Environment committee  Thank you very much. Good afternoon, Mr. Chair and members of Parliament. It's a pleasure to be here today to discuss the two key issues for our industry sector pertaining to your review of the Canadian Environmental Protection Act. My name is Shannon Coombs, and I'm the exec

Environment committee  Just to clarify for us, when a substance--for example, ammonia--is placed on schedule 1, there's no context provided. It's on the list; it's on schedule 1 because a risk assessment has been done about a particular use that has warranted its being placed on schedule 1, meaning it

Environment committee  Certainly. Actually, could I use a disinfectant? Those are the products that my members make.

Environment committee  I am--a coalition--but I'm most familiar with the pre-market registration process for disinfectants. In terms of disinfectants, for example, if I wish to use a new substance, truly new to Canada, I have to go through Environment Canada and apply for an NSN. That data package wil

Environment committee  I would have to make a submission. Also, Health Canada has a data package that would be required with respect to the safety and efficacy of that particular product.

Environment committee  We would do the testing, but we provide the data that's required by Health Canada. They make a list of all the submission data that I have to provide to support the submission being reviewed and approved.

Environment committee  The substances that would be in the product would have to be on the DSL, the domestic substances list, as well; however, the end use of that product would have to be approved by Health Canada. Our companies go through extensive testing to make sure the product is safe for consu

Environment committee  I can certainly provide you with a list of the submissions for what we have to go through with the test data that we have to provide. It is quite extensive and Health Canada is quite rigorous in their review with respect to all the end-use products that they regulate.

Environment committee  I'll jump in and my colleagues can finish. From a CCSPA and an FPIC perspective, we've provided two key recommendations. It certainly is the committee's prerogative to look at the review however they wish, but in the last review, in 1999, there were over 150 amendments outside

Environment committee  Okay, I'll start off. In our brief, I think we made it quite clear that schedule 1 is not a list of substances to be avoided. The list is designed to ensure that a risk management strategy is in place for the substances. So what we're looking for is contextual wording, or a brie

Environment committee  For our industries, because we're subject to two pieces of legislation, it was a bit daunting and overwhelming. But we now have a process in place where NSNs can be used for a variety of things. If your substance gets an NSN and you use it in a variety of substances, under the Fo

Environment committee  Just quickly, on pre-market.... I'm sorry, go ahead.

Environment committee  I'll just answer it briefly, Mr. Chair. For the Food and Drugs Act sector, a lot of the substances that have been on schedule 1 and are of concern to us, for example ammonia, aren't toxic. So we continue to use it in our products because it's not toxic in glass cleaner, for exam

Environment committee  For a sector that was regulated under the Food and Drugs Act for so many years, to have a different type of risk assessment be done by a different piece of legislation, by two different departments, is.... Yes, we absolutely think it's a good act. It's a good foundation and a goo

Environment committee  Well, I don't think it's as loaded as toxic.