Mr. Chairman, I do have five minutes and then unfortunately I have a flight.
The CEPA process is very good in principle. I think the fundamental guts of the documents, in my opinion, are sound. The problem comes with its implementation. It's heavily based on risk assessment and risk communication, risk management, not on risk reduction, and very little evidence of the application of the precautionary principle, on which it's based. So there's a lot of risk communication, and a previous member asked again whether the public is adequately informed.
It's very frustrating to speak to some of the individuals associated with trying to implement actions under CEPA when one hears that a predominant strategy for risk reduction is risk communication. It's not actually reducing exposure. It's not actually implementing a precaution. It's just communicating to people that there are dangers associated with exposure to certain substances.
“Relative risk” is a term that's extremely confusing. One must remember what risk is voluntary and what risk is involuntary. So when we hear about relative risk, we hear, well, what's the risk of exposure to this substance in a product compared to the risk of flying or crossing the street, which are voluntary actions.
The risk of exposure to a chemical in a product is a problematic area for CEPA. Some of the substances we've been talking about today are in products. Mercury is in thermometers. Mercury is highly neuro-toxic. But under CEPA, you can't regulate the mercury in thermometers because it's a product.
Synthetic musks that are in all the stuff that you used today when you got up and took your shower, such as the soaps that have no purpose except cosmetic--some of which are endocrine disrupters, and others may be carcinogens--have no function. Yet we can't regulate them under CEPA because it's in products. So regulation of chemicals in products is something CEPA needs to grapple with.
And there are actual pollution prevention actions and initiatives that demonstrate adherence to the precautionary principle.
Those would be three major areas.
Finally, on the monitoring piece, which the previous member had asked about, monitoring does need to be improved. I know that the health ministry would probably welcome the appropriate level of investment in monitoring and toxicological studies to understand what the threats to human health are and what the trends in body burns are over time.