Good morning to all the members of the committee.
We want to thank you very much for the opportunity to speak to you today. We have prepared a presentation in both official languages that I think was distributed, but I'm not going to read it. I simply want to touch on some of the highlights in my comments with you today.
I'm joined by Beta Montemayor, our director of environmental science and regulation at the CCTFA. As a trade association on behalf of our industry, we have been very much engaged. Beta has led our efforts in working with the CMP process over quite a number of years now and has a great deal of experience in this particular area. He is here today should you have any specific questions.
Our industry is cosmetics and personal care products, which covers everything from colour cosmetics to fragrances, moisturizers, sunscreens, cleansers, shampoos, anti-perspirants, toothpastes and other oral care. It's products that you use every day. We are downstream product users, as Shannon Coombs' association is. The producers of our raw materials have spoken to this committee earlier, but it's important to note that we are engaged in this process because our personal care and cosmetic products are, in essence, regulated both as products through the Food and Drugs Act and as ingredients that go into them through CEPA.
Many of the decisions that have been made over the last number of years on specific substances have resulted in changes, for example, to the cosmetic ingredient hot list that guides what substances can be put into cosmetics. The results of the work of CEPA affect us very directly and we've been very engaged in that process.
I want to pick up on something that my colleague mentioned about this program and its importance in relationship to the wider world. It's very easy to come to a program and look at it and point out things that may be shortcomings. Every program has shortcomings. In another life, I served in a provincial legislature and was responsible for regulatory departments and sat on your side of the table, so I came to appreciate in those days that what's very important for any particular program is context.
I think what's important to look at in our chemicals management program is context. This program is one of the leaders in the world. If you look at what was in place prior to the chemicals management plan, over a 10-year period I believe some 75 substances were reviewed. It was slow and cumbersome and not very good at serving the needs of Canadians, their health, or their environment.
Since we've had the chemicals management plan, as has been pointed out, some 21,000 of the 23,000 existing substances have now been assessed; 4,300 priorities were identified; and while all that was taking place, any new substance entering our marketplace was also assessed.
When you compare that context to what existed before, you really have to say that this has been an incredible program despite whatever shortcomings with it may be identified. As well, when you compare it to other parts of the world, the European Union with their REACH has a somewhat similar program and some differences and issues there, but Canada and the European Union are really two of the major world entities that have this kind of program. The United States doesn't have it, and are facing quite a dilemma and issues there with regulation happening at the state level and frustration at the national level and, some would argue, a real mess.
When you compare what we've been doing in Canada to the rest of the world, this program is truly a world leader in this area. It's not perfect, but certainly, when compared and put into context, it's a great success.
From our perspective—and I think we've highlighted this in our documents—what has really made this an envy of many jurisdictions is that it is risk-based. It does look at the intrinsic properties of substances; it does look at inherent hazards, and also at exposure, which is a critical part of the risk assessment process; and it determines whether or not there is, in fact, a real risk and what is the best way to manage that risk.
Making regulatory decisions based solely on one element in isolation of the other elements that need to be considered would be overly simplistic and inappropriate, and would potentially lead to misleading conclusions that could prohibit innovation and access to chemistries that are safe in reality. So we have a lot of those principles generally right in our system and they have, as I said, really been the envy of the world compared with other jurisdictions.
We also think the use of science and the weight of evidence is really important . What has been just so strong about the Canadian chemicals management plan is that not only does it look at the potential risks, the potential safety for the environment and human health, but also digs down and is able to assess if this is real It looks a real world data not just theoretical risk, and it's able to make conclusions and suggest or put in place risk management that is appropriate to real world risk.
When we were looking at what others have said about this, we thought it would be well worth us—and would highly suggest that the committee do so too—to look at the board of review process for Siloxane D5, which happened some years ago. It was carried out by three very prominent scientists who headed that board of review. They looked at evidence, had two weeks of hearings here in Ottawa where every interested stakeholder could make presentations and present the science, and they came out with a finding. However, what was very interesting is that they came out with some observations the about process, which were referenced recently in an article in the Huffington Post. If I may just conclude this with its comments:
Like the scientific process itself, this approach to regulation encourages good faith skepticism, honest debate, and confidence in the regulations themselves. Most people, whether in Canada, Europe or the United States, understand that government investigations may be based on suspicions, but regulations must be based on science.
Despite whatever issues there may be and that no system is perfect, Canada did generally get this right with this program. It has a legislative mandate to complete its review by 2020. We would strongly suggest that it be allowed to do that, and then it can be fully assessed with improvements made going forward to where we want to be after 2020.
Those would be our comments.
I hope, Madam Chair, I have kept to the tradition of being within the 10 minutes.