In our respectful submission, it is risky to rely on a risk-based approach in regulating toxic substances in Canada. It is true, as the industry members have said, that CELA is based on risk, and risk is a function of hazard times exposure. I think I understand the industry position to be that if there is no exposure, there is no risk. I think the reality of the situation is that many hazardous substances available in the Canadian environment thought to have no exposure have proven to be very available in the environment. Using a hazard-based assessment approach that assumes there will be exposure, in our view, is more precautionary than is a risk-based approach, and that's essentially what has gone on in the REACH process in Europe.
Given the levels of toxic substances we are seeing being released into the environment, the data for some of which we've provided in our material today, in our view there is no alterative for Canada but to move away from a risk-based approach and move toward a hazard-based approach in the future if we're going to begin to reduce the levels of increases we are seeing currently in the data.