Environment Committee on April 21st, 2021

[The Chair, Liberal, Francis Scarpaleggia]

I call to order this 26th meeting of the Standing Committee on Environment and Sustainable Development. We are continuing with our study on plastics.

For the benefit of witnesses—because all the members know this already—when you're not speaking, please put your system on mute. When speaking, please speak through the chair. You may speak, of course, in either official language. That's about it.

Members, I would like unanimous consent to end at 5:30 even if the bells start at 5:15. The vote is at 5:45. We don't have far to travel to vote. If that's okay, then we'll end it at 5:30.

[Some hon. members]

Agreed.

[The Chair, Liberal, Francis Scarpaleggia]

We have five witnesses with us today. One, I believe, is in the process of joining. Each witness will have five minutes for opening comments.

I think we'll start with Professor Curran, if that's okay.

[Deborah Curran, Executive Director, Environmental Law Centre, University of Victoria, As an Individual]

Thank you, Mr. Chair

The Environmental Law Centre is an organization that works within the Faculty of Law at the University of Victoria, and has done so for 25 years. We provide over 6,000 hours of pro bono legal services to community groups, indigenous organizations, and citizens each year.

In 2017 we met with three then members of Parliament at their request—the Honourable Gord Johns, Murray Rankin and now Minister Jonathan Wilkinson—to discuss our client’s increasing concern with plastics, and specifically the impact of single-use plastics in the ocean, the freshwater environment, and as a largely unregulated waste. As you know, since then the plastics issue has exploded.

As a lawyer I am not here to address the pollution issue for you. You have plenty of evidence in front of you regarding the pervasive and invasive presence of plastics in every part of our food chain, hydrologic cycle, and in our land. Clearly we need to stop unintentionally treating our communities and natural environment as a dumping ground for low value, persistent plastic particles.

We are supportive here at the ELC of many aspects of the proposed integrated management approach to plastic products to prevent waste and pollution, that is, the approach set forth in the federal government's discussion paper. In particular, we agree that banning and/or restricting of harmful single-use plastics is a priority, and support the proposal to establish minimum recycled content for plastics producers. We also support the Government of Canada’s commitment to work with provinces and territories to promote extended producer responsibility.

Following on the work completed through the Environmental Law Centre, in particular by my colleague Calvin Sandborn, Q.C., I will address the specific purpose of this committee hearing, a ban on single-use plastic items and designating plastics under the Canadian Environmental Protection Act, 1999. We have produced three reports on this issue more broadly that can be found at elc.uvic.ca. I will include in my written submission to the committee all of the links and direct you specifically to our commentary on regulating single-use plastics.

I have three recommendations to highlight for the committee today. The first one is regulating single-use plastics. Some call it a “ban”, but in law we understand it more as “regulating” because, typically, we ban substances or activities and then we create exceptions for them or create conditions under which they can be used. Creating a regulation of a broad range of single-use plastics, what are traditionally single-use plastics, under CEPA makes perfect sense. Everything from adding polypropylene, polystyrene, and hard-to-recycle plastics or particular products to CEPA in schedule 1 and enacting regulations to control the way we interact with them in Canada makes perfect sense. That would certainly reflect a 21st century understanding of environmental law and regulation. When we do that, then we could reduce and/or tax the importation of products that contain these substances and also control the way they're used in manufacturing.

My second recommendation is to establish meaningful recycling standards that would give direction to the plastics industry and anyone who is interacting with plastics about what kinds of plastics are welcome to be produced and always reused in Canada. We want to get away from this approach where whatever the client wants, the client gets in terms of plastic production, and go to a much more streamlined range of plastic production that can be reused over time. These kinds of regulations involve mandating a minimum quantity of post-consumer plastic content in all plastic products from these listed substances, and improve the reusability and recyclability of products made from these materials. There are lots of other ways that this can brought about as well.

