Okay. Thank you very much. I'll try to be as brief as possible.
From this point on, we're largely going to focus in on the chemicals management plan. We've heard through some of the stakeholders' submissions that a lot of people spoke about the chemicals management plan, and really what launched it was some of the work that was done under CEPA and that's required under CEPA. I won't say that the chemicals management plan is all of CEPA or vice versa, but there's significant overlap between the two.
Essentially this all started, as Mr. Moffett said, when we took a look at substances on the DSL. We did a triage of all of those legacy substances that were added and were not subject to the new substances notification regulations. We came up with a list of 4,300 based on criteria, such as persistence, accumulation, inherent toxicity, and potential for exposure. We then had to go through and do screening level risk assessments on those 4,300 to see if more action was required from a risk management perspective, or if they were generally okay. If more action is required from a risk management perspectives, then we proceed down the road of adding substances to schedule 1 and taking those necessary actions.
For the chemicals management plan, it started in 2006. For the risk assessments, we're about two-thirds of the way there. There's some form of an assessment to the draft or final on about 2,700 substances, and we have that last tranche of about 1,500 substances that we are moving forward with in the remaining five years. That will bring us up to March and April of 2020 to have that exercise completed.
Over the years, we've had a lot of questions on how we do risk assessments of substances. We could do risk assessments for individual substances. We take one individual chemical substance, we take a look at the exposure of that substance and the hazardous properties of that substance, and ultimately we come up with an element of risk. We determine whether that risk is of concern either from an ecological perspective with specific individual ecological organisms, to the environment upon which life depends, or to human health. We pick from one of those three as we move forward.
What do we consider in terms of doing this? We consider ultimately the properties of a substance, its presence in different media—so air, water, soil, indoor air—and the range of effects associated with that. We then combine them.
I think an interesting point worthwhile noting—and we heard this in some of the comments that were raised through various submissions—is about vulnerable populations. I think it's important to note that we do consider vulnerable populations in this. We take a look at things from a human health perspective with children and pregnant women. We do take a look at exposures and routes of exposures associated with those most vulnerable populations.
We also look at persistence and bioaccumulation. This is an issue we've been faced with over the past few years. The persistence and bioaccumulation regulations that we do have are ultimately based on science of the nineties. Science has evolved since then. This could be an area for consideration. Does this have to be updated? We have now noted that there's accumulation not just in lipids, but also in proteins, and different jurisdictions around the world have adopted different levels. This is stuff for consideration as we move forward.
The other thing I'd like to raise is that I mentioned initially that we could do individual one-off assessments, so one chemical at a time. While we don't really do what we call alternative assessments, we have done grouping assessments over time. We've looked at chemical substances and grouped them based on their structural similarity and their use profile. Could they be used more or less interchangeably? We have done some element of assessment along those lines, particularly under the CMP, and that has allowed us to be more efficient in the number of substances that we assess, but also to be more inclusive of the fact that some of the exposures can be cumulative over time.
This is slide 21.
I think this is another question that we get. People will ask us, do we have tunnel vision? Are we uniquely focused in on those 4,300 substances that were identified by DSL categorization?
The answer to that is no. While that is a large focus of our efforts, we do have what we call “a triggers document” that focuses in on different pathways to identify substances that should be considered either for assessment or for reassessment. If you take a look at these boxes, you'll notice, for example, there's emerging science. We have new science that was pulled together. This is something that we could consider with regard to a certain class of substance.
Section 70 of the act requires people who have information to reasonably believe that a substance could be toxic to submit that information to us. We routinely get submissions on that.
Internationally, we work very closely with the partners at the OECD and the U.S. EPA, so there's always a sharing of information there, so data from either domestic or international organizations and review of decisions in other jurisdictions. Sometimes we see trends through the new chemicals program. We see certain classes of substances being notified and we see if there are any linkages that could be made to substances already on the DSL. That helps them inform the science as we move forward with that.
