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Environment committee  There are two things. First, as we are out of time, I just want to mention that we do have a full submission, which is currently being translated. It will be available to you within a day or two. Second, the concern from industry is that their substances will be “stigmatized”, wh

November 20th, 2006Committee meeting

Jessica Ginsburg

Environment committee  Thank you, Chair. I would add that the fundamental process governing the assessment is a substance-by-substance approach, which by its nature means that cumulative effect considerations are not adequately addressed.

November 20th, 2006Committee meeting

Jessica Ginsburg

Environment committee  Absolutely.

November 20th, 2006Committee meeting

Jessica Ginsburg

Environment committee  Absolutely. There is a problem of missing data, or as the substances are referred to, “the uncertain substances”, because we don't know. That's an issue primarily with the existing substances that have just undergone the categorization process. I would argue that even with the

November 20th, 2006Committee meeting

Jessica Ginsburg

Environment committee  Perhaps I could just take a few seconds for myself and then have permission to pass it to Dr. Khatter. I just want to very quickly point out that not all pieces of legislation use the same test for maintaining confidentiality. For example, the Access to Information Act does not

November 20th, 2006Committee meeting

Jessica Ginsburg

Environment committee  I want to reiterate what Mr. Arseneau said and highlight the fact that there is an appeal provision for companies that feel their information should have been kept confidential, but there's no comparable provision allowing appeals for the public or other interested parties who fe

November 20th, 2006Committee meeting

Jessica Ginsburg

Environment committee  I would just make one additional point. I was involved in the new substances notification regulations on organisms that are essentially biotechnology products. In the context of that process I tried very hard, as a concerned member of the public, to find out what the protocols we

November 20th, 2006Committee meeting

Jessica Ginsburg

Environment committee  Thank you. In order to speak to the pros and cons, I think we only have to look at what the historical situation has been and the direction in which other countries, such as the European countries, are moving. Through the priority substance list exercise, we've seen that it is

November 20th, 2006Committee meeting

Jessica Ginsburg

Environment committee  Perhaps I could speak to that. One of the most direct ways the precautionary principle could apply relates to the fact that there are hundreds of substances about which there is very little known information. I'm referring now to the existing substances, those that have been go

November 20th, 2006Committee meeting

Jessica Ginsburg

Environment committee  There are a number of areas of existing and new substances that I think could bear improvement. Certainly the onus on industry to provide data for new substances is an improvement over essentially the non-requirement that existed originally for the existing substances. There is a

November 20th, 2006Committee meeting

Jessica Ginsburg

Environment committee  For both.

November 20th, 2006Committee meeting

Jessica Ginsburg

Environment committee  Could I respond? The comments around burden of proof were directed to both existing and new.

November 20th, 2006Committee meeting

Jessica Ginsburg

Environment committee  Good afternoon. My name is Jessica Ginsburg. I am special projects counsel at the Canadian Environmental Law Association, also known as CELA. I'd like to introduce Kapil Khatter, director of the Pollution Watch program on health and environment, which is a joint initiative of C

November 20th, 2006Committee meeting

Jessica Ginsburg