Introduction to the Chemicals Management Plan - March 5, 2009
Q: What kinds of efforts would be most helpful for you from NGO and non-profit groups in the sectors you have identified?
A: From my perspective as a fairly new coordinator on this file, I think word of mouth is helpful. I appreciate very much that Barbara took the initiative to host a webinar on the CMP. And certainly the more people who are able to understand that this is happening, the more voices that will add power to the requests we put through for transparency, plain language, and non-technical tools for weeding through the “alphabet soup,” as you call it. –Philana Dollin
A: We (NGOs) need support to make the CMP public, in plain language. We need a toxics campaign. So right now, our very limited resources have gone into submission to the government. The preparation of these comments is time-consuming and a difficult task. But they do not go into public outreach. –Anna Tilman
Q: What kinds of further supports and resources from government would make a big difference now? From the outside, seems like major efforts at 'social marketing' funded by government would be important to reach Canadians, to explain the tasks and the stakes and mobilize citizens, groups and communities. As well, is there a funded "intervener status" process by which those especially harmed or at risk are able to participate -- both in the evaluation and in public awareness campaigns?
A: I don’t know about intervener status processes related to the CMP – if they even exist at this time. But I can tell you that the two primary requests for resources/supports we have put in to government lately for help with understanding and responding to the CMP process are basically:
1. Online tracking tools – so that individuals can look at changes on designation of particular substances throughout the challenge program and will be able to understand decisions made along the road to that designation.
2. Regular technical teleconferences – so that individuals responding to the batch releases and management approaches are able to have their technical questions answered directly by government risk managers who are making the decisions.
We have put in formal requests for both of these items (as well as a few others) and continue to include these requests in our reporting to Health Canada. Fingers crossed that these requests are granted and that they prove useful in capacity building for the NGOs involved. –Philana Dollin
A: More material is needed to explain the government program, highlight some of the issues – worst chemicals , what the government should be doing, and get this message to groups across the country. Without resources and with only a handful of people working (I would say mainly volunteering their time) on this, we can’t do what we need to do. There is no intervenor status process. We would need to leverage funding and resources beyond what the government has dedicated to this. –Anna Tilman
Q: What is the nature of chemical labelling requirements in current Canadian law? Who is responsible for such laws? What is the connection between the CMP and the agencies involved in such controls? What is the approach to CEPA-toxic chemicals, prior to the end of the CMP process?
A: The approach to CEPA-toxic chemicals has varied according to the strategy developed by the government. In my review of CEPA-toxics, I have not seen dramatic results – reductions, etc., other than when a regulation has been passed for certain industries etc. –Anna Tilman
Q: When "high priority" chemicals assumed to be toxic are formally so deemed at the end of the consultation process, do they automatically achieve a status of "banned"? If not, what are the other statuses/options under consideration? You spoke of risk management strategies -- what are the central planks of these, and what are the penalties and incentives for industry?
A: The chemicals are not banned. So far, few have been found to be CEPA-toxic, even though, prior to the CMP, the government indicated that there was a propensity to declare them toxic.
The central plank for most so far has been very limited. In submissions that I have done, I comment on these and recommend stronger measures, regulations, etc. –Anna Tilman
Q: It is commonly understood that the synergistic effects of multiple chemicals, even if some are of "medium" or even "low" priority, especially with long exposure, produces both known and emergent health harms-- indeed, very serious ones. And clearly, such synergies then de facto change the danger quotient of given chemicals, just as duration and intensity of exposures do. What provisions are being made for assessing and addressing this reality, which, for many Canadians, may actually be the single greatest danger at this time?
A: I do not see any provision for addressing these. –Anna Tilman
Q: Are risk assessments being developed taking into account the great range in human sensitivity to chemicals -- in people's ability to detoxify chemicals, in their genetic and epigenetic susceptibility to given chemicals and linked diseases, in age- and gender-linked vulnerabilities, and in the ways in which chemicals bio accumulate in women and are passed on to the next generation? Are the risks to the most vulnerable serving as the benchmarks for assessments of toxicity? Even in the past year, new research from important researchers has come forward confirming or linking anew a variety of chemicals to many health harms (including diabetes, obesity, respiratory disorders and illness, neurological deficits and illnesses, gastrointestinal disorders, and cardiovascular, liver and kidney diseases, myalgic encephalomyelitis-chronic fatigue syndrome, fibro-myalgia and environmental sensitivities-multiple chemical sensitivities). Is there an agency or department wherein the government evaluation process continues to refine evaluation criteria according to new findings -- or is this left entirely up to civil society participants reacting to the 1984 data? How does this work?
A: Likewise, the depth of the assessments for the CMP is not there. The assessments are called “screening assessments” which do not do the kind of analysis that you are indicating. –Anna Tilman
Q: Surely we can all agree on the need for plain-language information for a successful, inclusive CMP, and to enable Canadians to consume chemicals responsibly?
A: Yes, it is necessary and you have developed very worthwhile ideas on this. The next step is translating this to action and mobilizing people to push for government to do this or get funding for a “Public Program – Right-to Know, on Chemicals and develop a Toxics Use Reductions Program. –Anna Tilman
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