I think we might be wasting time talking about the wrong thing.
I have two things.
In terms of the specifics and getting to the pollution talked about in Bill C-30, we're willing to make that very clear and articulate that specifically in this amendment.
Second, we're not talking about eliminating these substances. The assessment that Mr. Moffet has made is correct. They have gone through a toxicology assessment, but they've never gone through a substitution assessment. It is important for committee members to realize that when we're looking at the ability to substitute something, there are a bunch of measures taken in. The predetermined conclusion is not that we're going to eliminate it; we're seeking to substitute it. We're chasing the wrong rabbit on this one.
If proposed paragraph 68.1(1)(c) is too broad and too extensive in terms of the Government of Canada's challenge to industry, then we're willing to remove it, but the concept of substitution to be built into this act when we're talking about air contaminants is actually quite important. It allows the government to do an assessment to ask if another substitution is available for this chemical. If there is, then the encouragement is to send industry down that path. If there is no substitution in existence—if it just doesn't exist—or if the substitution is deemed to be far too outside of the economic reach of the company, then it's also deemed not to be an option. But for heaven's sake, why, if we're talking about improving air quality for Canadians, wouldn't we seek a substitution analysis of the very chemicals we're talking about, rather than just saying there's a limit on the chemical you're producing? We know it's dangerous; we know it's harmful; that's the cap on what you can do. Why not ask the more fundamental question of whether there is anything else you can be using? Then you don't have to worry about a cap one way or the other.
Because I think there's some conversation going on, I'm going to suggest to the committee that we hold on this particular amendment and see if committee members want proposed paragraph 68.1(1)(c) out, and we're willing to do that. If they want a clear delineation of the scope of the chemicals we're talking about that relate directly to the Bill C-30 listing, that's fine, but don't toss the baby out with the bathwater on this one.
The concept of substitution is being used in REACH in Europe. It's being applied in many U.S. states. It puts us in line with many of our industrial competitors, and it's something we should consider.
Please do not confuse the concepts of substitution and elimination. This is not a game in which we go about trying to eliminate a whole series of chemicals willy-nilly; we're seeking out better alternatives to be used in the Canadian industrial process. That just seems intelligent to me.