Brad Ross, Application Processor
Environmental Assessment and Approvals Branch
2 St. Clair Avenue West, Floor 12A
Toronto, Ontario, M4V 1L5

SENT BY FAX: (416) 314-8452

EBR Registry Number: IA03E0184

RE.  Application by Grant Forest Products Inc. for Approval of the
        Addition of Methane diphenyl diisocyanate       (MDI)
 
Notice of an application from Grants Forest Products for approval of the addition of methane diphenyl diisocyanate (MDI), at a maximum rate of 2000 kilograms per hour to Grants production lines has been posted on the Environmental Bill of Rights electonic registry. According to the posting, Grants is proposing to add MDI to "the wood waste strands introduced through the forming heads of each of Line 1 and Line 2, exhausting to atmosphere through two (2) existing stacks".

MDI is one of 15 substances currently under review by the Ministry of the Environment.  According to on-line sources, MDI is described as being toxic, harmful by inhalation or ingestion,  and an eye, skin and respiratory irritant. It may cause allergic sensitization, and may be harmful through skin contact. Under U.S. EPA's 1996 Proposed Guidelines for Carcinogen Risk Assessment, the carcinogenic potential of MDI/PMDI would be characterized as "cannot be determined," but for which there is suggestive evidence that raises concern for carcinogenic effects.

Northwatch has reviewed the EBR posting, done some preliminary research on environmental, health and toxicity concerns related to MDI, reviewed the application for approval dated August 19th, 2002 and completed a preliminary review of the "Information Draft on the Development of Air Standards for Methane Dyphenyl Diisocynate (Ministry of the Environment, December 2002).

On March 2, 2003 we wrote to Grant Forest Products requesting more information about their proposed addition of MDI to their production lines at their Englehart facility. Our questions included:

•   what is the purpose of the proposed addition of methane diphenyl diisocyanate (MDI), in terms of enhancing production or your product?
•   what are the environmental and health impacts associated with the addition of methane diphenyl diisocyanate (MDI) to your process?
•   what alternatives were considered in selecting methane diphenyl diisocyanate (MDI) as the additive?
•   how was the environmental / health cost/benefit analysis done with respect to the selection of methane diphenyl diisocyanate (MDI) as the additive of choice?

We were very pleased to receive a response from the Company, dated March 6 and received on the same date, and appreciate the effort made to respond to our inquiry with the very short timeframe we had available. In their response, Grant Forest Products outlined the history of their use of MDI (at their Timmins plant), identified some market pressures and concerns, indicated that they are not aware of any health related problems as a result of their introduction of MDI at the Timmins oriented strand board plant. They also indicated that they had performed air dispersion calculations to assess the impact of adding MDI to the manufacturing process at the Englehart plant and are satisfied with the results, and that the introduction of MDI to the Englehart plant process will reduce the formaldehyde air emissions from the plant.

While we appreciate the response to our inquiry, and are generally satisfied with respect to our question about the purpose of the proposed addition of methane diphenyl diisocyanate (MDI), in terms of enhancing production or Grant's product, we do not feel that the balance of our concerns are outstanding, and in particular, our concerns with respect to the  environmental and health impacts associated with the addition of methane diphenyl diisocyanate (MDI) to the production process at Grant's Englehart plant.

As indicated above, MDI is known to be toxic and suspected to be carcinogenic. In addition to the known effects of chronic exposure (asthma, chronic bronchitis, hypersensitivity pneumonitis) and acute exposure (coughing, laryngitis, chest pain, head aches, insomnia, ataxia, vomiting and senstation of construction of the chest) there are also concerns about postnatal developmental effects associated with MDI.

The Ontario Ministry of the Environment has identified the need to update the air quality standard Methane diphenyl diisocyanate.. An Air Standard Information Draft for Methane Diphenyl Diisocyanate which summarizes key toxicological and risk assessment information and reviews standards and guidelines for methane diphenyl diisocyanate used by other jurisdictions has been released for comment, and the peer reviewed scientific studies and other relevant toxicological information summarized in the draft standard will form the basis for the future proposed air quality standard for methane diphenyl diisocyanate.

In respect of all of the above, it is our view that the an approval should not be given to Grant Forest Products Inc. for the addition of methane diphenyl diisocyanate (MDI), at a maximum rate of 2000 kilograms per hour, to Grants production lines at their Englhart plant. Our reasons include the following:
 

•   to the best of our determination, there has been no environmental / health cost/ benefit analysis done with respect to the selection of methane diphenyl diisocyanate (MDI) as the additive
•   there are serious environmental and health impacts associated with the chronic and/or acute exposure to methane diphenyl diisocyanate (MDI)
•   the Ministry of the Environment is currently reviewing the Air Standard for Methane Diphenyl Diisocyanate, with the public comment period not closing until (at least) March 15, 2003 and the revised standard not available for some unknown period following that; it would be inappropriate to approve the addition of a toxic substance to a plant's emissions when recent toxicological information has resulted in a decision by the Ministry of the Environment to review the Air Standard (for release) of that same substance.

In closing, we urge Approvals Branch to reject this application. In the alternative, and without prejudice to our preferred option as just stated, we would urge the Ministry to do the following:

•   defer consideration of the application until after such time as the Air Standard for Methane Diphenyl Diisocyanate has been revised; and
•   require the Company to hold an information session in the community of Englhart, with adequate notice to the community and concerned parties, including Northwatch, to provide the community with the opportunity to make informed comment to the Ministry of the Environment with respect to the Application.

Thank you for considering our comments.
 
 

Brennain Lloyd
Northwatch

cc.    Larry Lefebre, Ministry of the Environment Timmins District Office
         Gaeten St-Denis, Manager, Corporate Compliance, Grant Forest Products Inc.
         Gord Miller, Commissioner of the Environment
 

Brennain Lloyd
Northwatch