My final recommendation is for the Government of Canada to really take a long-term view of this, given that the persistence or legacy of plastics in our environment will now we be with us for thousands of years. A long-term approach would commit to a 21st century view of environmental regulation that includes taking a circular economy approach.

Therefore, any ban or regulation of single-use plastics has to take place within a larger plan for bringing the Canadian economy and how we do environmental regulation up to date. We still use the principle that dilution is the solution to pollution, but our environment can no longer withstand that approach.

[The Chair, Liberal, Francis Scarpaleggia]

You have another 10 seconds and then there will be opportunities to answer questions and get points across.

[Deborah Curran]

That's fine. Thank you.

[The Chair, Liberal, Francis Scarpaleggia]

Thank you, Professor Curran.

We'll go to Dr. Misra for five minutes.

[Dr. Manjusri Misra, Professor and Tier 1 Canada Research Chair in Sustainable Biocomposites, University of Guelph, As an Individual]

Thank you, Mr. Chair, and to the entire committee for inviting me.

My name is Manju Misra. I am a professor and tier 1 Canada research chair in sustainable biocomposites at the University of Guelph.

I would like to say a special hello to MP Longfield, who has visited our lab, the Bioproducts Discovery and Development Centre, on many occasions and is familiar with our work.

Sustainable materials development for green manufacturing supporting the circular economy is the focus of our centre. Currently, the world produces around 450 million tonnes of plastics per year. That will double to about one billion tonnes per year by 2050. Today, 50% of the plastic produced is for single-use only. This is why I believe that action on single-use plastics destined for landfill is critical. When left in the environment, plastic does not biodegrade, but instead breaks down to smaller parts, including microplastics, and has a devastating impact on ecosystems, which we all know. About 90% of Canada's plastic waste is not recycled or recovered. We need alternative solutions now.

The Ellen MacArthur Foundation's new plastic economy initiative has set actionable targets to reach 100% reusable, recyclable or compostable plastic packaging by 2025. The good news is that leading Canadian companies have joined this initiative through the Canada Plastics Pact. To support these efforts, our research at the University of Guelph focuses on using biodegradable and compostable materials as commercial alternatives to single-use plastics.

For the committee's consideration, I would like to highlight three key material segments that should be targeted. These represent over 80% of the single-use plastic waste.

The first is packaging with mixed materials that combine plastic, paper and metals. Examples include single-serve coffee pods, yogourt and ice cream containers, and recyclable packaging with glued-on labels, which are destined for landfill. Our centre facilitated the successful launch of the world's first fully compostable coffee pod with Canadian industry partners Loblaws, Club Coffee, Competitive Green Technologies and Fourmark. It's a classic example of industry-academia collaboration with support from the government. So far, over one billion of these compostable pods have already been used in Canada.

The second segment is multi-layer protective films that recycling facilities cannot separate and therefore don't get recycled. Examples include Tetra Paks, chips and cookie bags. Our centre has developed a compostable solution with extremely high barrier and improved shelf life for food and pharmaceutical packaging.

Third and most importantly are items that are impractical to recycle even though they are mono-materials, like disposable cutlery, straws and takeout containers. Compostable alternatives exist and work is under way at our centre, with some products already in the marketplace, such as straws and stirrers.

Targeting compostable alternatives in these three areas is a real opportunity to position Canada as a global leader in sustainability, which would result in economic prosperity for all Canadians.

Achieving what I have just outlined requires investment to create innovation in the existing manufacturing and packaging industries; re-tooling as needed; infrastructure development for the end-of-life disposal; modernization of industrial composting facilities; and government-led requirements for certifications and labelling. Finally, skilled HQP development, along with consumer education, is essential.

The government, through policy and incentives, can accelerate this much-needed transition to sustainable resource management and a healthier environment.

Thank you for this opportunity on the eve of when we all in the world are observing Earth Day.

Thank you.

[The Chair, Liberal, Francis Scarpaleggia]

Thank you, Dr. Misra.

The floor is yours, Ms. Boudreault. You have five minutes.

