Minister's response to notice of objection: U.S. Vinyl Institute
April 21, 2021
Ned V. Monroe
President and Chief Executive Officer
The Vinyl Institute
1747 Pennsylvania Ave NW Suite 825
Washington D.C. 20006
Dear Ned V. Monroe:
I am responding to the Notice of Objection and request to establish a Board of Review that you filed on behalf of the U.S. Vinyl Institute regarding the proposed Order to add plastic manufactured items to the List of Toxic Substances in Schedule 1 of the Canadian Environmental Protection Act, 1999 (CEPA). The proposed Order was published in the Canada Gazette, Part I, on October 10, 2020.
Subsection 332(2) of the CEPA states that any person may file a Notice of Objection requesting that a Board of Review be established. As set out in subsection 333(1) of CEPA, the mandate of a Board of Review in this instance would be to inquire into the nature and extent of the danger posed by plastic manufactured items.
I have fully and carefully considered the issues set out in your Notice of Objection. As the scientific information and additional references provided in your Notice did not raise sufficient uncertainty or doubt in the scientific considerations underlying the proposed Order to warrant the establishment of a Board of Review, I am denying your request to establish a Board of Review. The scientific considerations that underlay the proposed Order are related to the ability of macroplastics to have an immediate or long-term harmful effect on the environment or its biological diversity as set out in section 64 CEPA.
In your Notice of Objection, you stated that the Science Assessment of Plastic Pollution was published without a complete view of the best available science. I can assure you that in preparing the Science Assessment, the current state of science regarding plastic pollution was reviewed and the assessment presented a thorough summary of the science available in the peer-reviewed literature at the time it was written. Scientific studies discussed in the report were validated against a set of qualitative criteria, and where study limitations were identified, this is clearly indicated in the text. Further, the report underwent an external peer review by both domestic and international experts, and was subject to a 90-day public comment period. The report clearly acknowledges that uncertainties exist and high quality information is lacking in several study areas.
In addition, the draft Science Assessment was peer-reviewed, both internally within the Government of Canada and externally by leading experts in the field. The internal review component involved a sequential process beginning with experts internal to Environment and Climate Change Canada and Health Canada and expanding to other government departments (Natural Resources Canada, National Research Council, and Fisheries and Oceans Canada). The external review component involved six peer reviewers. These reviewers provided expert comments and input into the report. Reviewers were chosen because of their known expertise in plastic pollution. The draft Science Assessment was also subject to a 90-day public comment period.
You also raised concerns that the exposure scenarios in the Science Assessment of Plastic Pollution were not based on peer reviewed data. As described above, all references cited in the Science Assessment, including those on exposure, were peer-reviewed and validated against a set of qualitative criteria.
With regard to the non-scientific issues raised in your Notice of Objection, as well as the non-scientific references provided, these are being considered alongside other comments received on the proposed Order and will be addressed in the Regulatory Impact Analysis Statement that is published with the final Order.
I appreciate your bringing the U.S. Vinyl Institute’s concerns to my attention.
Please accept my best regards.
The Honourable Jonathan Wilkinson, P.C., M.P.
Richard Krock, The Vinyl Institute
Aiñe Curran, The Vinyl Institute of Canada
Stan Rodriguez, The Vinyl Institute of Canada
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