Thank you.
It's true, as Mr. Teeter points out, that once the ministers responsible for CEPA announce their intention to list a substance on the list of toxic substances they have two years, and then there's a further one and a half years to develop and implement. So it really is a three-and-a-half-year timeline to develop and implement a regulation or other control instrument, which he also correctly says could be voluntary as well as regulatory.
Mr. Hamilton suggested that part of the scheme whereby a new list is created would somehow make it easier to have a voluntary approach. In fact, the existing act already allows for a voluntary approach to be taken as the sole control instrument. Our position--for three reasons--is that the act should be modified so that regulation is a mandatory centrepiece of what's developed in that plan. In other words, a voluntary measure alone cannot stand.
Those reasons are: first, it's been shown that a regulation provides the greatest motivation for change; second, it provides the certainty that industry always seeks; and third, it's the most effective. We would add, as we have advocated, that there be a requirement for substitution of a substance that's been found to be potentially harmful, and in respect of which a regulation is in place. So a substitution, as is the case in other jurisdictions like Massachusetts and California, is part of the process. It's a spur of industrial innovation that has economic benefits as well as the obvious environmental ones.