All right. My two-hour statement in 10 minutes, by the look of it.
In the case of road salts, the agencies understand that proper management not only conveys environmental benefits and can be done consistent with accomplishing the mission of keeping the roads safe, but it can also even save tax dollars by being able to put down road salts a little more conscientiously.
Designing a solution that allows society to derive the benefits of CEPA-managed materials is fundamental. We can't compromise the safety of the roads. We can't trade dead motorists for pine trees, we can't sacrifice workers' jobs for a park ranger's opinion that salt intoxicates birds, and we can't immunize governments against civil suits if they don't do their job of keeping the roads safe.
The bottom line is that we think the involvement of the stakeholders has achieved the momentum for implementation of the code of practice, which is getting the job done, which would not have been expected given the tenor of the assessment process.
Turning then, in my remaining time, to the issues of enforcement, why would we have enforcement? What we want really is the environmental result, so we want people to be encouraged, induced, to adopt the correct practices.
The Salt Institute has been engaged in teaching our customers sensible salting for about 40 years. We have sent out people to train the operators, because it's the operator in the cab who actually decides how much salt's going to go down. It's not the road agency itself, and it certainly isn't the salt company that, months before, sold them the salt. We really need to get training down to the operator level, and that's what we've been doing, in partnership with TAC and with the OGRA. And I think we have been quite successful, because we've been able to work cooperatively during the risk management phase with Environment Canada.
In terms of what we want to do, we don't really want to regulate something that is going to be so variable, because the weather, the topography, the service demands are set by locally elected officials. Those are all going to vary storm by storm, not only region by region. We need to give enough flexibility so that a regulation that is written can be applied in a real life situation, which is a life and death situation on the highways in the middle of a winter storm.
We do think that promoting compliance is going to be best done with a voluntary arrangement, such as a code of practice.
That moves us into the final point of appropriate tools. Right now, we have a code of practice, of course. Also, we have tools of the pollution prevention plans, where there's a regulatory arrangement. And we are engaged with Environment Canada in negotiating an environmental performance agreement for the salt industry to do its part in terms of producing the product and storing the product properly. But we don't see any need to move into a regulatory environment if you can get the voluntary situation to work, because, in our case anyway, there's a great deal of local variability in terms of what proper management is.
We believe the statutory process should encourage Environment Canada to promote risk management much sooner and focus resources earlier on doing a better job with environmental management. Where regulations may be required, the focus of the debate should be on the context of the substance that's creating the problem in the first place, as opposed to the name of the substance, which creates the stigma that we've testified about earlier.
Once again, with this approach we'll achieve a better environmental outcome. We thank you for your attention.