Thank you. It's nice to see everybody in person.
I think the question is about the implications of having strict timelines for subsequent risk management instruments. I would make three points.
The first is to assure you that departments are highly motivated to manage the risks of substances. Timelines in legislation can sometimes help, but they don't always make things happen. You might recall that 4,300 substances from the 23,000 that were existing in 1998 were assessed between 2006 and 2020 under three plans on timelines and were generally on time without those timelines being legislated. That's one point.
The second is that timelines for risk assessment and risk management are a little bit different. We know that on average it takes two to three years to move from a draft risk assessment to a final risk assessment. The requirement that was added was, when it goes past two years, to explain why.
For risk management instruments, you know that in the act there's already a requirement for that first risk management instrument draft to be published in 24 months and the final version to be done 18 months later. That's 42 months altogether.
It takes that long because it's not only a scientific assessment; it's also considering cost-benefit. Over the time that we're developing the risk management instrument, we get a better idea of the sources of exposure and how to manage the substance. There's a lot more discussion about how to implement that. That's why it takes longer.
In general, the first one that's published will be the one that has the most impact. The supplementary ones are then developed as fast as possible. In general, I would say they are done in time.
I know that the committee will say that there are times when the risk management instruments take a very long time to get into place. There are reasons for that. Sometimes more information is being gathered to understand either the sources or the paths of exposure. Sometimes it's because the market situation has changed. Sometimes it could be because there are multiple instruments from different management instruments impacting a specific area, so they're trying to sequence them. Sometimes they're prioritizing across all the risk management instruments because they wouldn't work on one that has a small effect before they would work on one that has a big effect on a different substance.
That's a long explanation, but that's why. I think we all appreciate that people want the accountability, so I think the reporting on it....
The third reason is sort of administrative. It's to find the least administratively burdensome way to incent fast action. One way to do that would be to require updates in the annual report.