Thank you, Mr. Chair. To both you and members of the committee, I'd like to commend the work that the committee has done on CEPA so far. I think that work has been very comprehensive. I very much appreciate the efforts you've made to ensure that a broad range of perspectives is both heard and considered.
Along with my colleague, Dr. Kapil Khatter, I'd like to touch briefly on some of our key recommendations, gleaning from what some of the other organizations and individuals have said about them. We'll only touch on a few of these recommendations, with a more comprehensive list already having been submitted to the clerk and circulated.
As previously mentioned, in the last couple of days a letter from 721 Canadian scientists was tabled with this committee. That letter, which includes some of Canada's best-known scientific minds, endorses each of the recommendations that Dr. Khatter and I will be talking about.
In addition, I'd like to table with the committee another letter from a group of a dozen Canadian law professors who have examined this issue and supported these recommendations. They also recommend removing the barriers to citizen participation in CEPA. These barriers are so onerous that CEPA's citizen action provisions have never been used in the history of the act. We've provided this letter to the clerk, as well as a summary of each major recommendation, with a list of a very broad cross-section of organizations that support each one.
I'd like to talk about two of the recommendations, my colleague will talk about two more, and then I'd like to address briefly two other issues that have arisen.
The first recommendation I'd like to talk about has already been discussed briefly—that is, establishing significant areas for regions like the Great Lakes. CEPA explicitly recognizes the importance of an ecosystem-based approach, but there are no provisions requiring the government to address vulnerable ecosystems in Canada. The Great Lakes-St. Lawrence basin is where nearly half of the country's toxic air pollution is generated; 58% of the facilities that report to the national pollutant release inventory are located in the Great Lakes-St. Lawrence basin. We recommend that a new part of CEPA should be created to recognize significant areas that are environmentally important because they are large emitters of pollution or because they're particularly threatened by pollution. This part would then be used to recognize the need to address Great Lakes-St. Lawrence basin issues.
The second issue I'd like to address is the authority to regulate consumer products. CEPA has this authority, but the government has generally used the Hazardous Products Act instead. The HPA takes a product-based rather than a substance-based approach that is inadequate for addressing the sources and avenues of toxic chemicals in our environment. The poor track record on regulating lead in consumer products is an excellent example that was discussed yesterday.
CEPA should be the preferred authority to regulate toxic substances in consumer products, with a prohibition on the use of toxic substances in products and controlling their release where outright prohibition is impossible. Exceptions would be made where there are no reasonable alternatives or in cases where the substances would not be considered toxic when used in a consumer product. An obvious example would be carbon dioxide.
It's worth noting that the government's new chemicals management plan recognizes that consumer products are a major source of toxic substances that we should be dealing with in the regulatory system. It's time to ensure that our overarching pollution law is equipped to deal with this.
I should also mention that in addition to the scientists' letter and the law professors' letter, many organizations support this recommendation. These include consumer organizations, such as Option consommateurs, l'Union des consommateurs, the Consumers Council of Canada, services of the Alberta Council on Aging, and others; health organizations, such as the Canadian Cancer Society and the Ontario Public Health Association; as well as many other organizations that are in the document that we've just tabled.
I'd like to pass it on to my colleague, and I'll return to address two other issues.