Notice of objection: C-P Flexible Packaging
December 8, 2020
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
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
CP Flexible Packaging, Aurora Ontario, producer of sustainable flexible packaging
CP Flexible Packaging 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. Our plant in Aurora employs over 200 employees.
CP flexible packaging]
formally objects to the Proposed Order
requests the establishment of a Board of Review to review the recommendation
Lack of screening assessment
The final science assessment of plastic pollution is not / does not fulfill the requirement for:
a screening assessment, and/or
a screening assessment of all ‘plastic manufactured items’ (insufficient basis for the broad category identified in the Proposed Order)
A draft screening level risk assessment (DSLRA) would:
have a different conclusion;
would not have led to such a broad designation;
show a significant weight of evidence to suggest that the risk to the environment is not from plastic manufactured items; and
show that the risk is not related to the physical/chemical properties of the designated items
Other inconsistencies in established CMP process for adding substances to Schedule 1:
- Not offered for public comment in draft form
Possible headings: Plastic Manufactured Items are not Toxic, Incorrect Toxic Designation, Imprecise Toxic Designation, Consideration of Cause, Risk, and Exposure, etc.
The Proposed Order
not as specific as Science Assessment, which correctly identifies the potential harm of plastic pollution in the environment
applies to every single piece of plastic in Canada, without exception, regardless of how it is disposed
Risk to the environment
does not come from the item, but from behaviours, decisions and/or contract obligations of consumers, waste management groups and municipalities.
Intervening steps that must occur before alleged risk to environment presents:
the plastic manufactured item has to be used by a consumer;
the plastic manufactured item has to be improperly disposed of;
poor municipal waste management practices could also contribute
Declaring plastic manufactured items as toxic when these acts contribute to the adverse outcome ignores the true cause(s) of the unacceptable risk or The true cause(s) of the unacceptable risk are disregarded in this proposal
Tradition of CMP: materials are not found to be toxic when the exposures of concern do not emanate from an intended use
- the identified risk does not come from the plastic item itself; it is from disposal after intended use.
Science approach document
published without a complete view of the best available science or lacks a comprehensive review of scientific literature
DSLRA approach would have:
led to a more fulsome review of scientific literature and application/contextualization to pollution in Canada
would not have concluded that all plastic manufactured plastic items have the potential to cause ecological harm.
designation must be more precise to target individual concerns
Government commitment to sound science
should be established to review government’s work
has no vested political interest in the outcome of the investigation
government admitted to scientific gaps in Science Assessment that preclude the ability to conduct a quantitative risk assessment - panel could fill these gaps
Moving ahead with significant data gaps is not overly precautionary
consistent with the Prime Minister’s instructions in the Minister’s mandate letter to ensure that “(t)he Government of Canada is committed to strengthen science in government decision-making and to support scientists’ vital work.”
ECCC’s Economic Study of the Canadian Plastic Industry, Markets, and Waste (2019) indicates that plastic leakage (pollution) into the environment from Canada is 1 per cent.
Director of Innovation
CP Flexible Packaging
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