This Web page has been archived on the Web.

Fuel additive MMT

Petition: No. 32

Issue(s): Air quality, human health/environmental health, and toxic substances

Petitioner(s): Several Canadian residents

Date Received: 3 July 2001

Status: Completed

Summary: The petitioners requested information from Health Canada on the gasoline additive MMT (methylcyclopentadienyl manganese tricarbonyl). The petitioners expressed concern about poor air quality in southwestern Ontario during the last half of June 2001 and suggested a link with MMT. They asked Health Canada to explain what steps the Department had taken to re-examine the use of the gasoline additive. 

Federal Departments Responsible for Reply: Environment Canada, Health Canada

Petition

July 1, 2001

Petition to the Commissioner of the Environment and Sustainable Development, under section 22 of the Auditor General Act.

We the undersigned, hereby petition the Commissioner of the Environment for information from the Department of Health Canada.

Whereas, during the last half of June, 2001, air quality in Southwestern Ontario and throughout the Hamilton - Toronto region was very poor (in fact smog covered a large portion of the region and people with respiratory problems were urged to stay indoors) and whereas it is a known fact that much of this air pollution comes from automotive and industrial emissions, and, in view of the fact that Health Canada continues to support the use of MMT in Canadian gasoline, based on a review of existing information published Dec. 6th, 1994, that includes studies by a person who was apparently part of the Peer Review, and who may have close associations with the manufacturer of this product, (thereby causing a conflict of interest) and in view of the fact that a later report, authored by the Troy Herrick and Monica Campbell (PHD) of the Toronto Health Council, asked for a ban on MMT one year later, based on a series of studies by reputable neuro-toxic scientists, and in view of a report by the National Round Table on the Environment and the Economy that indicated that the Department of the Environment did not support the use of this additive (MMT), we wish to know what steps Health Canada has taken to

  1. re-examine the use of this product, utilizing studies done by prominent neuro-toxic scientists from across Canada whose work was not included in the Dec/94 report;
  2. to examine the work by Dr. Louis Gottschault of California regarding the relationship between levels of manganese in the violent offenders and the incidence of violence in society; and
  3. to apply the precautionary principle to ban all neurotoxic substances and carcinogens from gasoline and diesel fuels in Canada.

Respectfully submitted by

[Original signed by several Canadian residents]*

*[names withheld at petitioners' request]

[top of page]

Minister's Response: Environment Canada

December 5, 2001


Dear [Petitioners]:*

I am writing in response to the petition that you sent to the Commissioner of the Environment and Sustainable Development, on the subject of the gasoline additive MMT.

I understand that Health Canada has provided you with a response to the petition's first two questions, which relate to the current health science on manganese, and has outlined steps that the Government of Canada is taking to apply the precautionary approach in the risk management of neurotoxic substances and carcinogens in gasoline and diesel fuels. I will outline the steps that Environment Canada has taken to address "neurotoxic substances and carcinogens from gasoline and diesel fuels in Canada."

The environmental and health effects of toxic substances occur upon the substances' release into the environment. Accordingly, initiatives to control such substances in fuels, as well as measures to reduce harmful emissions from vehicles and engines, are important.

The Benzene in Gasoline Regulations, made pursuant to the Canadian Environmental Protection Act (CEPA), were passed by Parliament in November 1998 and took effect in July 1999. These regulations limit the concentration of benzene, a known carcinogen, to 1 percent. Since the regulations took effect, benzene levels in Canadian gasoline have been reduced by nearly 50 percent. Environment Canada has also observed 30-per-cent reductions in ambient benzene levels at monitoring stations across Canada. Benzene levels in Canadian gasoline in 1999 are summarized in an Environment Canada report, Benzene in Canadian Gasoline: Report on the effect of the Benzene in Gasoline Regulations - 1999. This document can be viewed at www.ec.gc.ca/oged-dpge/level2e/publicationse.htm.

On June 23, 1999, the federal government passed the Sulphur in Gasoline Regulations. Starting in 2005, low-sulphur gasoline (that is, gasoline with an average sulphur level of less than 30 parts per million (ppm)) will be required throughout Canada. As an interim step, gasoline with an average sulphur level of not more than 150 ppm will be required starting in 2002. The regulations will reduce the sulphur content of gasoline by more than 90 percent from current levels, and will significantly reduce sulphur-containing and other harmful emissions.

