Crude Tall Oil Proposed for CEPA Schedule 1
Canada Gazette, Part I, Volume 157, Number 7: Order Adding a Toxic Substance to Schedule 1 to the Canadian Environmental Protection Act, 1999
On 2023-02-18 the government proposed adding crude tall oil (CTO) to Schedule 1 of the Canadian Environmental Protection Act, 1999 after a screening assessment found CTO may harm aquatic life from releases at pulp-mill and related sites. The order itself does not create new regulatory requirements or costs but enables Environment and Climate Change Canada and Health Canada to develop future risk-management instruments; a 60-day public comment period followed publication.
- Published
- February 18, 2023
- Department
- Unavailable
- Section
- REGULATORY IMPACT ANALYSIS STATEMENT
- Comment deadline
- April 19, 2023
- Effective date
- Unavailable
- Publication part
- Part I
Summary
Summary#
On February 18, 2023, the federal government published a proposal to add crude tall oil (CTO) (CAS RN 8002-26-4) to Schedule 1 of the Canadian Environmental Protection Act, 1999. The screening assessment found CTO may harm aquatic life from releases at pulp-mill and related sites. The order itself would not yet impose rules but would let officials develop future risk-management measures.
What it does#
- Adds crude tall oil (CTO) to Schedule 1 of the Canadian Environmental Protection Act, 1999 (this is a proposed order).
- Gives Environment and Climate Change Canada and Health Canada authority to design and propose risk-management actions for CTO if they choose.
- Does not by itself create new regulatory requirements or costs for businesses.
- Starts a public comment period of 60 days after publication (proposal published on February 18, 2023).
- The departments concluded CTO meets the ecological test in paragraph 64(a) of CEPA (risk to the environment), but they did not find a human-health concern.
Who's affected#
- The pulp and paper sector, especially facilities that produce CTO as a co-product of kraft pulping. Industry reports for 2011 showed manufacture in the range of 10,000 tonnes to 100,000 tonnes and imports in the range of 10 tonnes to 100 tonnes.
- Companies that import or handle CTO. A recent industry survey identified five importers and four manufacturers in Canada.
- Businesses using CTO or downstream products (for example, tall-oil pitch, rosin, distilled tall oil (DTO), and some industrial uses such as oil‑and‑gas drilling additives). The assessment noted DTO and CTO are distinct; consumer products appear to use DTO, so consumer exposure to CTO seems low.
- Aquatic ecosystems and the organisms living downstream of facilities that release CTO or its components to surface water.
- The general public: the proposal itself does not change regulations or create immediate costs for citizens.
Why it matters#
- The screening assessment found releases of CTO from manufacturing and associated activities could harm aquatic life. That is the reason for adding CTO to Schedule 1.
- Being listed on Schedule 1 is the step that lets the government propose concrete controls. Future rules could affect how pulp mills treat wastewater, manage spills, or handle CTO and its wastes.
- Right now, the proposal does not change laws or require actions. But it signals possible future regulation and starts a public comment process where industry, communities, and others can respond.
- There is some uncertainty in the assessment because CTO is a complex, variable mixture and some of its components also occur naturally; that affects how persistence and bioaccumulation were judged.
Key topics
Source: Canada Gazette