0ba0c9c5_t_Red_104___Environment_Canada_Summary_table_Response
[Topic] Data collection [Comment] The government should use section 71 of CEPA to fill in data gaps in exposure estimates for these pigments (i.e. leaching rates; incineration activities; scrap metal yards; occupational exposure; hobbies with materials containing these pigments; and exposure to children and other vulnerable populations). As well, the government should further investigate the ability of all grades of silica encapsulation to decrease the potential toxicity of these pigments. [Response] 
In the Notice of Intent published in Canada Gazette, Part 1, the Government of Canada invited industry and other stakeholders to provide specific information that may be used to inform risk assessment and to develop and benchmark best practices for the risk management and product stewardship of those substances identified as the highest priorities. In addition to the data collected under the section 71 surveys, the screening assessments use the available scientific data from a range of sources including published literature in scientific journals and other international reviews. The Government of Canada has stated that the absence of new information will not preclude the Ministers from issuing a decision that safeguards human health and the environment. Thus the process being used for the Challenge substances is not to wait until data gaps are filled, but to act on what we know now.
Public comments for C.I. Pigment Red 104 - Environment Canada