The BPA is both a good and a bad example about what is different. BPA is a bad example in terms of this act specifically, in that it was noted in the chemicals management plan as a priority, so it was already a trigger for the government, which was moving to act.
There was an assessment done that looked at all of the various sources from which Canadians could be exposed to BPA. It looked at that in consumer products. It looked at the use of those consumer products. It looked at that in all kinds of products, including foods, food packaging, and other things, to arrive at an integrated assessment about which populations were most at risk, and then took a look at the appropriate interventions in order to respond to that particular risk. That would continue to happen, where Canada is a world leader in terms of chemicals management and identifying those risks.
What would be different with this act is that we would then be able, as a result, to move very quickly with industry without having to develop regulations to say, “If this substance poses an unacceptable risk and doesn't belong in your product, you are breaking the general prohibition”. We would be able to act.
If we were uncertain, we could demand tests of industry. How do you know that this product is safe and that it doesn't come out of the product and expose humans to it? What is the ultimate fate when disposed into the environment? What cumulative exposures have you considered? We'd be able to work that in as we move forward. That's where it really helps us as we move forward.
The most fundamental change with this bill is that it moves from the government having to provide proof and introduce regulations, to, in the absence of that, which is a time-consuming process, working voluntarily with industry. This bill allows us to clearly state to industry, “The onus is on you to provide us the information we need to make sure that's working”. When it's not, then we're going to be there as that backstop. Along the way, we will inspect and we will make sure the system is working, which allows us to move far more rapidly.
As for our objective with Bill C-6, I will again go back to my comments, as they are so fundamentally important to us. In a system that is post-market, not pre-market, where we don't get to see products ahead of time, active prevention is through the establishment of standards. We will work with the Canadian Standards Association and others to say what standards should exist for different consumer products. Then we would tell industry that they need to use those standards that would be appropriate.
Those types of active preventions, including working with targeted oversight, the incident report and getting the information we need, the inspection, cyclical enforcement, taking a look at what's coming into our country, and then backstopping that with the rapid response, will allow for far more timely action on a broader range of issues when voluntary actions fail.