Document 3edbVL1J3V8VR7ZEwZrVxra5a

AR Consultation Meeting on PFCA Action Plan February 2006 1 r 00033 Background Assessment reports completed mid 2004 New related science is being published at a high rate EC & HC using two processes to achieve a current view of the science External review of assessment reports Review of current literature 2 000034 p to ffllP 14>| !Canstia :y: ' External Review NS assessment reports made available to 22 reviewers, and concurrently made available to the public - November, 2005 13 institutions or individuals provided comments on the assessment reports representing; Government regulators and researchers, Academics, Industry, and Environmental Groups Over 150 comments on various aspects of the reports received to date 3 000035 p CJ eiwiwfewS' 8 rii6 w in w w < t' Canrla Costate Nature of Comments Comments received have either questioned or clarified or supported the scientific basis of the assessment and the decision making process Areas of interest have included: - atmospheric fate - polymer stability - biological fate - exposure - toxicity - general issues 4 00003*7 p -P Comments: Atmospheric Fate Fluorotelomer intermediates will be adsorbed, not volatilized Evidence is supportive of volatilization Lack of evidence to support long range transport Atmospheric oxidation will degrade the fluorocarbon chain, PFCAs wi I not be formed Monitoring has not shown FTOHs higher than 8:2 Other mechanisms must be considered in atmospheric fate analysis Atmospheric fate mechanisms not sufficiently understood 5 0003*7 O0l Comments: Polymer Stability Lack of direct evidence of polymer instability OECD hydrolysis studies do not show significant hydrolysis Cleavage of ester bond is expected FTOH will not be produced by polymer degradation Biodegradation not observed in certain studies Representative structures used in modeling could be improved It is appropriate to consider breakdown products in assessment 6 p 9> Comments: Biological Fate Need to consider evidence of metabolism of FTOH to PFCAs C-F bond to be metabolized to a certain extent Branching and length of fluorocarbon chain affects excretion rate Concentration in organs reflective of exposure, not bioaccumulation Bioaccumulation should be based on concentrations in diet Observed levels may come from snow ingestion 7 coorte: Comments: Exposure Release of flurotelomer precursors insignificant compared to direct PFCA release Incineration should be discussed as a disposal mechanism Data from an ice core sample is indicative of high historic levels Water a likely medium for PFCAs to reside Arctic data may be explained by historic fire fighting activities Additional exposure routes need to be considered for human assessment, e.g. dust/particles ingestion in children and inhalation of indoor air 8 000040 p 00 Comments: Toxicity No data showing concern over aquatic species Concentrations used in toxicity studies exceed concentrations in the environment Lab animal data may not be an appropriate surrogate for non-rodent terrestrial wildlife Terminology and significance of certain toxicological endpoints were questioned p <0 I 9 000041 Comments: General Inappropriate use of the precautionary principle Support for the application of the precautionary principle Much of the scientific work conducted by one research group Assessments do not consider cumulative exposure from related substances 10 000042 Science Update Health and Environment Canada are gathering and reviewing recent scientific information Data collection efforts include: - Scientific studies provided to EC/HC - Search and collection of peer reviewed literature - Collection of recent conference presentations/posters 11 000043 p. 11 Science Update cont. 133 new relevant scientific publications available Numerous scientific studies available through recent conferences Studies have addressed issues including: - Atmospheric chemistry of precursors - Biological and environmental monitoring - Analytical methods - Environmental and mammalian toxicology - Physical properties - Aqueous degradation - Human monitoring List of scientific publications are available 12 000044 Analysis to date Comments raised several issues which are addressed through publications since 2004 Comments, combined with a review of scientific literature is not prompting EC/HC to reconsider the original assessment conclusions. 13 000045 p. 13 fm ($p fmm^- -g^ponnemer* Sf Next Steps Official responses to comments will be prepared Current literature and the comments are being considered: - In the regulatory proposals for the four new polymers, and - In developing other aspects of the Action Plan, notably a research agenda and assessment activities. p. 14 14 000046 Additional Input? Additional input on the science (comments or studies) will be accepted until February 22,2006 Input should be sent to: Greg Hammond New Substances Division Environment Canada Place Vincent Massey, 14th floor 351 St. Joseph Blvd. Gatineau, Quebec K1A0H3 greg.hammond@ec.gc.ca 15 000047 p. 15