On February 17, 2001, the federal government's agenda on Cleaner Vehicles, Engines and Fuels was announced. A number of measures will be taken to further reduce air pollution from gasoline- and diesel-powered vehicles and engines. These measures include the following:

  • a regulation to reduce the level of sulphur in on-road diesel fuel from the current level, 500 ppm, to 15 ppm by mid-2006, in line with the United States Environmental Protection Agency regulation;
  • regulations to align with U.S. Tier 2 standards for light-duty trucks and vehicles, to be phased in starting with the 2004 model year;
  • regulations to bring Phase 1 standards into effect for heavy-duty vehicles and engines for the 2004 model year;
  • measures to align with U.S. emission requirements for off-road vehicles and engines, such as those used in the agricultural sector and by the construction industry.

These measures will have a significant impact in reducing the emissions of harmful pollutants, including toxic substances, such as benzene, 1,3-butadiene, acetaldehyde, formaldehyde, and fine particulate matter.

The federal government takes the approach that the regulation of neurotoxics and carcinogens in fuels should be risk-based, taking into consideration the potential impact of these substances on the Canadian population. In assessing the need for controls, the government must take into account not only the substance itself, but also the substances that are produced upon its combustion and the impact of these products on emission-control equipment. For example, sulphur in the emissions of gasoline-powered vehicles has been shown to contaminate the vehicle's catalytic converter, reducing its effectiveness. Accordingly, reducing the level of sulphur in gasoline has been a high priority activity for the federal government, because it reduces emissions of several other substances, including carcinogens.

In announcing that Canada would lift its restrictions on the interprovincial trade and import of the gasoline additive MMT in 1998, the federal Ministers of the Environment and Industry underlined the government's continued commitment to protect the health and environment of Canadians. The federal government will assess the results of future tests on the effects of MMT or any other fuel additive on automobile tailpipe emissions. If subsequent federal action is warranted, it will be taken under CEPA.

Yours sincerely,

[Original signed by David Anderson, Minister of the Environment]

David Anderson, P.C., M.P.

*[names withheld at petitioners' request]

[top of page]

Minister's Response: Health Canada

RESPONSE
of
HEALTH CANADA

TO THE
PETITION FILED JULY 2001
RECEIVED BY THE MINISTER
OF HEALTH JULY 23, 2001

(IN CONFORMANCE WITH THE AUDITOR GENERAL ACT)

regarding
The fuel additive MMT and other substances contained in gasoline

Minister of Health
[Allan Rock]

November, 2001

 


Executive Summary

Health Canada has prepared the following response to the petition received from [several Canadian residents],* under the Auditor General Act. This response, along with a separate response by Environment Canada, provides information relevant to the petitioners as well as to all Canadians interested in this issue.

The petitioners raised the following issues:

  1. Re-examine the use of the gasoline additive MMT, utilizing studies done by prominent neuro-toxic scientists from across Canada whose work was not included in the December 1994 report;
  2. Examine the work by Dr. Louis Gottschault of California regarding the relationship between levels of manganese in the violent offenders and the incidence of violence in society; and,
  3. Apply the precautionary principle to ban all neurotoxic substances and carcinogens from gasoline and diesel fuels in Canada.

Additionally, in the text of the petition, several issues are raised which require response or clarification. These include:

  1. The statement in the petition that Health Canada "continues to support the use of MMT";
  2. A statement in the petition which questions the credibility of one of the peer reviewers of the 1994 Health Canada risk assessment; and,
  3. A position taken by the Toronto Health Council asking for a ban on MMT.

With respect to the request to re-examine the use of this product utilizing work done by Canadian scientists since 1994, Health Canada has continued to follow the science that has been published on the health effects of manganese and exposure to manganese through diet or inhalation since the time of the last risk assessment. Canadian researchers have published many studies, and even more work has been published by investigators in the U.S., Europe and elsewhere. Health Canada scientific staff have been monitoring and assessing this literature as it becomes available.

With respect to the request to review the work by Dr. Louis Gottschault in California, Health Canada had already examined this work in 1994. The use of hair as a biomarker of metal exposure is controversial, and interpretation of the study results are at best difficult.

Although the results are interesting from a scientific perspective, it should be noted that Health Canada, the U.S. EPA and the World Health Organization all agreed in their risk assessments for inhaled manganese that the most sensitive endpoints of manganese toxicity are subtle, subclinical neurological signs such as hand-steadiness and eye-hand coordination.

With respect to the request to ban all neurotoxic and carcinogenic substances from gasoline, Environment Canada and Health Canada follow a risk-based scientific decision making process to carry out their responsibilities under the Canadian Environmental Protection Act (CEPA) and other statutes. That is, before risk management measures (e.g., a ban, control or pollution prevention plan) are taken on a substance, a risk assessment is completed. Simply put, the process consists of two parts. First, the hazard posed by the substance itself (e.g., determination of neurotoxicity or carcinogenicity) and the extent of the exposure of Canadians or ecosystems to the substance is determined. Then, this information is used to assess the risk posed by the substance. If the risk is significant, risk management measures are developed in consultation with interested parties.

