Absolutely. There is a problem of missing data, or as the substances are referred to, “the uncertain substances”, because we don't know. That's an issue primarily with the existing substances that have just undergone the categorization process.
I would argue that even with the new substances that do have to submit a data set, as I mentioned, there are areas of that data set that could be strengthened, and one that comes to mind is chronic toxicity, which would indicate a lot of carcinogenic effects. So this is something that is not adequately dealt with in the new substances regulations.
With respect to the existing substances in the categorization process, as I mentioned, where there is not enough data to indicate toxicity, bioaccumulation, and persistence with the high exposure, the substance is not looked at further. So those are a certain set of criteria, and either because there's no data or it's of an extremely poor quality, if there's not sufficient indication that those criteria are met, then the substance does not get categorized and therefore doesn't move on to the next more in-depth assessment phase.
So I would say that would not be an example of a precautionary approach, because those substances that are fundamentally missing data may still pose significant threats to human health or the environment.