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.