The structure of the act is such that it requires risk assessment first, before actions are taken. There is a conclusion of harm, or toxicity in this case, under the section 64 definition of “toxic substances”.
What I'm recommending--and you might be able to do this simply with an attitudinal change in Environment Canada--is that as the substance is being assessed, you also ask what is happening with risk management. What is happening out there in the real world, not in Ottawa but in the real world, to manage how this substance is actually being used in the environment? You might be surprised with the answers you get. If the answers tell you there are actually some positive environmental actions taking place now, you start working with the stakeholders on those at the same time as you're assessing. It seems to me to be common sense. The resources would then be deployed in a way that quickly stimulates positive environmental actions.