Thank you, Chair.
We have a number of concerns with clause 3 as it's written.
First, the bill would take regulatory action on DBP and BBP without scientific assessments in support of that action. Risk assessments conducted in 1994 and 2000 found that DBP and BBP did not pose a risk to human health. Taking regulatory action without scientific evidence could result in legal challenges in trade disputes. Therefore, we're moving to withdraw references to DBP and BBP in clause 3.
We are, however, committed to reviewing new information on DBP and BBP. We will move to add a fifth clause to the bill that would commit the government to reassess DBP and BBP under CEPA. It will be amendment 15, which will be discussed further.
Secondly, as currently written, Bill C-307 would use CEPA to control phthalates in toys and other children's products. Again, these products are normally regulated under the Hazardous Products Act. We need to deal with the appropriate statute.
Our amendments would therefore replace clause 3 with one requiring the Governor in Council to make an order under the Hazardous Products Act to prohibit the use of DEHP products that could be put in the mouths of children less than three years of age.
Finally, Chair, the prohibition of DEHP for medical devices may result in effective devices being withdrawn from Canada. Alternative devices that are phthalate free have not yet been tested for all of the uses and, in some environments, are currently licensed devices. Without sufficient safety and effectiveness testing, these devices may introduce other safety risks to Canadians. No other country has stipulated a phase-out time for DEHP in medical devices. No other country has stipulated a phase-out time. We move to withdraw reference in the bill to regulations pertaining to DEHP in medical devices.
However, we're committed to phasing out phthalates in medical devices, starting with those used by the vulnerable populations, and they are children, pregnant women, and newborns. We will move to introduce other measures to meet those objectives. The objectives and motions are found in a new clause in amendment 15.
Thank you, Chair.