Thank you very much.
Good morning, Mr. Chair and honourable members of the committee.
My name is Marion Axmith. I'm the director general of the Vinyl Council of Canada, which is a council of the Canadian Plastics Industry Association. I've been with CPIA for 24 years and I've worked on the Vinyl Council managing the Vinyl Council for the past 14 years.
Our members include a wide range of companies, from resin producers to additive suppliers, compounders, processors or manufacturers, and recyclers. The Canadian plastics industry is about a $51-billion industry. It employs approximately 150,000 Canadians.
The Vinyl Council members are members of a responsible industry within Canadian society. In 1999 we launched our environment management program to manage and reduce our environmental footprint. The program is a commitment to manufacture vinyl products in a safe and environmentally responsible manner. It is our road map to ensure we protect the environment and health during manufacture, use, recycle, and disposal of our products. We continually improve our performance. We strive for sustainability and we improve our capacity to listen to all our stakeholders.
We are here to speak to you about Bill C-307, which is an act to prohibit the use of three phthalates—BBP, DBP, and DEHP—in certain products. We are here to argue that Bill C-307, in its current form, is not necessary, as it circumvents the existing CEPA process for evaluating the safety of chemicals in Canada.
Incidentally, Canada has one of the best screening processes for chemicals in the world today. As I'm sure you're aware, CEPA has already screened 23,000 chemicals over the past six years or so. They've identified 199 of these for further review, and none of these phthalates, which are the subject of this bill, are on that list. They're not on that list because they have been assessed and they are not substances of concern.
What are phthalates? You've heard Dr. Cammack talk about DEHP, but generally phthalates are a class of compounds used mostly with a plastic called vinyl to make that plastic soft and flexible without compromising the strength of the vinyl. As Dr. Cammack said, DEHP has been used safety in medical devices for almost half a century and it provides many very useful benefits, including flexibility, a resistance to kinking, and the ability to withstand harsh sterilization methods while at the same time remaining very cost-effective.
Of the other two phthalates, BBP is most commonly used in flooring, carpet tile, caulking, and sealants. DBP is actually not used in vinyl at all and it is not found in children's toys. The main use for that one is in adhesives, cosmetics, and mostly nail polish.
On DEHP, Dr. Cammack covered the medical devices side. It is used in some plastic toys, inflatable toys like beach balls or water wings, that sort of toy, but it is not used in toys that are put in the mouth by children.
The product that keeps coming up and keeps getting mentioned is teethers. Most of the teethers made in Canada today are not made from vinyl. They do not have phthalates in them. They're made from silicone. So phthalates used primarily in vinyl are a very important part of our everyday lives.
In the next slide in front of you we've covered most of the benefits of the product, so I'll move directly to page 6.
Industry's perspective is that science should prevail here. We feel it's very important to remove this debate from the political arena and move it to the scientific and medical arena, where it can be properly studied and reviewed. The weight of scientific evidence to date demonstrates that bans on phthalates are unnecessary to protect human health.
As you're aware from your March 20 meeting, Health Canada has expressed concerns about the legislation as it is currently written, and I'd simply like to take you through some quotes that I pulled out of the transcript of that meeting from Mr. Paul Glover, who is the director general of the safe environments program of Health Canada. These are quotes and these are some of the things Mr. Glover said at the March 20 meeting:
The risks posed by these substances to human health and to the environment were formally assessed under CEPA. The assessments for BBP and DBP were published in 1994 and in 2000 respectively. Both of those were found not to be CEPA-toxic, and therefore no further action was required under CEPA. That was primarily on the basis of exposure, or the lack of it.
...we also have no long-term safety data on the alternative chemicals used for medical devices. It is important to note that some phthalate-free medical devices have not yet been tested for all of the same indications of use as if they had phthalates in them. Therefore, it may not be suitable to simply substitute these.
So the Vinyl Council would respectfully like to put on the table two proposed amendments to this bill. The first one occurs in clause 3, to amend that, on page 1 of the bill, by replacing lines 9 and 10 with the following:
the coming into force of this Act in accordance with the Canadian Environmental Protection Act, direct Environment Canada and Health Canada to review the use of the three phthalates: BBP, DVP, DEHP.
The second amendment refers to clause 3 on page 2, by deleting lines 9 and 10, which in effect would delete “medical devices” from the bill.
In summary, I want to stress that the Canadian plastics industry is a very responsible sector. We care deeply about the health and safety of Canadians. The Canadian public is our clientele. Canada has one of the best screening systems in the world for assessing chemicals, and we are asking that CEPA and the CEPA review process be allowed to work. Use this excellent system that the government has put in place.
We cannot make policy based on rumour, innuendo, and fear-mongering. Follow the science, use the excellent CEPA screening system that already exists.
Thank you, Mr. Chair.