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

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 Mississauga, which is part of 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.

Requirement for a Proper screening assessment has not been fulfilled:

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:

Fact: 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

Governments continued reliance on Sound Science prior to decision making:

Scientific panel

In summary, all plastics are not Toxic. That is a fact.

There is no question that a proper screening and science-based approach would allow the Canadian Government to avoid this misstep and seize the opportunities around the root of the issue; pollution. Pollution and improper disposal/recycling practices are the Canadian Governments largest opportunity to make a difference.

If there is any support that myself or the industry experts at Amcor may be able to provide, we are at your service.


Sincerely,

Tino Pennino; P.Eng
Plant Director
Amcor Mississauga
245 Britannia Road East, Mississauga, ON
L4Z 4J3

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