With respect to other issues raised in the petition:

  • it is important to note that, based on its assessment of the scientific evidence, Health Canada has no objection to the use of MMT.
  • Health Canada is confident that the peer review process and the outcome of its 1994 assessment are reliable.
  • The Toronto Department of Public Health did not dispute the findings of the Health Canada 1994 assessment.

Health Canada will continue to do its utmost to assure that substances are subjected to the highest standards of scientific testing for environmental, health and safety impacts. Assessments will be re-evaluated periodically as new scientific data dictates, and measures consistent with mandates will be taken. The federal government will continue to work through established risk assessment and risk management protocols in order to achieve the highest possible environmental quality for all the citizens of Canada.

Table of Contents

Foreword
Background
Introduction

Response to Petitioners' Request:
Steps Health Canada has taken to re-examine this product since 1994
Steps Health Canada has taken to examine the work of Dr. Louis Gottschault
Steps Health Canada has taken on neurotoxic/carcinogenic substances in gasoline

Other statements contained in the petition
Health Canada's position on the use of MMT
Peer Review of the 1994 document
Position taken by another organization on the use of MMT

Concluding Remarks

Annex A
The Procedures of The Petition Process Under The Auditor General Act


Background

1. [A Canadian resident]* prepared and, on July 3, 2001, on behalf of petition signatories filed a petition pursuant to Section 22 of the Auditor General Act.

2. While without a formal title, the petition concerns the gasoline additive MMT and the toxicologically important components of gasoline and diesel fuel.

3. The petition process is a means by which Canadians can express their concerns and seek greater clarification on matters of federal environmental policy. The Ministers of the Environment and of Health maintain that responsible environmental stewardship is a central priority of the federal decision-making framework.

4. The petition deals with aspects of the scientific assessment process, the peer review process, and the application of policy to the content of transportation fuels.

5. The main focus of the petition relates to new scientific studies which have become available since the Health Canada assessment of 1994, or those which may have been overlooked in that assessment, and the general approach to regulating the content of fuels. The petition requests that Health Canada:

  • Re-examine the use of the gasoline additive MMT, utilizing studies done by prominent neuro-toxic scientists from across Canada whose work was not included in the December 1994 report;
  • Examine the work by Dr. Louis Gottschault of California regarding the relationship between levels of manganese in the violent offenders and the incidence of violence in society; and,
  • Ban all neurotoxic substances and carcinogens from gasoline and diesel fuels in Canada.

6. The petition also makes statements about Health Canada's position with respect to MMT, the integrity of the peer review process followed by Health Canada in its assessment of MMT, and highlights the position taken by the Toronto Health Council in 1995 calling for a ban on MMT.

Introduction

7. The Minister of Health has provided this document to the petitioners as required by the Auditor General Act.

8. The Minister believes that Canada's existing regulatory system provides, in a sound manner, for the risk assessment and management of chemicals in the environment.

9. The Government of Canada recognizes that scientific investigation is dynamic and diagnostic tools and knowledge of impacts will continue to emerge. Thus, requirements and/or guidelines set by all levels of government will need to be revised and adjusted in accordance with emerging scientific findings.

10. This document describes the current status of Health Canada's efforts with respect to examining the scientific issues relating to manganese and MMT. It is structured to reflect three questions posed in the petition regarding the steps Health Canada has taken to: i) address the most recent science; ii) assess the 1991 research by Dr. L. Gottschault; and iii) apply the precautionary principle to a ban of all neurotoxic and carcinogenic substances in gasoline. (In the case of the application of the precautionary principle, the Commissioner also requested that Environment Canada respond.) The Health Canada response also addresses other issues raised in the text of the petition regarding Health Canada's position on MMT, the peer review process followed in Health Canada's 1994 risk assessment, and the position of another organization on MMT.

Response to Petitioners' Request:

Steps Health Canada has taken to re-examine this product since 1994.

11. In 1993, the U.S. EPA set its current reference concentration for respirable manganese in air at 0.050 µg Mn/m3. In 1994, the U.S. EPA, using a series of different statistical approaches, suggested a range of 0.09-0.20 µg Mn/m' for the reference concentration. The Health Canada reference concentration is 0.110 µg Mn/m3. In 2000, the World Health Organization (WHO) published its new manganese air quality guideline for Europe: 0.150 µg Mn/m3. The quantitative risk assessments used to derive these numbers are all based on the same study (Roels et al 1992), and are very similar.

