Notice of objection: CB Supplies Ltd.

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

CB Supplies Ltd. is a master distributor and manufacturer of plumbing goods with 4 locations in Canada, and we have been in business since 1962. We employ over 100 Canadians and are a contributor to the Canadian economy. We manufacture millions of feet of polyethylene pipe for plumbing purposes every year. We believe in creating a sustainable circular economy for the plastics industry; our flagship product is PE-RT pipe which is recyclable.

CB Supplies Ltd.

Deviation from Established Process

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:

Consideration of cause, risk, and exposure

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

This entire process and proposal from the government seems unprepared, rushed, and ill-advised from a scientific perspective. The changes you are proposing to make will have substantial impacts that you are not aware of and not accounting for. The plastics industry is extremely diverse and should not be whole grouped together for a single legislative action. This type of issue is one that should be tackled by both the public and private sector. The government should be working with the industry, rather than against it.


Sincerely,

Christopher McNeil
Director of Operations
CB Supplies Ltd.

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