I have never seen an alternatives assessment in Environment Canada or Health Canada risk assessments under CEPA. Maybe the industry is doing it. Risk assessments aren't defined in how they're done under CEPA. They're done completely outside the act. It is used to determine whether it meets section 54 toxicity requirements.
They're not laid out in terms of how they're conducted. I'm suggesting that CEPA give you instructions on how to do risk assessments, potentially even set some hazard threshold—