12. Health Canada has continued to follow the science that has been published on the health effects of manganese and exposure to manganese through diet or inhalation since the time of the last risk assessment. Canadian researchers have published many studies, and even more work has been published by investigators in the U.S., Europe and elsewhere. Health Canada continues to examine all relevant literature as it is published. Health Canada scientific staff recently attended the Manganese 2001 Health Issues Symposium in Québec City to learn of the latest research results from key investigators from around the world.

13. As part of an update of the manganese risk assessment, Health Canada plans a contract to review the toxicokinetics of manganese and results of the epidemiology study of manganese neurotoxicity.

14. Although Health Canada concluded in the 1994 document that air manganese levels in most urban centres did not represent a threat to the health of Canadians, it was stated that levels in cities with manganese-emitting industries can be above the reference concentration. Hence, Health Canada has developed a protocol for a study of personal exposure to manganese and other metals in a city with industrial emissions, and is seeking funding for such a study.

15. In 2000, Health Canada and the United States National Academy of Sciences published recommendations on minimum and maximum amounts of manganese that should be ingested daily in our diets. For more information on dietary issues, see: Dietary Reference Intakes for Vitamin A, Vitamin K, Arsenic, Boron, Chromium, Iodine, Iron, Manganese, Modybdenum, Nickel, Silicon, Vanadium and Zinc. National Academy Press, 2001. [ http://www.nap.edu/books/0309072794/html/ ].

Steps Health Canada has taken to examine the work of Dr. Louis Gottschault

16. The petitioners cite the work of Dr. L. Gottschault regarding the relationship between levels of manganese in the hair of violent offenders in California prisons and the incidence of violence in society.

17. The 1991 publication by Dr. Louis Gottschault and colleagues regarding higher manganese levels in the hair of violent offenders is interesting from a scientific perspective. However, the use of hair as a biomarker of metal exposure is controversial. The metal content of hair can be from blood (endogenous) or from the external environment (exogenous), such as shampoos or dust. Misinterpretation of study results can occur due to improper cleaning of hair samples, the incorporation of external manganese directly into hair, and there are many other sources of potential error. The higher levels of manganese found in the hair of violent offenders in the study may be due to exogenous sources related to the prison or to the environment from which they came (e.g. inner city). Gottschault et al discuss the fact that the known elements of manganese neurotoxicity are not directly associated with violence.

18. It should be noted that Health Canada, the U.S. EPA and the WHO all agreed in their risk assessments for inhaled manganese that the most sensitive endpoints of manganese toxicity are subtle, subclinical neurological signs such as hand-steadiness and eye-hand coordination. While it was examined in 1994, the large degree of uncertainty in the Gottschault et al study resulted in it not being included in the critical studies of manganese toxicity reviewed for the Health Canada risk assessment.

Steps Health Canada has taken to ban neurotoxic/carcinogenic substances in gasoline

19. Environment Canada and Health Canada follow a risk-based scientific decision making process to carry out their responsibilities under CEPA and other statutes. That is, before risk management measures (e.g., a ban, control or pollution prevention plan) are taken on a substance, a risk assessment is completed. Simply put, the process consists of two parts. First, the hazard posed by the substance itself (e.g., determination of neurotoxicity or carcinogenicity) and the extent of the exposure of Canadians or ecosystems to the substance is determined. Then, this information is used to assess the risk posed by the substance. If the risk is significant, risk management measures are developed in consultation with interested parties.

20. A risk assessment always involves a degree of uncertainty, the extent of which depends on the quantity and quality of the data and information available. The Canadian Environmental Protection Act, 1999, requires that the Government of Canada, including Environment Canada and Health Canada, "exercises its powers in a manner that protects the environment and human health, (and) applies the precautionary principle that, where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation." This precautionary principle compliments the risk management process; it is risk-based, not hazard-based. That is, knowing that a substance is poisonous, for example, is insufficient to justify regulatory action under the Canadian Environmental Protection Act, 1999.

21. As to the specific chemical content of gasoline, the government of Canada has taken numerous steps to significantly reduce the toxic components of gasoline, and the emissions of toxic substances from the tailpipe. These steps include: The Benzene in Gasoline Regulations (1998) which limit the benzene content of gasoline to 1% and which have already significantly reduced ambient benzene concentrations in Canada; the Sulphur in Gasoline Regulations, which will reduce sulphur-containing and other harmful emissions; and the government of Canada's agenda on Cleaner Vehicles, Engines and Fuels which will significantly reduce tailpipe emissions from diesel powered trucks. The above measures will have a significant impact in reducing the emissions of harmful pollutants, including toxic substances, such as benzene, 1,3-butadiene, acetaldehyde, formaldehyde, and fine particulate matter.

Other statements contained in the petition

Health Canada's "support" of the use of MMT

22. It is important to correct the statement in the petition that "Health Canada continues to support the use of MMT in Canadian gasoline." Health Canada's analysis of the scientific information on the health effects of MMT are contained in its risk assessment (available at www.hc-sc.gc.ca/air) in which it was concluded that "airborne manganese resulting from the combustion of MMT in gasoline-powered vehicles is not entering the Canadian environment in quantities or under conditions that may constitute a health risk."

23. Health Canada conducted the 1994 (and previous) risk assessments of MMT to respond to Part 5, paragraphs 68(b) and 68(c) of the then CEPA (1988) to assess whether or not a substance is "CEPA toxic" in the Canadian environment.

24. Based on the 1994 risk assessment, which reviewed the pertinent scientific literature on the direct health effects of manganese and MMT, Health Canada has no objection to the use of MMT in gasoline.

Peer Review of the 1994 document

25. The petition raises questions about the impartiality of "a member" of the peer review panel for Health Canada's 1994 Risk Assessment for the Combustion Products of Methylcyclopentadienyl Manganese Tricarbonyl (MMT) in Gasoline.

26. In relation to these statements contained in the petition, it should be noted that peer review is designed to draw on the expertise of those active in the area of enquiry.

27. In the case of Health Canada's MMT assessment, reviewers with significant expertise and considerable reputation provided their perspectives on the document. Health Canada is confident that the peer review process and the outcome are reliable.

Position taken by another organization on the use of MMT

28. As pointed out in the petition, a 1995 document by the Toronto Department of Public Health, entitled A Review of MMT and Manganese as a Public Health Issue recommended a phase-out of MMT from Canadian gasoline.

29. The authors of this report (Herrick, Weninger and Campbell) reviewed the same critical studies of the neurotoxic effects of manganese as were reviewed in the Health Canada document of a few months earlier (e.g., Roels et al 1987 and 1992, Mergler et al 1994, Iregren 1990, Wennberg 1991 and 1992). Herrick et al did not present a quantitative risk assessment, but reviewed those of Health Canada and of the United States Environmental Protection Agency (U.S. EPA). They concluded that both the approaches and results of the two organizations were similar. They did not dispute the Health Canada derivation of the reference concentration for manganese of 0.110 micrograms of manganese per cubic metre of air (µg Mn/m3). In fact, they described the Health Canada document as "an excellent scientific overview of the use and health implications of MMT in gasoline across Canada."

30. The recommendation for the phase out of MMT appears to be based on a policy of the use of alternatives when feasible. It should be noted that the Herrick et al document suggested that methyl tertiary-butyl ether (MTBE) was a feasible alternative for MMT as an octane enhancer in Canadian gasoline. It has since been determined in the United States that the mandatory addition of oxygenates in gasoline in certain parts of the United States has resulted in the extensive contamination of groundwater and surface water sources with MTBE due to leaky underground storage tanks and boat traffic. As a result, the phase-out of MTBE was recommended by a Blue-Ribbon Panel in the United States. This situation highlights the difficulty and necessity of assessing the advantages and disadvantages of any alternative, and the caution with which the introduction of an alternative must be approached. It should be noted that the amount of scientific information on the neurotoxicity of and exposure to manganese is substantial compared to the equivalent information on the toxicity and potential exposures associated with some of the alternatives.

Concluding Remarks

31. The Government of Canada appreciates the seriousness of the petitioners and other correspondents concerned about this issue.

32. Health Canada will continue its study of the scientific literature regarding manganese and MMT in the context of CEPA and will take, in conjunction with Environment Canada and stakeholders, any action indicated by the scientific evidence.


Annex A

THE PROCEDURES OF THE PETITION PROCESS UNDER THE AUDITOR GENERAL ACT

Subsection 22 (1) of the Auditor General Act states the following:

Where the Auditor General receives a petition in writing from a resident of Canada about an environmental matter in the context of sustainable development that is the responsibility of a category I department, the Auditor General shall make a record of the petition and forward the petition within fifteen days after the day on which it is received to the appropriate Minister for the department.

Paragraphs 22 (3)(a) and (b) state that the Minister shall consider the petition and send to the person who made it a reply that responds to it, and shall send a copy of the reply to the Auditor General within

1. one hundred and twenty days after the day on which the Minister received the petition from the Auditor General; or,

(b) any longer time, where the Minister, personally, within those one hundred and twenty days notifies the person that it is not possible to reply within those one hundred and twenty days and sends a copy of that notification to the Auditor General.

*[names withheld at the petitioners' request]