The undersigned organizations and experts support the following Submission to the Ministers of Environment and Climate Change and Health on Bill C-28, An Act to Amend the Canadian Environmental Protection Act, 1999, etc. submitted by the Canadian Environmental Law Association in February 2022. This submission is relevant for Bill S-5 (An Act to amend the Canadian Environmental Protection Act, 1999, to make related amendments to the Food and Drugs Act and to repeal the Perfluorooctane Sulfonate Virtual Elimination Act) released on February 9, 2022.
“Advanced recycling” is an umbrella term, sometimes also called “chemical” or “molecular recycling” that encompasses an ever-growing list of technologies that are speculative when it comes to recycling plastic. The reality is that there is no known commercial example of an “advanced recycling” facility anywhere in the world that turns plastic waste back into plastic products or packaging.
Canada has committed to ending plastic waste by 2030.i Reaching this goal will require ambitious actions that address the full life cycle of plastic.
Canada is a major—and growing—producer of plastics and the world’s second highest user of plastic on a per person basis.ii Production, use and disposal of plastics is an increasing contributor to climate change and habitat degradation. It also imposes disproportionate harm on those living next to production and disposal facilities, often low-income and Black, Indigenous and People of Colour communities.
We, the undersigned, therefore call on the Government of Canada to commit immediately to implement the following actions on an urgent basis:
Immediate action on plastics is necessary. The government’s Science Assessment on Plastic Pollution, referenced in the Regulatory Impact Assessment Statement, confirmed that plastic pollution is widespread in Canada, causing a range of adverse effects on wildlife and ecosystems. Furthermore, there is strong public support for federal action. Recent polling found that 95 per cent of Canadians are concerned about plastic pollution and 86 per cent support a federal ban on single-use plastics. Every day Canada fails to act, another 7,900 tonnes of plastic waste end up in our landfills and environment.
While we strongly support maximizing consultation opportunities, we also support timely action to address long understood but neglected problems with CEPA, a law that has not been significantly amended in two decades.
We at the ORA fully support strengthening the Canadian Environmental Protection Act (CEPA) through the list of 87 recommendations made by The Standing Committee on Environment and Sustainable Development in its Eighth Report, tabled on 15 June 2017. The ORA supports the right to a healthy environment. Healthy communities, a healthy economy and a healthy environment are essential to Canada’s sustainability. A review of the Act presents the federal government with a golden opportunity to improve the health and well-being of all people in Canada.
The government’s proposed P2 Plans on triclosan are inadequate to address its continued use in consumer products and presence in the environment. Rather, the government’s proposal will ensure the on-going use of triclosan in consumer products. Unless there is a prohibition of triclosan in personal care products and other consumer products, the substance will continue to be released into the aquatic environment, including the Great Lakes and waterbodies across Canada, creating unnecessary risks to aquatic and terrestrial species. The US Food and Drug Administration (FDA) requested data demonstrating that consumer products containing antimicrobial ingredients are effective in their stated purpose – to prevent infections. The FDA did not receive such data and therefore passed its final decision to prohibit the use of triclosan and triclocarban along with 18 other antimicrobial chemicals in consumer antiseptic wash products that are rinsed off after use, including hand washes and body washes, starting in September 2017.20 The State of Minnesota passed a regulation to prohibit the use of triclosan in sanitizing or hand and body cleansing products starting in January 1, 2017.21 If regulatory measures to prohibit the use of triclosan in consumer products are not taken in Canada, it may become a dumping ground for products containing triclosan and other antimicrobial chemicals that are subject to these regulations. Continue reading
The Canadian Environmental Law Association (CELA), Chemical Sensitivities Manitoba, Ontario Rivers Alliance, Ottawa Riverkeeper, Prevent Cancer Now and Citizens Network on Waste Management are submitting the following comments in response to the Canada Gazette publications (Vol. 150, No. 48 — November 26, 2016) for the Publication of final decision after assessment of a substance — phenol, 5-chloro-2-(2,4-dichlorophenoxy) [triclosan], CAS RN (3380-34-5) and Canada Gazette (Vol. 150, No. 50 — December 10, 2016) for Order Adding a Toxic Substance to Schedule 1 to the Canadian Environmental Protection Act, 1999 (CEPA 1999). In addition, we are also offering comments on the proposed Management Strategy for triclosan.2