two additional peroxides (i.e., CAS # 8015-9 and 1338-23-4) that are included on your list.
We also agree with the MDH that a more thorough review will be needed for future revisions of the
CHC list as an in-depth review of all of the chemicals on the Maine list did not occur. In addition,
we note that the source lists used by the MDH are not static and will continue to be updated and
modified.
Please contact me directly at 202.974.5258 or [email protected] if you have any
questions or if you require additional information. We appreciate your help with this matter and
look forward to hearing from you regarding MDH’s process to update its chemicals of high
concern list.
Sincerely,
Melissa Hockstad
Executive Director, Organic Peroxide Producers Safety Division
SPI: The Plastics Industry Association
1667 K St. NW, Suite 1000
Washington, DC 20006-1620
Attachment
Attachment 1 – Environment Canada (EC) Preliminary Assessments Information
Batch 1
Environment Canada published the original draft assessments for the three Batch 1 peroxides
(CAS # 78-63-7, 1068-27-5 and 6731-36-8) on January 19, 2008 and that information can be
found at:
http://www.ec.gc.ca/lcpe-cepa/eng/notices/NoticeDetail.cfm?intNotice=435
See items # 3, 4 and 5 on the list – Click on the “HTML” link.
PDF Copy of the original Canada Gazette notice can be found at:
http://canadagazette.gc.ca/rp-pr/p1/2008/2008-01-19/pdf/g1-14203.pdf.
Final assessment reports can be found on the Challenge website:
http://www.chemicalsubstanceschimiques.gc.ca/challenge-defi/batch-lot-1/index-eng.php.
Batch 3
Environment Canada published the original draft assessment for the Batch 3 peroxide (CAS #
25155-25-3) on August 23, 2008 and that information (HTML version) can be found at:
http://canadagazette.gc.ca/rp-pr/p1/2008/2008-08-23/html/sup-eng.html#CAS25155253.
PDF Copy of the original Canada Gazette notice can be found at:
http://canadagazette.gc.ca/rp-pr/p1/2008/2008-08-23/pdf/g1-14234.pdf. Go to “Supplement” at
the end of the Gazette issue.
Final assessment reports can be found on the Challenge website:
http://www.chemicalsubstanceschimiques.gc.ca/challenge-defi/batch-lot-3/index-eng.php.