Canadian Risk Management Regulation
Canada Releases Updated Risk Management Strategy for Acrylonitrile Which Concludes No Need for Additional Controls
In November 2010, Environment Canada released an updated risk management strategy for acrylonitrile. This document offers an update to Environment Canada’s 2002 risk management strategy in order to account for information on a significant new source that has appeared after the original pollution prevention (P2) plan was introduced. The purpose of this update is to determine whether additional control measures are warranted for addressing this new source.
The original 2002 risk management strategy was issued as a result of Canada’s 2001 conclusion that acrylonitrile meets the criteria specified in paragraph 64(c) of CEPA 1999 [link to history] This conclusion placed acrylonitrile on the List of Toxic Substances in Schedule 1 of CEPA 1999 and in the publication Canada Gazette, Part II. Following publication in the Gazette and pursuant to CEPA 1999, a risk management strategy for acrylonitrile was set in place in 2002, with the objective of reducing acrylonitrile emissions to the lowest achievable levels using the best economical techniques available. The risk management strategy document explains the reasons for managing human health and environmental risks posed by the use and/or release of acrylonitrile while describing the existing management initiatives or instruments in place to reduce uses and/or releases both domestically and internationally. The 2002 risk management also aimed to outline a future approach for preventing and controlling further use and/or release of acrylonitrile.
Since the Minister of Environment and the Minster of Health issued a notice requiring the preparation and implementation of pollution prevention plans for acrylonitrile in May of 2003, Environment Canada had been monitoring the NPRI to identify and address any significant new sources of acrylonitrile emissions not subject to the original P2 planning notice. Towards the end of 2005, Environment Canada and Health Canada began working with various agencies in Quebec, including the Ministère du Développement durable, de l'Environnement et des Parcs (MDDEP) and industry in order to characterize an increase in acrylonitrile emissions reported to NPRI and determine if further risk management measures would be warranted. In December 2008, the Commissioner of the Environment and Sustainable Development to the House of Commons tabled a report to Parliament recommending that Environment Canada review and update its risk management strategy (RMS) for acrylonitrile. Thus, Environment Canada prepared an updated 2010 strategy in order to take into account significant new sources of acrylonitrile.
Excerpts from November 8, 2010 Updated Environment Canada AN Risk Management Strategy
Acrylonitrile emissions from the plastic sector
Based on NPRI reports of the last four years…one SAN foam producing facility released the largest percentage of all industrial acrylonitrile emissions (91%). The implementation of BATEA at this facility has resulted in a reduction of its acrylonitrile emissions by 84.5% over the last four years (NPRI 2000-2008 data, NPRI preliminary data 2009). Ambient air monitoring program results in the vicinity of this site show that acrylonitrile concentrations were further reduced by 16% in the last two years.
One other facility in the plastic sector (production of polystyrene foam product) reported minimal (2 kg in 2009) releases of acrylonitrile to air.
Given that the largest acrylonitrile emitter in this sector has significantly reduced its acrylonitrile releases by implementing BATEA and thus achieved the RMO, no risk management actions are considered for the plastic sector at this time.
Acrylonitrile emissions from the rubber sector
The single NBR manufacturer subject to the 2003 P2 notice prepared and implemented its P2 plan…In 2008 this facility transferred its NBR production outside of Canada.
…no risk management actions are considered, at this time, for the rubber sector.
Acrylonitrile emissions from the chemical manufacturing sector
The 2009 acrylonitrile releases for one facility in the chemical manufacturing sector (production of acrylic emulsions) are minimal as a result of the implementation of BATEA at the facility. …no risk management actions are considered, at this time, for the chemical manufacturing sector.
Acrylonitrile emissions from other sectors
One facility in the wood product manufacturing sector reported releases of only 1 kg of acrylonitrile to air in 2009.
Given the minimal contribution…no risk management actions are considered, at this time, for the wood product manufacturing sector.
Acrylonitrile in tobacco smoke
Given the broad range of activities included in Canada’s comprehensive tobacco control strategy…no additional risk management initiatives for acrylonitrile are planned at this time.