Consultation on Proposed Regulations for Polycyclic Aromatic Hydrocarbons (PAHs) in Sealant Products

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By: Sarah D’Mello, Senior Product Safety Specialist, email

The Government of Canada (GC) is seeking feedback on the Proposed Regulations for Polycyclic Aromatic Hydrocarbons (PAHs) in sealant products consultation document. The Regulations are expected to cover the manufacture or import of all pavement and roofing sealant products with a PAH content above 1000 ppm, other than Coal Tar-Based Sealant Products, as they are proposed to be prohibited.

This consultation will complement the Proposed regulations for coal tar-based sealant products consultation document that was published in December 2021 to inform and involve stakeholders on regulating PAHs in pavement and roofing sealant products in addition to coal tars and their distillates.

What are PAHs?

PAHs are compounds made up of carbon and hydrogen atoms grouped into rings containing five or six carbon atoms. They occur naturally in coal, crude oil, and gasoline or can result from burning coal, oil, gas, wood, garbage, and tobacco. PAHs can bind to or form small particles in the air.

An assessment carried out and published in 1994 by Environment Canada concluded that PAHs are toxic under the Canadian Environmental Protection Act (CEPA) and as a result, were added to Schedule 1 of the Act. PAHs are deemed to be entering the environment at a concentration resulting in harmful effects to the environment and human health.

Key Questions and Topics for Discussion

The GC has outlined a series of questions and/or topics that feedback is being sought. These include:

  • Are there any essential uses of these pavement/roofing sealant products that we should consider exempting from these proposed Regulations?
  • If your company is manufacturing, importing, and/or using these products, how long could it take to transition to pavement/roofing sealant products with PAH contents equal to or lower than 1000 ppm?

Participating in the consultation

The GC would like to hear from the industry and stakeholders including individuals from Indigenous communities, non-governmental organizations, and the general public.

The consultation period was opened on August 24, 2022, and is expected to close on October 22, 2022.

Participation in the consultation can be done through email, phone, or mail. For more information, please visit the Government of Canada website.

Dell Tech
Sarah D’Mello 
Senior Product Safety Specialist

Dell Tech has provided professional, confidential consulting services to the chemical specialty

industry in Canada, the USA, Europe, and Asia for the last 40 years.

Contact us today for more information.


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