Sure.
No, CEPA doesn't appropriately manage the risk. For many different criteria, as Dr. Dayna Scott put it, we have the least protective standards in the industrialized world. For example, our regulations for persistence and bioaccumulation are the least protective in the world. We allow much higher levels of persistence and bioaccumulation before we regulate, compared to other industrialized countries.
On the substitution principle, in my mind there are many paths to the top of the mountain. One way to get to the substitution principle is pollution taxes. You make it more costly to use the more dangerous substance. You harness the power of the market. There is an exciting field called green chemistry.