0ba0c9c5_t_Red_104___Environment_Canada_Summary_table_Response
[Comment] Recorded releases and assumed low quantities of the pigments are insufficient evidence to conclude that all requirements for being CEPA toxic are not met. Releases from landfills and incinerators should not be assumed to be zero and the level of leaching to groundwater or surrounding soil should be critical to the assessment because the substances remain in these locations for a very long time. Incineration may enhance the problems since the by-products (i.e. dioxins, other heavy metals, particulate matter) may have impacts on health or environment and are not considered in the assessment reports. [Response] 
In the context of the mass flow tool, releases from waste management sites were not considered in the calculations because they are difficult to estimate and are expected to be small. In the case of landfills, considering the properties of the substances (low vapour pressure, low solubility, moderate to very high partition coefficients for the dissolved metals), the presence and the migration of the dissolved metals through soil or leaching to groundwater is expected to be minimal. Additionally, the dissolution of the pigments is further reduced by the incorporation of the substances in products (plastics, paints and coatings). Additionally, it is important here to note that all products sent to waste disposal and incineration are managed through waste management programs at Environment Canada and/or provincial jurisdictions, such as programs to meet the Canada Wide Standards for dioxins and furans.
Public comments for C.I. Pigment Red 104 - Environment Canada