[Laurence Boudreault, General Manager, Bosk Bioproduits Inc.]

Good afternoon, dear members of the committee.

My name is Laurence Boudreault, and I am the general manager of Bosk Bioproducts. Thank you for giving me the opportunity to speak.

Bosk Bioproducts' mission is to reduce the global accumulation of plastic waste. We are a Quebec company that has been developing for more than 10 years, thanks to the support of our partners and the government, an ecological alternative to fossil-based plastics that will have significant benefits for Canada.

We are therefore of the opinion that a regulation on single-use plastics will help better regulate the use of plastics, but it is important not to ban innovative ecological materials such as PHAs, or polyhydroxyalacannoates, a natural biopolymer that offers the same properties as conventional plastics, but which is truly compostable.

Under the REGEN trademark, Bosk Bioproducts develops, manufactures and sells bioplastics based on PHAs, bio-based from renewable materials, and compostable. According to recent tests carried out at the National Research Council Canada, or NRC, Bosk Bioplastics meet recognized compostability standards. We offer these bioplastics to manufacturers of finished products to replace petrochemical plastics.

Bosk Bioproducts offers an innovative solution that will, with your support, build a prosperous circular economy. It is important to know that our technology contributes to the circular economy on several levels. On the one hand, our innovative technology makes it possible to recover untapped by-products from the forest industry to transform them into value-added products, and on the other hand, our technology, which makes it possible to produce PHAs, offers a sustainable solution to the end-of-life plastics.

PHAs are a series of biobenign natural materials that have appeared in nature for over three billion years, similar to other natural materials such as wood, other cellulose-based materials, proteins and starch. These are micro-organisms that produce them naturally from sugars, starches, cellulosics and vegetable oils. Biodegradation of PHA materials in all environments—compost, soil, water—is comparable or faster than cellulose, in other words, paper.

PHA-based materials can partially replace any of the traditional fossil polymer families. Depending on the type and grade, PHA materials can be used for a wide variety of applications, including injection molding, extrusion, thermoforming, foam, non-wovens, fibres, 3D printing, paper and fertilizer coating, glues and adhesives.

Thanks to the support of our ecosystem and our government, for more than 10 years, we have been working to develop and market an ecological alternative to fossil fuel-based plastics. Our technology was developed by working with the Institut national de la recherche scientifique in Quebec and the National Research Council of Canada. All of this work was made possible thanks to the financial support of our partners, the Government of Quebec and the Government of Canada.

With the production of REGEN at our new Quebec plant, we are now at the stage of offering our ecological material to current players in the plastics value chain, as an alternative to fossil fuel-based plastics.

Bosk Bioproducts aims to deploy its technology on multiple paper mill sites. For each full-sized plant that would be built on a paper mill site, this means the valorization of thousands of tons of unused material from the paper mills, the creation of about ten high-level jobs, the transformation of a waste management cost into a new profit centre for paper mills, increased profitability of the paper mill and longer useful-life, the production of tens of thousands of tonnes of compostable bioplastics to replace their petrochemical counterparts, in addition to a significant reduction in greenhouse gas.

The Bosk Bioproducts project will not only promote the competitiveness of the Canadian forest sector, but also position Quebec and Canada as a global producer of bioplastics, in line with the foundations of sustainable development and the circular economy.

In short, Bosk Bioproducts works with our ecosystem and the government to offer an ecological solution to fossil fuel-based plastics. There are sustainable solutions to plastics, and we believe it is important not to ban the use of bio-based and compostable biopolymers for the manufacture of single-use products.

Thank you.

[The Chair, Liberal, Francis Scarpaleggia]

Thank you, Ms. Boudreault.

We'll continue now with Mr. Burt.

Mr. Burt, you have five minutes.

[Michael Burt, Vice-President and Global Director, Climate and Energy Policy, Dow]

Thank you, everyone.

My apologies for being a little bit late. I had some connection issues.

