Notice of objection: Amcor Packaging Canada Inc. (Amcor Brampton)

The Honourable Jonathan Wilkinson, P.C., M.P.
Minister of the Environment
c/o The Executive Director Program Development and Engagement Division
Department of the Environment
Gatineau, Quebec K1A 0H3

eccc.substances.eccc@canada.ca


RE: Notice of Objection and Request for Board of Review in relation to the Proposed Order to add plastic manufactured items to Schedule 1 to the Canadian Environmental Protection Act, Canada Gazette, Part I, Volume 154, Number 41: Order Adding a Toxic Substance to Schedule 1 to the Canadian Environmental Protection Act, 1999

I am the Plant Director for Amcor Brampton, which is part of the Amcor Packaging Canada Ltd. Our parent company is Amcor which is a global leader in developing and producing responsible packaging for food, beverage, pharmaceutical, medical, home- and personal-care, and other products. We have 230 facilities in over 40 countries. Last year we had over 12.5 Billion USD in sales.

Amcor is also a member of the Chemistry Industry Association of Canada’s (CIAC) Plastics Division, which represents Canada’s leaders in plastics industry sustainability - a $28 billion sector that directly employs over 93,000 Canadians.

Amcor Packaging Canada Ltd.

Lack of Screening Assessment:

The final science assessment of plastic pollution is not / does not fulfill the requirement for:

A draft screening level risk assessment (DSLRA) would:

Other inconsistencies in established CMP process for adding substances to Schedule 1:

Plastic manufactured items are not toxic

The Proposed Order

Risk to the environment

Tradition of CMP: materials are not found to be toxic when the exposures of concern do not emanate from an intended use

Science approach document

Strengthening science in decision-making:

Scientific panel

A few main points that I want to emphasize; food and healthcare products are longer lasting and retain their economic value longer because of the packaging that has been developed. The recycling of plastics allows for the reduction of costs and the improvement of environment, once produced, certain plastics can be reused over and over with minimal resource investment. In conclusion, I am available for discussion, myself and others of the Amcor team are available and willing to join and assist with any discussion and panel involvement.


Sincerely,

Arnold Anderson; P.Eng
Plant Director
Amcor Brampton

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