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Dear Executive Director, Program Development and Engagement Division,
I am writing to you today about the recent decision published in Canada Gazette, Part I, Vol. 143, No. 36 - September 5, 2009 to not designate 1,4-dioxane as "toxic" in Canada. As you know, this chemical is an International Agency for Research on Cancer Group 2B carcinogen, on California's Prop 65 as a chemical known to cause cancer, and a European Commission Category 3 carcinogen. As you also know, it's everywhere in consumer products, including those used by children, even though it can be easily removed.
There is concern that assessing the extent of Canadian's protection from exposure to this obvious carcinogen was limited. This is because of, but not limited to, the:
- Lack of drinking water tested for meaningful model input;
- Limited number of personal care products considered; and
- Various assumptions fed into exposure estimates.
Given the above, as well as its persistence in water, unknown interactive effects, and relatively small lower margin of exposure for levels at which no tumours or any harmful effects may occur, a precautionary approach should be applied and 1,4-dioxane should be designated as "toxic".
Testing in the US found 1,4-dioxane in Aveeno Baby Soothing Relief Creamy Wash, Johnson's Baby Shampoo, and other products on Canadian shelves. It is clear that action beyond addition to the Cosmetics Hotlist is needed to rid toxins from personal care products.
Thus, I urge you to show the world, once again, that Canada is a leader when it comes to protecting our health and our children's health from harmful chemicals: designate 1,4-dioxane as "toxic" and get manufacturers to remove it from our consumer products.
Thank you.
Sincerely,
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