It's a pleasure to be here this afternoon.

My name is Michael Burt, and I'm the vice president and global director of climate and energy policy for Dow Canada.

For more than 75 years, Dow has been proudly innovating in Canada. We develop basic chemicals and polymers used to make a broad range of innovative and technology-based products and solutions in the packaging, industrial infrastructure and consumer care industries.

Dow Canada is headquartered in Calgary, Alberta. We have manufacturing locations in Alberta and Ontario, and distribute products throughout Canada. We are one of the largest resin producers in the world.

There is no question that the world has a plastic waste problem. We recognize that plastic waste must be dealt with, and this is an issue of paramount importance for our company. We do not believe it is appropriate, however, for the federal government to take unilateral action in this regard.

We do not believe that CEPA is the appropriate tool for dealing with post-consumer plastic. The issue of plastic waste is not the plastic itself but the behaviour that allows it to leak into the environment. As a criminal law statute, CEPA is meant to punish actions, not objects.

We are happy to see that the minister has recently proposed changes to CEPA that move away from the inappropriate toxic substances label. We believe the next step is a national framework tackling plastic waste, not a broad category of products.

Parliament, however, must pass these changes as quickly as possible. Unless changes are implemented and passed before the addition of plastic manufactured items to what is currently schedule 1, the inappropriate and incorrect toxic label will create significant confusion in the marketplace as consumers grapple with the distinction between what is in the news and how their food is packaged.

We would urge the government to wait until these legislative changes have been adopted before moving forward with this regulatory proposal on single-use plastics. If the government continues down its current path, it is our view that the stigma associated with the toxic designation will persist. This will significantly impact the perception of plastic in Canada and around the globe. This will negatively impact the investment climate in Canada for the petrochemical sector and is directly at odds with the government's initiative to restart the economy, in which the petrochemical sector plays a critical role.

Separate and apart from the naming issue, it is our view that the broad designation proposed inappropriately applies to all items manufactured from primarily plastic. This ignores the importance of the contribution made by most plastic items to the world. It includes every electronic device society uses today, an endless array of medical and healthcare devices that are used to treat patients and diagnose illness, and the packaging that keeps our food safe and fresh and prevents food waste due to spoilage.

To be clear, a ban will not deal with the fact that our waste management process needs improvement. A ban should be the last step the government takes as it works to deal with an issue, not the first.

Our industry urged the government to build the appropriate regulatory framework to address plastic waste and to include all provinces in those discussions. To date, the government has not followed this advice. It has opted to take an existing tool and incorrectly apply it to the wrong problem. Plastic waste is the problem, not plastic manufactured items.

We are strongly in favour of a new piece of legislation developed with the provinces and all stakeholders that can entrench a life cycle and circular economy approach to removing plastic from the waste stream. A post-consumed plastic is a resource to be captured, not designated as a waste. The same legislation can create the regulatory authority to build a national extended producer responsibility program involving the provinces, and a new act can invest in the technologies to foster chemical depolymerization.

A new act can create the authority for recycled recovery content standards, and provide a statutory authority to invest in the technologies that can repurpose recovered plastic to keep those molecules and valuable resources in the economy.

The appropriate legislative pathway deals with the entire waste management value chain, in contrast to bans that don't get to the root cause of the environmental leakage and diminish the path to a true circular economy. The appropriate legislative pathway will not need to call plastic toxic to achieve these goals.

In conclusion, no one believes that plastic belongs in the natural environment. We support actions to protect the world's oceans. If the government moves forward with its stated pathway to list plastic as a toxic substance, the impact on Canada's petrochemical place in the world will be profound. We believe the government can achieve the same end through a different means and, in doing so, foster investment as opposed to frustrating it.

I would welcome the opportunity to answer questions on this vitally important issue.

[The Chair, Liberal, Francis Scarpaleggia]

Thank you, Mr. Burt.

Go ahead, Mr. St-Hilaire. You have five minutes.