There are also CMP assessment activities. So maybe we did a one-off assessment activity on one substance, now we're doing a class of substances. We may want to bring in these other substances, and we'll have a richer data set to help inform what the risk associated with that substance is.
There's also a significant new activity notifications, what we call the SNAcs, and that is ultimately a tool that is implemented on a substance, and that allows us to say, we're good with this use, but if you want to use that chemical for another use, you have to notify us of that use. As we get that information, then we get a sense of appreciation of the additional tox data that could be submitted, as well as other uses. It allows us to go through and maybe look at other decisions that we've made in the past.
I think the question that a lot of stakeholders have had and a lot of partners have had of us is, so you do this and what ultimately does it result in?
We have publications available on the chemical substances website. A 2015 data review was done to make a lot of this transparent to stakeholders. It reveals about 2,600 substances that were flagged for various reasons. We took a look at those and put certain filters, if you want, or certain criteria to say, okay, there could be a high-hazard profile to it, is it even in commerce in Canada and in what quantities? We took a look at it, and of that we flagged about 260, so about 10% of the substances that we flagged, and we said, those ones require a bit further merit.
If you're wondering how we broke those down, there were about 195, of them for which we said we should probably have further data gathering activities on those, so routine updates in terms of what their commercial status is. That's going to be a mandatory information gathering under section 71 of the act. There were 28 of them about which we said we have to integrate those with our ongoing risk assessments, based on some of the information that was flagged. So we've added those in moving forward with it. There were 27 of them about which we realized that activity is going on internationally in other jurisdictions, let's get a sense of what's going on, what conclusions they're coming to and let's follow that, so we're aware. All that to say, of those 2,600 we're actively following, there are 10% of them for which there are going to be further active follow-ups on.
In the interests of time, I will skip to slide 26.
Here, we're sort of in the annex, and it's probably worthwhile noting stakeholder engagement that we've done on the chemicals management plan. I must say that when we do meet our international partners, this is something that they are very surprised with, the degree of stakeholder engagement that we have on the chemicals management plan and the way we involve our stakeholders.
Naturally, under the act, we make decisions, we publish a draft risk assessment, a draft risk management document, etc., and there are mandatory 60-day public comment periods on that. But above and beyond that, we have many different points on which we involve stakeholders. We have early stakeholder engagement many months in advance, notifying stakeholders that we will be assessing or taking a look at certain classes of chemicals. We publish notices of intent with lists of substances that enable industry to contact their parent companies abroad, or their foreign suppliers, to say, we are likely going to need data on these substances.
Over the past two years, we have had four multi-stakeholder workshops that were organized, which were open to any stakeholder who wanted to participate. At those, we introduced some of the work we're lining up as we move forward with the chemicals management plan. We described the assessment activities, the risk management activities, the information gathering activities. We got a lot of valuable input from participants in those workshops. They are attended by stakeholders from industry and human health and environmental NGOs.
We also have more formal engagement mechanisms. For example, we have a CMP stakeholder advisory council that consists of aboriginal participants as well as industry, NGO, and some advocacy groups. That is ultimately to provide the government with advice on how the chemicals management plan is being implemented. This committee has been ongoing since 2006 when we launched the chemicals management plan. It's a very valuable committee. It provides us with that input. We use them as a sounding board.
We also have the CMP science committee that I think is incredibly valuable. We have had that under different forms since almost the beginning of the CMP. That is a science advisory body. We have experts from academia, from the NGO community, from other regulatory agencies, who come forward and provide us with expertise on specific questions that we may have. John spoke about CEPA NAC, or the national advisory council.
I guess the other is on slide 27, which focuses in on some of the international engagement. I mentioned that earlier on, but I can't overestimate the importance of a lot of these partnerships, either work that's done with U.S. EPA, with the European Chemicals Agency, other members of the Organisation for Economic Co-operation and Development, which have various task forces under there, such as the hazard one, the exposure task force. These all help us strengthen a lot of our assessment techniques, our modelling techniques, that are used to have robust approaches that are internationally recognized.
My apologies for going a bit over time. Thank you.