A pollution prevention plan, or a P2 plan, is a form of risk management. Really, at the heart of decisions made about risk management is that risk management has to be tied to the risk assessed. Experts currently have a variety of risk-management tools at their disposal, depending on the degree of risk that is posed by that substance. This ranges from, on one side, pollution prevention to, on another side, prohibition.
There are also regulations under CEPA and other acts for the use of the best-placed act that can be used for risk management.
We think that any mandatory pollution prevention requirement would take away this discretion, and this link between risk assessed and risk managed would codify the process and would not adequately reflect the science and the risk-based nature of the act.