[William St-Hilaire, Vice-President, Sales Business Development, Tilton]

Thank you, Mr. Chair.

Mr. Chair, members of the committee, I thank you for receiving our comments as part of your work on the complex issue of single-use plastics.

I represent Tilton, a company in Quebec City.

For 35 years now, we've been creating plastic packaging that meets the needs and strict requirements of the food, medical and pharmaceutical industries.

Our packaging is used throughout North America. Our clients include Loblaws, Sobeys, Metro, Saputo, Biscuits Leclerc and a number of large, North American pharmaceutical companies.

Since its inception, Tilton has remained at the technological and environmental forefront of the global packaging industry. We cover all stages of the life cycle, from raw materials to raw materials.

This isn't what we call going around in circles, it's called the circular economy.

Long before the concept entered the public debate, we chose to work only with materials of the future: recyclable, 100% recycled and certified compostable.

In fact, the real problem is that we don't have enough recovered and properly sorted plastic to recycle. We have to import waste materials from the United States and Mexico because of a lack of local availability.

We have made major investments in technology, equipment, research and development, all in partnership with international companies to meet the highest standards in terms of quality and environmental protection.

We're one of the few companies capable of upgrading PET deposits to meet food grade standards. In the last five years alone, we've invested over $30 million in our facilities, including $21 million in 2020 alone. Other investments are already under way.

Our manufacturing equipment is powered by 100% renewable energy from hydroelectricity. Our plants are equipped with high-performance energy systems, including heat recovery and natural cooling systems. The water used in this process flows in a closed loop, so this system operates without any natural water input or release into the environment.

Sustainable development and the circular economy are at the heart of Tilton's mission. With so-called “single-use” plastic, we start the process over again. We encourage the committee to look at the situation from this perspective. The problem isn't single-use plastic, it's the single use of plastic that's the problem.

If plastics are banned, what would replace them?

In the sectors we serve, eliminating plastics would lead to major food safety, security, sanitation and food waste issues. That's why we say the real problem is the single use of plastic.

It's our [Technical difficulty—Editor] as a society to upgrade it. That's where efforts must be focused. We need to implement effective collection to stop single use, develop partnerships between governments, municipalities and businesses, raise awareness so that we stop throwing these resources in the garbage, and invest so that other companies act like Tilton. Believe us, the demand for recycled packaging is very strong. Customers are aware of it and are asking for more.

Governments must make this transition possible. In Quebec, the government has announced an expansion of the deposit and a restructuring of recycling collection systems. We believe this is a step in the right direction.

Tilton is proving every day that we can reuse this material and create a true circular economy. With your government's support, industry across Canada can accelerate this shift that we have already begun.

Here are five recommendations to support the committee's work.

First, make massive investments in sorting centres to improve their operation and standardize the grading processes according to resin type. In this regard, we feel that implementing automated systems is essential.

Second, phase in a minimum amount of recycled content for all new plastic packaging, be it water bottles or food containers, whether they are manufactured, distributed or imported into Canada. This requirement would create quality and quantity raw material streams to support a plastics reclamation industry.

Third, establish eco-responsibility certification in collaboration with standards associations. This would allow for quick identification of plastic packaging by consumers so that they can sort it properly.

Fourth, mobilize other governments, municipalities and citizens to develop a culture and even pride in recycling.

Fifth, ensure that any measures imposed on Canadian companies, producers, and users also apply to packaging products that are imported.

In conclusion, we are ready to take a leadership role in helping our industry meet new challenges and create a true circular economy. We've been doing this for a long time, and we want to see the entire industry follow suit.

We want to go even higher and even further. In considering these few recommendations, you have the power to give us the means to do so.

Thank you for your attention.

[The Chair, Liberal, Francis Scarpaleggia]

Thank you, Mr. St-Hilaire.

We'll now start the first round of questions.

In addition to welcoming Mr. Maguire, I'd like to welcome Ms. May, who is with us today.

