On the precautionary approach, I think it's a question of interpretation, and the interpretation that is most broadly held in the world is one that was developed during the Rio environment meetings in 1992. That is the interpretation that, I think, underlies much of the government's application or precaution. It's been the subject of a very wide department-wide consultation in the 1990s, and we think it's the right approach. So, yes, precaution is built into CEPA. It should be based on a commonly held view of what precaution should be.
On vulnerable populations, as I've said, I think they are already being taken into account. We would certainly be willing to consider the extent to which they should be further built into CEPA. We note that the government's paper recommends the preamble. That's something we will take a look at and can certainly provide you with a written comment on, if you wish.
On the NPRI, I said earlier that the act is static until reviewed. Things should be reviewed. So when it's ready in its cycle to be reviewed, I would certainly hope that we will have an intelligent conversation about how it needs to be changed. If that means some substances need to be added, some need to be dropped, thresholds need to be changed, we should have that conversation. I think CEPA already enables that. I'm not sure it's an amendment to CEPA that's required. It's common sense.
On industry data, ask my colleagues; we provide lots of it. I come back to this point about our being about 2% of the market. With regard to the Europeans' REACH approach, which is very data intensive and very expensive, I would think that every time that is raised in front of this committee, you should be asking the question, “Show me the evidence that it works”.
I have given you some evidence that CEPA works. If you judge it by whether we ban something, which is what virtual elimination essentially means, then I guess you would be more critical of its success. If you judge it by whether we've taken the actions that are needed to reduce environment and human health risks to the levels where they are acceptable, then I think it's a resounding success. Focusing on the extremes doesn't help anybody. I think we should be looking at the broad impact of the act and whether it's doing what it needs to do.
If I may editorialize just a little, I very much like Dr. Diamond's example of the gym. It's a perfect illustration of why a risk-based approach is needed. If you took a hazard-based approach to flame retardants, you might go down one path. If you take a risk-based approach, in your risk management discussion, you are able to consider what to do about the gym, if somebody raises it.