To explain the timelines recommendation, the timeline that we're frustrated by right now is the lack of a timeline between the proposed risk assessment being published—most of the work has been done at that point and there's a proposed risk assessment that's public comment—and then finalizing that risk assessment. That is where there's a gap and there is no timeline in CEPA.
In our experience, especially for what you might call more controversial substances, we've seen waits of five-plus years to see final assessments. Risk management can't start—and it doesn't start for years after that—until the assessment is finalized and that substance is added to schedule 1. They can then move forward with doing instruments and regulations to manage the risk.
Having this long period and gap between proposed and final is the real problem. If there is the need for additional research that wasn't done at the proposed step in the draft risk assessment, we put in this opening to extend that one-year timeline to allow for that, but that is the frustration we're dealing with.