We'll start the first round of six minutes per party with Mr. Albas.

[Dan Albas, Conservative, Central Okanagan—Similkameen—Nicola, BC]

Thank you very much, Mr. Chair. I'd like thank all of the witnesses for coming today, and sharing with us their expertise and views.

I'm going to start by addressing my questions to Mr. Burt from Dow. I asked this of some of your industry colleagues last week.

Could you clarify, will the designation of plastic as a toxic kill jobs, and drive away investment from Canada?

[Michael Burt]

We believe it will.

I am also on the executive of the plastics division of the Chemistry Industry Association of Canada, the CIAC. We have numerous individual companies, SMEs, that operate throughout Canada, and the only products that they manufacture are single-use plastic bags and straws.

The first step in designating plastic-manufactured items on schedule 1, and deeming them toxic, is the government's plan to implement a series of bans. A number of the bans the government is looking at putting in place are of products that are only manufactured by these companies. The difficulty is this. We've asked the federal government that if it implements these bans, will it not allow these products to be manufactured, imported or exported? To date, the government has not answered that question. I'm not sure it has developed that concept yet. The reality is that if you're no longer able to manufacture straws, stir sticks or single-use plastic bags in Canada, these companies will go out of business.

The chill on the investment cycle is real. Dow Canada, like many companies in the resin producer chain, continues to look at where we're going to invest our next facilities. Canada is very much at the forefront. We haven't received much investment in the petrochemical sector over the last decade. It's been mainly going to other parts of the world, mainly the U.S.

The difficulty is that we manufacture virgin resin. If Canada is looking at deeming the product we manufacture toxic, we are not sure about the long-term ramifications. If you invest billions of dollars in these facilities and their lifespan is 40 to 50 years, it can be an insurmountable risk to someone looking at investing in Canada.

The reality is that the toxic designation is incorrect. The federal government has indicated that plastic products are not toxic. The mechanism the government is utilizing, by adding it to schedule 1 in CEPA, is known as the toxic substances list. We were pleased that the Environment Minister indicated that the government was going to undertake CEPA reform.

One of the aspects of that is changing the name and structure of schedule 1, looking at potentially doing it in two-parts: items of very high concern and items of less concern. We're unsure where plastic-manufactured items would go on that spectrum, but our ask of the government is that if it's doing a CEPA reform/review, to not add anything to CEPA while that's being undertaken.

We don't believe plastic-manufactured items, or plastic of any content, belong in CEPA. That's why we've been advocating for a national framework to deal with plastic waste, not the items made of plastic themselves.

[Dan Albas, Conservative, Central Okanagan—Similkameen—Nicola, BC]

Mr. Burt, you've mentioned Bill C-28. Obviously, the Liberal members here are likely going to say that Bill C-28 removes the word “toxic” from the regulated schedule; however, the rest of the bill still refers to the substances as toxic, so that doesn't really do anything.

Why is the word “toxic” so harmful to your industry?

[Michael Burt]

We believe that it creates a lot of uncertainty in the marketplace. Individuals who have their food packaged at the local grocery store, the electronic devices they utilize every day, these items they use are not toxic. The designation is inappropriate.

The ability to have the toxic designation will basically ricochet throughout the world, we believe, and there will be other jurisdictions that may take up the banner. You're looking at an item, plastic—from the petrochemical sector—that is paramount if Canada is looking to achieve its greenhouse gas emissions targets. Plastic contributes to GHG reduction every day in the lightweighting of vehicles, the products that we utilize and the preservation of food. The reality is that the toxic label is inappropriate; it's incorrect.

We are looking for a national framework to deal with plastic waste, not an item. CEPA is a criminal statute, and it's basically designed to punish and administrate the actions of individuals, not particular products. If you deem a global commodity like plastic as toxic, there are other jurisdictions where investment will take place. Unfortunately, Canada will lose out on one of its main objectives, that of being a leader in the circular economy and tackling GHGs. To reach those levels, plastic needs to be paramount in the program.

