Thank you, Mr. Chair.
Let me just fill in to cover three of the recommendations we've brought to the committee. One was touched on, and that is virtual elimination. CEPA recognizes that persistent and bioaccumulative toxic substances need to be virtually eliminated. Only one substance to date has been put on the list. The need to determine a minimum level of quantification is one of the barriers to that problem.
We've been recommending that CEPA needs a definition of virtual elimination that is consistent with the Great Lakes water quality agreement; that virtual elimination should include the cessation of intentional production use, release, export distribution, and import; and that it needs to be revised. We don't necessarily need a precise minimum level of quantification. We support the idea that elimination could be done in other ways, for instance, using the prohibition regulations. But we emphasize that these substances need to be eliminated or prohibited, not just risk managed.
Another issue we've been presenting is the need to change the burden of proof. There is little data from the majority of what we call the “existing substances”--the 23,000 substances that were in commerce up to 1986. In fact, about 10% of them have experimental data. For these substances, the onus is on the government to prove they are harmful--before taking regulatory action. That kind of onus is something we're moving away from. The Pest Control Products Act, for instance, places the onus on manufacturers to demonstrate relative safety before products can be on the market.
What we're looking for is burden of proof language in CEPA that is similar to that of the Pest Control Products Act. There should be a reverse onus, where industry must demonstrate substances and products are safe enough to be used. If there's no data, there should be no market.
Finally, we've also been talking about the need for mandatory timelines. Though parts of the assessment and management process have timelines--relatively loose ones--there are some major gaps. As a result, delays result in years of inaction on substances of concern. The categorization of the domestic substance list that was just completed demonstrates how effective deadlines can be in ensuring that substances are dealt with.
The solution is that CEPA should have mandatory timelines at every stage of the assessment and management to ensure that potentially harmful substances are quickly assessed and action is taken to protect our health and the health of our environment. We have circulated a list of our consolidated recommendations. In there are the details of our proposed timelines.
As Mr. Freeman talked about, these recommendations have been supported by a number of groups. Please look through the submissions and presentations, including the Canadian Cancer Society, the Canadian Association of Physicians for the Environment, the medical officer of health for Toronto, Peel Public Health, and the scientists' letter and lawyers' letter we talked about.
Thank you.