As for the impact of nanoparticles on health and the environment, given the number of studies that have been done, there is a scientific consensus that has existed for quite some yearsnow—perhaps Mr. Emond could confirm this—on the toxicity of certain nanoparticles, both for health and the environment. We know that this is certain. For most nanoparticles, there is, it is true, a great deal of uncertainty. I would like to remind you that we are talking about nanoparticles and nanotechnology, however, essentially, there are five that are the most often used in consumer products. These are nanoparticles of gold, silver, carbon, zinc and selecium. So, as Mr. Petersen said, we can zero in on the problem to some extent, although everything depends on the way that they are used. Already we can start investigating toxicity based on the use of these five nanoparticles in consumer products. Nevertheless, we are no longer simply asking questions; now there are some certainties. We have a lot of questions and many uncertainties, but as far as toxicity is concerned, we do already have some certainties.
The European legislation is also stricter, for example, in the area of chemicals, because the manufacturers and importers there have primary responsibility. As Mr. Emond, said, in Canada, it is primarily up to the government to prove that substances available on the market are toxic. In Europe, they are starting to make the producers and importers prove the safety of their products, whether they be chemicals that are normal in size or at the nanoparticle level.
There is another major difference: In Europe, there no longer is a distinction between novel substances and existing substances, meaning that all substances are subjected to the same obligations, or as in Canada, the obligations are much more restrictive for producers of novel substances. In my opinion, this is also hampering technological innovation, since those producers who wish to innovate and invent novel substances that are less polluting or toxic must comply with stricter requirements than those who have been marketing substances that have been around for 20 or 30 years.
These are but a few examples. There are, obviously, others. What I wanted to say, to qualify my comments, is that even if these laws are enforced in Europe and in Canada, the production thresholds that are required to provide information to the government are too high to pertain to nanoparticles. Consequently, in both Europe and Canada, producers are told that if they produce so many tonnes per year of a certain substance, they have to provide information regarding toxicity. In many cases, these ten-tonne or one-tonne thresholds per year are too high to be able to apply to nanoparticles given their small sizes. Consequently, this is not a good approach.
As Mr. Ostiguy said, we must stop thinking in terms of volumes but rather, for instance, in terms of surface. That was what I was trying to say earlier. In actual practice, even in Europe, most nanoparticles slipped through the REACH regulatory safety net, because they are not produced in a volume that exceeds the established threshold. So that is the situation and I hope that this is clear.