Through the chemicals management plan, which has been around since 1999 and really reinforced in 2006, there's broad agreement that the federal government's role is to assess new and existing substances, and identify those that pose unacceptable risks to human health and the environment.
Largely, the federal government will take action in certain areas, but when it comes to the workplace, legislation is regulated by provincial departments of health and labour. It's comprehensive. There's training. There's signage. There's personal protective equipment. They have robust and lengthy sets of occupational exposure limits that are strictly enforced, with auditors and enforcement agents visiting sites all the time.
When we're talking with the federal government, now that they perceive the need for a new role for the federal government in managing those risks, what gaps are you trying to fill? Where's the evidence that those gaps are there? Have the provinces agreed with you? We see a scenario where suddenly not only do we have to meet the requirements of the provinces, but also something from the federal government.
I go back to your earlier question. Can you imagine a year ago, when both Ontario and the federal government were working on the climate change file, and both levels of government put out requirements on how to regulate emissions from coal-generation equipment? The federal government's proposal came out, somewhat out of the blue, about a week after the provincial requirements had been tabled. They didn't line up. In fact, they conflicted with each other. The federal government would prevent you from meeting the provincial requirements.
Have you guys not talked to each other about this? If you're going to do something, and you know the provinces are already doing it, can't you talk to each other? No.
I'm trying to say this again. It's a chronic, daily thing. It's not that any one level of government is right or wrong. It's just that if we're serious in Canada about addressing the issues of regulatory competitiveness, we're in a very different structure from the United States. Roles are often much clearer there. We understand there's vagueness and uncertainty. That encourages us to have much more detailed conversations at the start about the proper roles for different levels of government.
I would say again, the directive on regulation is a very good document, but you will not see the word “provinces”. You will not see the word “jurisdiction” anywhere. There's an assumption from the first stage that the action being proposed is legitimate for the federal government. We would say you need to go back to the very conversations that were had through the program review, which asked one very direct question: Is it a federal role?