I'll be very quick.
One is timelines. The characterization process worked because there were mandatory timelines and resources. These processes go on forever unless there are clear timelines.
The second is building on the precautionary approach--what I think you've been calling “reverse onus”--but I think what's important is that for chemicals that are on the market you need data, and there must be a requirement that the data are provided.
A third is that you need to balance so that new chemicals and old chemicals have the same regulatory burden. It's good to require data for new chemicals, but if you're not also requiring data for old chemicals, that creates a barrier.
Fourth, the failure of CEPA to include chemicals in products has been a severe limitation. There are a lot of examples I could go into if we want to go into discussion, but much of the chemical exposure--certainly in health exposure but also environmental exposure--stems from chemicals in products, and CEPA has very weak powers with regard to chemicals in products.
Finally, on the special recognition of vulnerable populations and vulnerable ecosystems, and with regard to those, the two that should be singled out for special mention are the Great Lakes ecosystem and the far north. Again, on the reasoning for that, I can go into more detail. In the far north, people are being highly exposed to chemicals they get no benefit from whatsoever, just by long-range transport, and the same process is going on in the Great Lakes. Those are having, in both regions, profound health effects.
Thank you.