0ba0c9c5_t_Red_104___Environment_Canada_Summary_table_Response
[Topic] Weight of evidence and precautionary principle [Comment] Comments were received indicating both agreement and disagreement with the draft CEPA 64c conclusions in the screening assessment reports for C.I. Pigment Yellow 34 and C.I. Pigment Red 104. One commenter disagreed with the human health conclusions of the screening assessment based on the assumption that the pigments are inhaled carcinogens, which is not a relevant route of exposure to the general population. [Response] 
As stated in the screening assessment, Health Canada agrees that inhalation exposure to the general population is negligible. With respect to carcinogenicity, consistent with the Ministers' Notice of Intent (December 9, 2006), Health Canada considers that evidence of carcinogenicity (i.e., classification by one or more international/national agencies), in the absence of a fully elucidated mode of action analysis, is sufficient to propose a conclusion that there is a probability of harm at any level of exposure and that the criterion in paragraph 64c of CEPA 1999 is met. The application of a precautionary approach is required under CEPA 1999. Information regarding the assessment of non-threshold toxicants under the Existing Substances Program is available at http://www.hc-sc.gc.ca/ewh-semt/pubs/contaminants/approach/ index_e.html
Public comments for C.I. Pigment Red 104 - Environment Canada