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Management of BPA: the latest government proposal

In October 2008, the Ministers of Health and the Environment under the Canadian Environmental Protection Act 1999 (CEPA), concluded that BPA (bisphenol A) is toxic to both human health and the environment. With such a conclusion, Canadians have, no doubt, been wondering what steps the government would take to protect their health and the environment from exposure to BPA.

Ban on BPA Baby Bottles

The Ministers have proposed various strategies to manage BPA. For example, the government has proposed prohibiting the advertisement, sale and import into Canada of polycarbonate baby bottles that contain BPA. This proposal is expected to become law in the near future.

Food Packaging – Safe Enough?

In October 2008, the government also proposed adopting a precautionary approach for BPA in food packaging for products intended for newborns and infants. The proposal is not to ban it, but to make BPA levels as low as “reasonably achievable” for this vulnerable population. We feel that a genuinely precautionary approach would eliminate the use of BPA in this application and demand safe alternatives.

Government’s Plan is Weak

With mounting evidence of possible health impacts at very low levels of exposure to BPA and, in particular, its effects on fetuses, babies and children, there is concern: is the government’s course of action for managing this chemical sufficiently aggressive?

BPA released into the water of industrial effluent has been established as the greatest source of release for this chemical. In November 2009, the government proposed to deal with this by recommending a concentration limit for release from industrial facilities of 1.75 micrograms/litre.

There are a number of concerns with this proposal:

  • It only addresses industrial BPA releases at the end of the process (“end of pipe”) and does not attempt to reduce or eliminate BPA at the source;
  • It excludes measures to directly limit or eliminate human exposure to BPA from consumer products;
  • It does not consider minimizing the release of BPA from recycling and disposing of products which contain it;
  • It focuses only on releases to water and not to air and soil.

While this is only one segment of the risk management for BPA, there is concern that attempts to manage BPA in other sectors may be equally weak and do not sufficiently protect human health or the environment.
We believe that government should set significantly lower release levels, explicitly recommend reduction of BPA over time, and set total elimination as the final goal.

Article by Sandra Madray, PCN Board Member


Environment Canada – Consultation Document on bisphenol A (BPA), (Phenol, 4,4′-(1-Methylethylidene)bis-); Chemical Abstracts Service Registry Number: 80-05-7; November 2009

Government of Canada – Order Amending Schedule I to the Hazardous Products Act (bisphenol A) – Regulatory Impact Analysis Statement; Vol 143, No. 26, June 27, 2009

Environment Canada & Health Canada – Screening Assessment for the Challenge – bisphenol A – October 2008

Environment Canada & Health Canada – Proposed Risk Management Approach for bisphenol – October 2008

ENGO Comments in Response to Consultation Document on Bisphenol A (BPA) Proposed Regulations for Industrial Effluents – Canadian Environmental Law Association and Chemical Sensitivities Manitoba, January 2010.

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