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Environment committee  It's precisely because of the various stages in the act where we don't have tailoring of what to do and when, in respect of the most dangerous substances, that we need to be more specific about how to implement precaution. It doesn't mean, for example, plugging in that word “prec

June 5th, 2006Committee meeting

Hugh Benevides

Environment committee  Mr. Chair, these are the 400 substances that I identified earlier as having those characteristics. Certainly, as a starting point, one would want to consider what kinds of mandatory timelines would we want in an amended act, in terms of proceeding to the next stage of screening,

June 5th, 2006Committee meeting

Hugh Benevides

Environment committee  The context will determine how that might happen. There are some examples of different provincial legislation that have features of precaution within them, even if that word isn't used. That's why I was trying to say that what is less important than the particular meaning is what

June 5th, 2006Committee meeting

Hugh Benevides

Environment committee  That's right. In my introductory remarks I tried to establish the proposition that precaution is not an option, as it's an emerging principle of international law, and that the particular articulation of the principle in the act is one that is contested, and not the only one, b

June 5th, 2006Committee meeting

Hugh Benevides

Environment committee  Of course the act is able to address that problem, particularly, for example, in relation to the large final emitters. So one might ask: where are the regulations that would impose hard limits on those emitters and where are the timelines within those?

June 5th, 2006Committee meeting

Hugh Benevides

Environment committee  Act sooner rather than later.

June 5th, 2006Committee meeting

Hugh Benevides

Environment committee  Thank you, Mr. Chair. I'm sure John is right that the words “sound science” don't occur in the act. However, what Mr. Lourie was identifying was the reality of the kinds of activities and discussions going on in a swirling range of activity around the law. The law is just the ce

June 5th, 2006Committee meeting

Hugh Benevides

Environment committee  Of course. I'd let Bruce address that question in relation to mercury, because of the different situations, but I think for mercury switches.... The context is going to vary, but....

June 5th, 2006Committee meeting

Hugh Benevides

Environment committee  Yes, please. I note that mercury, at the time of the enactment of CEPA in 1999, was listed as number eight on the list of toxic substances, a clear indication that it's been there for some time. The second observation is that we have a gap in those substances that were already l

June 5th, 2006Committee meeting

Hugh Benevides

Environment committee  My final comment, Mr. Chair, in terms of the categories I wanted to identify is that there are barriers to taking precautionary action, and you can see how that ties into my last theme, both within the act and within various policies and directives that government officials are r

June 5th, 2006Committee meeting

Hugh Benevides

Environment committee  Thank you, Mr. Chair. My name is Hugh Benevides. I am with the Canadian Environmental Law Association, or CELA, as I will refer to it in my presentation. CELA is a legal aid clinic established under the laws of Ontario. We've been in existence since 1970 in order to represent t

June 5th, 2006Committee meeting

Hugh Benevides