Canada Introduces Plan to Assess and Manage Key Substances under Modernized Environmental Protection Act

On October 4, 2024, the Government of Canada took another important step to protect public health and the environment with the introduction of the Proposed Plan of Priorities under the Canadian Environmental Protection Act, 1999 (CEPA). In line with the modernization of CEPA, which received Royal Assent through Bill S-5, the Plan focuses on the assessment and management of substances in Canada with the goal of reducing risks to human health and the environment. The plan emphasizes the importance of transparency in the management of chemical substances that are integral to daily life but may pose risks if not carefully controlled. By prioritizing substances that may pose a risk to human health or the environment, the government aims to protect vulnerable populations and ecosystems.

Public consultations on the Proposed Plan of Priorities began on October 5, 2024 and will remain open until December 4, 2024. Environment and Climate Change Canada and Health Canada are seeking input from stakeholders including Indigenous communities, provinces, territories, industry and academia. This inclusive approach will ensure that diverse perspectives are considered as the plan is finalized.

Substances Prioritized for Assessment

The Proposed Plan of Priorities identifies key substances that require assessment based on their potential hazards. These include chemicals known to be carcinogenic, mutagenic, or toxic to reproduction, as well as those that may disrupt the endocrine system. The plan also targets substances that disproportionately affect certain populations or environments due to higher exposure or susceptibility. For example, chemicals capable of long-range transport, such as those affecting the Arctic region, are prioritized because of their potential to accumulate in ecosystems far from their sources.

The prioritization process uses a weight-of-evidence approach and applies the precautionary principle when conducting assessments. This ensures that the assessment process remains rigorous, with consideration for cumulative exposures and real-world impacts on human health and the environment.

List of Prioritized Substances

As part of the CEPA modernization, the government has identified a list of substances that will be prioritized for assessment. These substances were selected based on their potential hazards, such as carcinogenicity, mutagenicity, reproductive toxicity, and endocrine disruption. The prioritized substances include:

• Dichloromethane (DCM; CAS RN 75-09-2): A solvent used in industrial applications, known for its potential to cause liver and lung damage.

• Trichloroethylene (TCE; CAS RN 79-01-6): Commonly used to degrease metal parts, it poses significant risks to human health, including cancer.

• Styrene (CAS RN 98-83-9 and 100-42-5): Found in plastics and rubber, styrene has been linked to respiratory problems and nervous system effects.

• Tetrachloroethene (PERC; CAS RN 127-18-4): Widely used in dry cleaning, PERC has been linked to cancer and nervous system damage.

• Apigenin (CAS RN 520-36-5): A naturally occurring compound in some plants, under scrutiny for its effects on human health.

• 1,3,4,6,7,8-Hexahydro-4,6,6,7,8,8-hexamethyl-cyclopenta[g]-2-benzopyran (HHCB; CAS RN 1222-05-5): A fragrance ingredient suspected of accumulating in the environment and posing ecological risks.

Additionally, certain nanoscale substances such as Nanoscale silver (nAg; CAS RN 7440-22-4) and Nanoscale zinc oxide (nZnO; CAS RN 1314-13-2) are included due to their widespread use in consumer products and concerns about their long-term environmental effects.

Supporting Risk Management and Assessment

The Proposed Plan of Priorities outlines several initiatives to support the assessment and management of risks posed by substances. These include activities aimed at enhancing scientific methodologies, such as the development of non-animal testing methods and the integration of computational models. The government is also investing in research, monitoring and surveillance efforts to stay ahead of emerging risks and evolving scientific knowledge.

Additionally, the plan encourages public engagement through regular updates, workshops, and consultation processes to ensure transparency and inclusiveness in risk management activities. This includes gathering information from stakeholders to support the prioritization and assessment of substances.

In addition to assessment, the plan includes initiatives to promote the use of alternative testing methods, to reduce the reliance on vertebrate animal testing in favor of more ethical and advanced scientific approaches.

Reducing Animal Testing

In line with global trends, the Proposed Plan of Priorities emphasizes the need to replace, reduce, or refine vertebrate animal testing. The government is committed to developing scientifically justified alternative methods that can assess the potential harm of substances without relying on animal models. This strategy will be published in June 2025, following consultation with stakeholders and experts.

Introducing the Watch List

The Proposed Watch List, another key component of the plan, will identify substances that may not meet the criteria for toxicity but still pose potential risks. This list will be a resource for manufacturers, importers and consumers to make informed choices about the substances they use. It will be continuously updated as new information becomes available to help prevent harmful substances from becoming a bigger issue in the future.

Public Involvement and Feedback

Public input is essential to the success of the Proposed Plan of Priorities. Canadians are encouraged to participate in the consultation process, which runs until December 4, 2024. The government welcomes feedback on the list of prioritized substances, as well as on broader risk management strategies. The final plan will be published by June 2025, and ongoing updates will be provided to keep stakeholders informed of new developments.

The Government of Canada remains committed to promoting environmental justice and ensuring that all Canadians have access to a healthy environment. The modernization of CEPA and the introduction of the Proposed Plan of Priorities represent significant steps forward in the responsible management of substances and the protection future generations.

For more information on the Proposed Plan of Priorities and how to participate in the consultation process, visit the CEPA Registry on the Government of Canada website.