Notice of objection: Hymopack Ltd.

Hymopack
41 Medulla Ave., Toronto, Ontario, Canada M8Z 5L6
Tel: (416) 232-1733
Fax: (416) 232-2194


December 3, 2020


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

Dear Honourable Wilkinson:

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 Toxic Substance to Schedule 1 to the Canadian Environmental Protection Act, 1999

Hymopack is a private Canadian company that employs more than 170 employees in its manufacturing facility in Toronto, Ontario. Hymopack manufactures plastic shopping bags that are highly reused (77% reuse rate according to the Life Cycle Analysis conducted by Recyc Quebec), recyclable, sanitary and incorporate recycled material.

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

Hymopack supports the Government’s goals of reducing the amount of plastic waste that ends up in landfills and moving towards a more circular economy for plastics. In particular, Hymopack supports the CCME strategy of Zero Waste and encourages the Government of Canada to provide incentives for the development and expansion of the recycling infrastructure in Canada.

Hymopack

Possible headings: No Screening Assessment Completed, Lack of Screening Assessment, Draft Screening Level Risk Assessment Requirement, Inconsistencies in the CMP Process, Deviation from Established Process, etc.

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:

Possible headings: Plastic Manufactured Items are not Toxic, Incorrect Toxic Designation, Imprecise Toxic Designation, Consideration of Cause, Risk, and Exposure, etc.

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

Possible headings: Government Commitment to Sound Science, Strengthening Science in Decision-Making, Supporting Sound Science, etc.

Scientific panel

Conclusion

Should you wish additional information, please do not hesitate to contact the undersigned.


Gerry Maldoff
President

/jw

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