I think so. For example, PollutionWatch, in our submission, has recommended that mandatory timelines be placed in the act, at important stages of the act, so that action is taken at those stages, just as the categorization exercise was completed.
So going back to the question of how the in-commerce list should be handled--and I was being cautious until I knew I fully understood the proposal--I would say that the new substances notification process has some timelines in it, which is good, and the other attribute it has is that it places a greater burden of proof on industry to produce the data, which is of course something we're advocating.
Where I'm a little cautious is where things may move too fast, in a way that's not warranted. My understanding is that where a number of days pass--I believe it's 45 or 60 days in respect of a new substance--after an application to allow that new substance into commerce, where that deadline passes, the substance is automatically allowed into commerce. That's precisely the kind of approach we would like to avoid.
For example, where Europe is developing its REACH process, there will be greater, not fewer, obligations to submit data, not merely a timeline where, if you wait long enough, your substance can automatically enter in. So it is a very important issue, obviously, how to deal with timing.