Thank you, Mr. Chair.
Thank you for your question.
The proposal we've suggested, of removing the word “toxic” and changing it to “assessment and management”, we really believe is a credible position to put forward for the committee to consider, because that's what the act does. An assessment is done on a particular use, and that assessment reflects the findings. If the findings determine that, yes, it does meet the parameters of section 64 of the legislation, then it goes on to schedule 1 and risk management is undertaken.
The challenge we have is that what the public perceives as being intrinsically toxic, poisonous, or lethal is not necessarily what is being risk-managed on that list. I think ammonia is a very good example, because ammonia is being targeted. We do have some examples--I can certainly provide those to the committee--of websites where it's posted that ammonia, a CEPA toxic, is used in glass cleaner. It doesn't mention anything about the risk assessment with respect to the aqueous environment and the ammonia found in waste water effluent. It simply says it's used in glass cleaner, so don't use it. That's the challenge we're dealing with.
I don't think it's an inconvenience for industry. The challenge we have is that some of the other regulators, such as B.C., have said in their documents on procurement criteria that you must not have any substances that are on schedule 1. Well, if people don't understand the context, the risk assessment of ammonia, then they would just say, “Oh, ammonia is used in glass cleaner, so I can't use glass cleaner.”