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Call for comments on federal Triclosan policy by January 10

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In 2012, Environment Canada under the Canadian Environment Protection Act (CEPA) undertook a review of Triclosan and it was found to pose a risk to human and environmental health and was recommended for risk management.  Environment Canada has recently released a discussion document about the proposed approach to risk management. The discussion document is available at: 

Background on Triclosan
 
Triclosan is used as a preservative and as an antimicrobial agent in a wide range of products used by consumers including personal care, non-prescription drug, natural health, and cleaning products. As noted in section 2.1 of this document, triclosan was also registered in Canada, prior to December 31, 2014, as a pest control product for use in textiles, leather, paper, plastic and rubber to stop the growth of bacteria, fungus, mildew, and to prevent odours.
 
The primary way triclosan is entering the environment is through wastewater effluent, due to its presence in consumer products. 
 
The proposed environmental objective for triclosan is to reduce concentrations of triclosan in the aquatic environment to levels below the predicted no-effect concentration (PNEC) of 376 ng/L..

Proposed Risk Management Objective
 
Environment Canada is currently proposing the preparation and implementation of pollution prevention plans under section 56 of CEPA. The Notice would apply to formulators and importers of products containing triclosan.
The discussion document notes that wastewater effluent and biosolids production is regulated by provincial regulations and by the Wastewater Systems Effluent Regulation (WSER). Triclosan is not explicitly regulated in the WSER, but studies suggest removal rates of 49-98% of triclosan from secondary treatment plants in Canada – the ultimate end goal of the WSER.  However, secondary treatment may create methyl-triclosan, which is a potentially more persistent and more bio-accumulative substance than triclosan as indicated in the assessment report.

Next Steps
The current public consultation is intended to get initial feedback from the industry on the proposed risk management objective, before publication of the regulations themselves. The discussion document identifies several information gaps that Environment Canada is seeking specific information on:
 
  1. Information about potential alternative substances to triclosan;
  2. Identification of any products that contain triclosan for which no viable alternatives exist (along with an explanation); 
  3. Information on impacts and benefits of the proposed risk management instrument (for industries, consumers, the environment, etc.); and
  4. Information on changes in use patterns following the 2011 data received from the section 71 Notice under CEPA.
This type of information should be provided on or before January 25, 2017 to the contact identified in section 8 of this document.

Implications
 
It seems that the risk management measure for triclosan will address the substance at the point of addition to consumer products, rather than requiring its removal at wastewater facilities, which is an approach CWWA fully supports. 
As mentioned in the risk management document, while secondary treatment does efficiently remove triclosan, it has the potential to convert it to more persistent forms, so removing at the point of discharge is not a practical solution.

CWWA Response
 
CWWA will submit a response based on input from our members and our Wastewater Committee.  Please provide us with your comments by January 10th so that we may review and consolidate all comments.

Comments can be sent to info@cwwa.ca 
 

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