[Dan Albas, Conservative, Central Okanagan—Similkameen—Nicola, BC]

Thank you very much.

Madame Boudreault from Bosk, it sounds like your products are very innovative. Are you going to be affected adversely by the designation of some of your products? Are your products going to be on the schedule, whether the current schedule or a future schedule as featured in Bill C-28?

[The Chair, Liberal, Francis Scarpaleggia]

Ms. Boudreault, we're listening.

[Laurence Boudreault]

I'm sorry, but I haven't seen that schedule with all the ingredients that have been added. If PHAs, a natural biopollutant, isn't included, we won't be affected because our material is fully biosourced and compostable.

In fact, we want to make sure that our material isn't included on this list because it's a real green, concrete solution that is available today. So we want to make sure that we can continue to offer our alternative to manufacturers, who are the current players in the plastics value chain.

[The Chair, Liberal, Francis Scarpaleggia]

Thank you.

We'll now give the floor to Mr. Bittle.

[Chris Bittle, Liberal, St. Catharines, ON]

Professor Curran, I am wondering if you could respond to Mr. Burt.

We've heard a few times that these highly sophisticated corporations and consumers will be lost in this designation of “toxic”, that all of the economy will be destroyed, people will throw things out, they won't be able to address things. It will be a catastrophe.

I don't know many of my constituents who have read CEPA, but I am wondering if you could respond to his comments with respect to these highly sophisticated companies not being able to interpret the “toxic” provisions of the Environmental Protection Act?

[Deborah Curran]

Mr. Chair, I'd be happy to.

I want to first commend Dow, which is often used as the example of a company that has adapted as we've learned about chemicals over the last 40 years in particular. There are many stories from Dow Chemical about how they were innovators and leaders when they realized one type of waste stream that was coming from their factories was then able to be used for something different. They really are innovators in this area.

It's really important to have a look at the text of CEPA. I'm looking at section 64, which gives the interpretation of “toxic substances”, and I think we can all agree that paragraphs 64(a), 64(b) and 64(c) are exactly what plastics do: They “have or may have an immediate or long-term harmful effect on the environment or its biological diversity;” they “constitute or may constitute a danger to the environment on which life depends;” or they “constitute or may constitute a danger in Canada to human life or health.”

This is relevant for plastics. It is directly applicable, and CEPA, not as a criminal law statute, actually provides a framework for the management of all sorts of substances and activities within federal jurisdiction. As you know, federal jurisdiction is somewhat unique and shared in this area. The regulation of substances really is a tripartite endeavour between the feds, the provinces and municipalities, and in this area of plastic, every single level of government would like to take action in that way.

There's a high degree of consensus between the provinces and the federal government about banning certain types of substances, banning certain types of plastics, for the express purpose of better regulating what can then be produced and come into our environment so we can use it again in a variety of different ways.

It's really important to keep our context of, when we say “ban”, we're meaning regulate for almost the first time. Right now, you can go out and commission almost any kind of plastic that you want, irrespective of whether it can be reused at all, and that's simply no longer acceptable. We need to reuse substances time and again for a variety of different purposes, and one way to achieve that shift in our economy and the way in which we view materials used in Canada is through regulation.

Obviously, there are all sorts of different mechanisms that need to be embedded within a larger, long-term, phased plan around taxation, around incentives, around the work, for example, that Dr. Misra is doing in creating new materials and opportunities. However, creating a framework under the act that is phased and that also sends messages to industry about the way in which we expect plastics to be made so that we can re-use them or that they can be used for other things is very important.

As my final point, there are going to be all sorts of single-use plastics that we won't get rid of, obviously in the health care industry, and in certain food-related contexts. Those will simply carry on and it's up to you as legislators to decide what the boundaries of those are, but there are such very easy starting places with things such as plastic straws and single-use paper bags, where the Canadian public simply no longer accepts those as a useful part of our daily lives.

Thank you.