Industry committee  The feedstock is there.

Industry committee  It's a hybrid, and Sarnia has been in business for nearly a hundred years, but it's really since pre-World War II that it has been a very strong and globally important cluster of chemical operations. The industrial scale of bioinvestments has been realized in the last five years.

Industry committee  Thank you, Mr. Chair. It's an honour to appear before this committee today on behalf of Canada's chemistry industry. Our industry is vitally important to Canada's manufacturing landscape. Chemistry is a $53-billion a year industry in Canada. That makes us the fourth largest manufacturer and the second largest manufacturing exporter.

Environment committee  And we would say, stay with the risk-based approach.

Environment committee  I would say our system is better and it's a better use of public resources. I'm not here to trash REACH. It is one of the few other programs, like the chemicals management plan, that have done the job. I think our chemicals management plan was designed for Canadian circumstances, and it is more appropriate and it is a better use of public resources.

Environment committee  Risk management is complex. I'm sure you've looked at this. When a substance is listed under CEPA, schedule 1, there is a clock that starts to tick, and the government must introduce a proposed risk management measure. Once that's been consulted on they have another clock that starts to tick, and they must introduce a final risk management measure.

Environment committee  I don't know why. I know there are other thresholds as well and they include the size of the company in terms of—

Environment committee  There are other exemptions from NPRI reporting, and they often focus around the number of employees. I believe the threshold is 10 full-time equivalents. I think you'd need to ask experts, but what you might see in that industry is, yes, cumulatively there are emissions that reach the threshold, but in individual activities where those might be sourced from, you have fewer than 10 employees.

Environment committee  I'm saying it could be related to the nature of that business, and how many employees are at an individual wellhead. You're not going to find more than 10 employees at an individual wellhead on a full-time equivalent basis.

Environment committee  Very good, and I can't think of a better example than the decision made by the House of Commons to directly list plastic microbeads as toxic, and then the subsequent discussion and process around that. Think about that. What is a plastic microbead? Well, every piece of plastic is made out of a resin that is by definition a plastic microbead.

Environment committee  No.

Environment committee  I think we're back to the question that was raised earlier, about whether a toxic is a toxic is a toxic. I think one thing we've learned through this exercise is that it isn't. Often that label gets applied, and the public's response and the concerns raised aren't always appropriate.

Environment committee  While I can't speak for any individual company, the basic answer is yes. I'll come back to CEPA framework; it's expecting you to do that. We deal with our existing substances, those that were in commerce before CEPA provisions went in for new substance notification. We had a list of these substances.

Environment committee  I'm not sure I quite understand your question.

Environment committee  Certainly part of that, in terms of how you should safety dispose of it, is under hazardous workplace materials information. With regard to your message about different jurisdictions having different requirements, that's true too. The life-cycle approach is increasingly important and the cost of managing is also important.