The issue of environmental justice was raised not only today by you, but also in the testimony in March, so we've had an opportunity to think about it.
Our understanding of the position of the industry representatives at the time was that, in their view, such considerations were already said to be built into the act. Now, we don't agree that this is in fact the case, and is certainly not in the wording of the statute itself. In our view, if the process of incorporating environmental justice considerations is already taking place in the regime, then it would be a very simple matter to add it to the statute so there is correspondence between what is happening behind the scenes and what one sees when one reads the legislation.
To address specifically how to do it, one of the precedents we have had in Canadian law for quite a number of years now has been the provisions in the Pest Control Products Act that begin to address the issue of what needs to be considered, not only during the course of applications for new chemicals but also in re-evaluations or special reviews. One place to look for a precedent on where to start would be the Pest Control Products Act itself.
I think as a principle not only does it need to appear in the declaratory portion of the statute, but it also needs to be infused throughout the provisions. It needs to be part of the purpose and part of the working statutory language as you work your way through the statute itself. Also, of course, it needs to be reflected in the regulations that would apply to the particular areas of concern.