Notice of objection: St. Johns Packaging Ltd.

St. Johns Packaging
December 9, 2020
80, Moreau, St-Jean-sur-Richelieu
Québec, Canada, J2W 2M4

Thomas Kruidenier
Interim Executive Director, Program Development and Engagement Division
Environment and Climate Change Canada
Gatineau, Québec, KIA 0H3

eccc.substances.eccc@canada.ca

RE: Response to the Government of Canada's proposed order adding "plastic manufactured items" to Schedule 1, the List of Toxic Substances, under the Canadian Environmental Protection Act (CEPA) published on October 10, 2020 in Canada Gazette, Part I, Volume 154, Number 41.

Mr. Kruidenier,

Founded in 1954, St. Johns Packaging Ltd. is a vertically integrated manufacturer of flexible packaging products that are sold to leading food and consumer product companies. We are a member of the Chemistry Industry Association of Canada (CIAC), the association for Canada's chemistry and plastic sector leaders, innovators, solution providers, and world-class stewardship pioneers.

We are committed to developing sustainable and economically viable flexible packaging solutions that reduce plastic and food waste. In fact, 100% of the flexible packaging products (mainly polyethylene wicket bags) we manufacture and sell in Canada are recyclable. We are also proud members of the Sustainable Packaging Coalition and the Flexible Packaging Association. Moreover, we are continuously working towards reducing the environmental footprint of our manufacturing processes and improving our energy efficiency.

We appreciate the opportunity to respond to the Government of Canada's proposed order adding "plastic manufactured items" to Schedule 1, the List of Toxic Substances, under the Canadian Environmental Protection Act (CEPA), published on October 10, 2020 in Canada Gazette, Part I, Volume 154, Number 41.

We are convinced of the role of plastic packaging to fight food waste and to minimize the avoidable losses of natural resources regarding food production in Canada. We acknowledge the urgent need for a profound transformation of the Canadian plastic's valorisation infrastructures. We welcome the opportunity to work with the government on building the circular economy the Canadian plastics industry needs. We strongly believe it is possible to combine an efficient use of resources and plastic waste management incentives in every step of the plastic items life cycle to create a sustainable and prosperous future for the plastic producers and manufacturers.

Nevertheless, we do not support the Government of Canada's proposed order adding, "plastic manufactured items" to Schedule 1, the List of Toxic Substances, under the CEPA.

St. Johns Packaging Ltd. believes designating plastic manufactured items as "toxic" without a proper risk assessment undermines:

We urge the government to:

The following outlines our concerns with the proposed order to add, "plastic manufactured items" to Schedule 1.

Proposed addition to Schedule 1, broad target under proposed order

We believe the well-established risk assessment pathways under CEPA and the CMP are rigorous and scientifically sound. This chemical management policy framework needs to be upheld for the CMP to remain credible.

The proposed approach regarding plastic manufactured items raises the following concerns:

Final science assessment of plastic pollution, data gaps

St. Johns Packaging Ltd. agrees with:

Additional study is required to determine the scientific factors and consequent risks associated with specific substances before any risk management actions should be taken.

Precautionary principle, risk assessment

Precautionary principle.

The precautionary principle has been applied inappropriately.

Treaty obligations and trade

Parties to the Canada-United States-Mexico Agreement (CUSMA) agreed to a risk-based approach to chemicals management.

The government has already proposed to ban six categories of single-use plastics, yet it remains unclear how many more plastic items will be banned once plastic manufactured items have been added to Schedule 1. It also remains unclear on which scientific or legal basis the government will assess these future plastics items.

In conclusion, St. Johns Packaging Ltd. is against the Government of Canada's proposed order adding "plastic manufactured items" to Schedule 1, the List of Toxic Substances, under the Canadian Environmental Protection Act (CEPA), published on October 10, 2020 in Canada Gazette, Part I, Volume 154, Number 41 and expresses the following concerns:

We recommend that the Government of Canada conduct a thorough assessment of the underlying risks associated with specific substances to identify and evaluate appropriate, targeted, cost-effective measures to manage those risks. We also suggest that the government evaluate the possibility to create a new list of substances under the CEPA which can help to characterize substances that are detrimental to the environment, but not toxic under section 64 of the CEPA.


Sincerely,

Marc Leclair
President and Chief Executive Officer
St. Johns Packaging Ltd.

Report a problem or mistake on this page
Please select all that apply:

Thank you for your help!

You will not receive a reply. For enquiries, contact us.

Date modified: