Sure. I'll answer the first question and then I'll ask Mr. Carreau to answer the second question.
The first question had to do with virtual elimination. Your perception, as I understand it, is that PFOS has somehow fallen through the cracks. I hope to allay that concern. What the government has done is proposed a regulation to prohibit the use of this substance. Prohibition goes well beyond virtual elimination, but the way virtual elimination is defined in the act it's a virtual elimination of releases, not a virtual elimination of uses. That's an artifact of the way the act is written. This committee is currently conducting a review of CEPA, and it may want to look at that, but the way the act is written now, it's a virtual elimination of releases.
There are various problems with the way the act is constructed now. One of them has to do with the requirement that in all cases, a substance that is identified for virtual elimination must have a level of quantification; it must have a ministerial release limit regulation. As I think we've all agreed, that's not always appropriate. Virtual elimination may be appropriate for substance A, but you may not need a release limit regulation. If you're going to prohibit the substance, you don't need to limit it. You don't need to also regulate its releases. CEPA doesn't give us that flexibility right now. That's a problem, in my view, that this committee may want to address, probably not through this bill hearing, but through the CEPA process.
Another problem that Dr. Khatter legitimately raised is that the bioaccumulation regulations didn't catch this substance, so this substance doesn't bioaccumulate in accordance with the criteria established by the bioaccumulation regulations that have been developed under CEPA. We know that's the case, and we're currently revisiting those regulations. We don't need to change CEPA to do that; what we need to do is revise the regulations. We're currently in the process of revising the regulations that define the criteria for bioaccumulation to allow us to address this problem.
Now, to be perfectly candid, that hasn't been urgent, to date, because we didn't want to catch ourselves in the virtual elimination bind, where if it had satisfied the B requirement, the bioaccumulation requirement, we would then have had to go down the route of an LOQ and a release limit regulation, when what we really wanted to do with this substance was ban it. So we need to fix the statute and then we can identify more things as PBiTs and slate them for virtual elimination, but allow the government to do the right thing for each substance, as opposed to locking us into one certain route that may be appropriate for some things but not others.
I'd be happy to go into more detail, but let me stop there and turn to my colleague to answer the question about the rationale for--