TCPP and TDCPP

2-Propanol, 1-chloro-, phosphate (3:1)
CAS Registry Number 13674-84-5

2-Propanol, 1,3-dichloro-, phosphate (3:1)
CAS Registry Number 13674-87-8

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Overview

  • The Government of Canada conducted a science-based evaluation, called a screening assessment, to address the potential for harm to Canadians and to the environment from TCPP and TDCPP.
  • Under the Canadian Environmental Protection Act, 1999 (CEPA 1999), the risk posed by a substance is determined by considering both its hazardous properties (its potential to cause adverse human health or ecological effects) and the amount of exposure there is to people and the environment. A substance may have hazardous properties; however, the risk to human health or to the environment may be low depending upon the level of exposure.
  • In October 2016, the Government published a Draft Screening Assessment for TCPP and TDCPP, proposing that TCPP was harmful to human health but not to the environment, and TDCPP was not harmful to human health or to the environment. Since then, significant new information became available regarding human exposure to products available to consumers, specifically foam products containing flame retardants, such as TCPP and TDCPP. As a result, the draft screening assessment was updated.
  • As a result of the new information and the Updated Draft Screening Assessment of TCPP and TDCPP, the Government is proposing that TCPP and TDCPP are harmful to human health, but not to the environment at levels of exposure considered in the assessment.

About these substances

  • The screening assessment focuses on the substances 2-propanol, 1-chloro-, phosphate (3:1) and 2-propanol, 1,3-dichloro-, phosphate (3:1), referred to as TCPP and TDCPP, respectively.
  • TCPP and TDCPP are included in the Certain Organic Flame Retardants Grouping in the second phase of the Chemicals Management Plan (CMP), which includes 10 organic substances having similar function: application to materials to slow the ignition and spread of fire.
  • These substances do not occur naturally in the environment. According to information gathered by the Government, TCPP is used as an additive flame retardant and is mixed with other ingredients to manufacture building or construction materials (for example, polyurethane spray foam insulation), in Canada. It is found in manufactured items containing flexible polyurethane foam (for example, in upholstered furniture and mattresses) as well as in textile waterproofing spray intended for consumer use.
  • TDCPP is used as an additive flame retardant in the manufacturing of flexible polyurethane foam (for example, to manufacture upholstered furniture and mattresses).

Human and ecological exposures

  • Canadians may be exposed to TCPP and TDCPP from environmental sources (for example, air, water, and dust), food, and from the use of certain products available to consumers, such as, spray foam and waterproofing products and manufactured items, such as foam-containing furniture and mattresses.
  • This assessment took into consideration the results of human biomonitoring studies, where substances are measured in blood, urine or breast milk. The information on measured levels in humans is important to estimating exposure to Canadians.
  • TCPP and TDCPP may be released to the Canadian environment as a result of industrial activities, and from the use of products available to consumers. These releases are expected to primarily enter water through wastewater treatment systems.

Key health and ecological effects (hazard)

  • For TCPP, reproductive and developmental effects were considered to be the important or critical effects for characterizing the risk to human health in the screening assessment.
  • TDCPP has been classified as a "suspected human carcinogen", according to the harmonized classification and labelling approved by the European Union. Carcinogenicity (potential to cause cancer) and effects on the kidneys and testes were considered to be the important or critical effects identified for characterizing the risk to human health from TDCPP.
  • TCPP has demonstrated moderate toxicity to aquatic organisms and terrestrial plants, while TDCPP has shown considerably higher toxicity to aquatic organisms including effects on the endocrine system in fish.

Risk assessment outcomes

  • Based upon a comparison of levels to which Canadians may be exposed to TCPP and to TDCPP from prolonged skin contact with manufactured items containing these substances, such as foam-containing upholstered furniture and mattresses, and levels associated with critical health effects, it was determined that these substances may pose a risk to human health.
  • The risk to human health from TCPP and TDCPP from environmental sources, food and from use of other products available to consumers, were not identified to be of concern.
  • Considering all information presented, it was determined that there is low risk of harm to the environment from TCPP and TDCPP.
  • The Government of Canada published the Updated Draft Screening Assessment for TCPP and TDCPP on October 17, 2020. The public is invited to comment on the assessment during the 60-day public comment period ending on December 16, 2020.

Proposed screening assessment conclusions

  • As a result of the updated draft screening assessment, the Government is proposing that TCPP and TDCPP may be harmful to human health at levels of exposure considered in the assessment.
  • The Government is also proposing that TCPP and TDCPP are not entering the environment at concentrations that may be harmful to the environment.
  • TCPP and TDCPP are proposed to meet the persistence criteria, but not the bioaccumulation criteria, as set out in the Persistence and Bioaccumulation Regulations of CEPA 1999.

Preventive actions and reducing risk

  • The Government of Canada published the Updated Risk Management Scope for TCPP and TDCPP on October 17, 2020. The public is invited to comment on the scope during the 60-day public comment period ending on December 16, 2020.
  • The Government will consider adding 2-propanol, 1-chloro-, phosphate (3:1) (TCPP) and 2-propanol, 1,3-dichloro-, phosphate (3:1) (TDCPP) to Schedule 1 of CEPA 1999, also called the List of Toxic Substances.
  • If the proposed conclusions are confirmed in the final screening assessment, the Government is considering taking regulatory or non-regulatory actions to help reduce dermal exposure of the general population to TCPP and TDCPP in certain products made with polymeric foams, such as polyurethane foam. These products may include upholstered furniture, mattresses, mattress toppers, and other foam-based products to which prolonged skin contact may be expected.
  • Information is being sought by the Government to further inform risk management decision-making. Details can be found in the risk management scope, including where to send information during the public comment period.
  • Further information and updates on risk management actions for substances managed under the CMP can be found in the risk management actions table and the two year rolling risk management activities and consultations schedule.

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