That is something we've addressed, some people would say, in painful detail.
We provided two large documents to members of the committee over the last several months. One was a lengthy set of submissions identifying nine areas of concern with CEPA generally, one of them being the issue of alternatives. A second document, which was our proposed amendments to Bill S-5, is a document that's actually longer than Bill S-5.
The part you're referring to, which deals with alternatives, is set out in tab three of our proposed amendments. What we did was basically take a page from the process that's engaged in by the European Union in their REACH authorization program in how to address the question of alternatives. There it applies to any substance that's on their.... They have a separate listing system, similar to CEPA, and we're proposing that the same approach be applied here.
This is what we have done. Since the government is proposing to bifurcate schedule —something we don't think they should do, but assuming for the sake of argument that the government is going to do that—we've suggested addressing the first 19 substances, which are in part 1, with the alternatives analysis we've set out in our proposed amendments, not unlike the analysis that is authorized not only in Europe under REACH, but also in Massachusetts under their Toxics Use Reduction Act, and giving industry a number of years to address that issue as it relates to part 1 substances.
Then in relation to the 132 substances that are in part 2 of schedule 1, we've suggested a somewhat longer time frame. and we've set that out in our proposed amendments at tab three of our material. That analysis would then go through those 132 substances as well.
The point of the exercise is to do exactly what the 1995 standing House committee, the predecessor to your committee, was urging Parliament to do at the time. That is to basically make pollution prevention the primary approach to this statute and not pollution abatement, which is really what it is engaged in right now. Secondly, include alternative analysis in that exercise in order to expedite those reviews.
I think the answers to your questions are found, in summary, in tab three of our proposed amendments.