I can try to give you a brief explanation.
In fact, previous iterations of this committee have reviewed this issue a number of times. All came to the conclusion that the regime is unworkable. That includes the committee's most recent review of CEPA and a review of a private member's bill about 10 years ago.
Essentially, the notion of virtual elimination, of trying to eliminate the presence of the substance, is not the concern; the concern is that when you introduce a concept like that, you have to define it and you have to require specific actions. In the statute at the moment, you have to develop a particular kind of regulation over and above the section 93 obligation to regulate, so we have this obligation to develop two regulations; however, if you're prohibiting a substance, there's no point adding a second regulation.
We also have defined virtual elimination in a way that refers to the quantification of the substance or the ability to measure the substance. In some cases, we can monitor emissions of the substance and identify what the lowest level of quantification is, but in a lot of cases, substances that we're worried about are used diffusely. In other words, they might be part of the treatment of millions of shirts and come off in the wash. We can't quantify the emissions from the use of the substance, so the way in which we defined virtual elimination meant that we could not comply with the law and we could not develop the regulation that was required by the law.
Rather than adding substances that were persistent and bioaccumulative to a schedule, we simply added them to the regular schedule of toxic substances and then took significant action, such as prohibitions. We achieved the goal, but we were not able to comply with the specific provisions in CEPA in 1999, which is why there are so few substances on this list at the moment.