Summary of public comments received on the draft science assessment of plastic pollution

Comments regarding the Draft Science Assessment of Plastic Pollution were submitted by:

Air Canada, Alberta Beverage Container Recycling Corporation, Alberta Plastics Recycling Association, Amcor PLC, American Chemistry Council, American Cleaning Institute, American Coatings Association, American Fuel & Petrochemical Manufacturers, AMERIPEN, Arctic Beverages LP, Biodegradable Products Institute, Business Council on the Environment, Canadian Beverage Association, Canadian Beverage Container Recycling Association, Canadian Consumer Specialty Products Association, Canadian Environmental Law Association, Canadian Fuels Association, Canadian Paint and Coatings Association, Canadian Produce Marketing Association, Canadian Stewardship Services Alliance Inc., Canadian Vehicle Manufacturers’ Association, Carton Council of Canada, CEPA Industry Coordinating Group, Chemistry Industry Association of Canada, City of Toronto, City of Victoria, Compagnie Selenis Canada Inc, Compost Council of Canada, Compostables Canada, Consumer Health Products Canada, Cosmetics Alliance Canada, DAK Americas LLC, Dalhousie University, Danone, Divert NS, Dow Chemical Canada ULC, Electronics Product Stewardship Canada, Environmental Defence Canada, EPS Industry Alliance, Fertilizer Canada, Flexible Packaging Association, Food & Consumer Products of Canada, Foodservice Packaging Institute, Government of Newfoundland and Labrador, Husky Injection Molding Systems, Ice River Springs Water Co. & Blue Mountain Plastics, Imperial Oil, Keurig Dr. Pepper Canada, Kimberly-Clark, LEGO Systems Inc., National Association for PET Container Resources, Norwich Plastics, NOVA Chemicals Corporation, Personal Care Products Council, private citizens, Recycling Affiliate Network, Region of Peel, Responsible Distribution Canada, Retail Council of Canada, Return-It, Saskatchewan Association of Rural Municipalities, Scotts Canada Limited, Styrene Information and Research Center, Surfrider Pacific Rim, The Mosaic Company, TOMRA Canada Inc., Town of Lincoln, U.S. Tire Manufacturers Association and the Tire and Rubber Association of Canada, U.S. Vinyl Institute, Ville de Montreal, Vinyl Institute of Canada, Wacker Chemical Corporation, and Western University.

A summary of the comments and responses is organized by topic:

TopicSummarized / rolled-up commentSummarized / rolled-up response
Potential ActionsThe Canadian Environmental Protection Act (CEPA) is not the right tool for taking action on plastic pollution, and other options should be considered.CEPA is one of the federal government’s key pieces of legislation for protecting the environment and preventing pollution. Any measures developed using CEPA would be in furtherance of these goals. The Act provides a broad suite of tools that allows the government flexibility to tailor measures to the issue needing to be addressed. The government will work with partners and stakeholders to ensure that any measures developed are appropriate, fit‑for‑purpose, and avoid unintended consequences.
Potential ActionsThe Science Assessment should not be the basis for regulatory action as this is not standard practice under CEPA.  Rather, data gaps identified in the Science Assessment should be filled and a traditional risk assessment should be carried out prior to determining whether or not action should be taken on plastic pollution. The Science Assessment provides a thorough review of the available information on plastic pollution, including its sources, occurrence, and fate, as well as on the potential effects of plastics on the environment and human health. It has been peer‑reviewed and provides a science-based recommendation that action is needed, in accordance with the precautionary principle, to reduce macroplastics and microplastics that end up in the environment. The government is satisfied that the Science Assessment shows that plastic pollution is having an immediate and long-term harmful effect on the environment, in particular to wildlife and their habitat. This provides the scientific basis to proceed with action to address and prevent the harms caused by plastic pollution.
Potential ActionsSeveral commenters expressed concern over implementing actions to reduce plastic pollution during the COVID-19 pandemic. The government recognizes the importance of balancing environmental protection and clean growth with the economic importance of plastic and its role in protecting human health, in particular during this COVID-19 public health emergency. Plastics are a valuable material in our economy and in the lives of Canadians. It is important that we continue our work to increase the recovery of plastics and retain its economic value and to reduce the amount we send to landfills. Partners and stakeholders will be given opportunities to participate meaningfully in informing any measures taken. 
Potential ActionsMany comments flagged specific polymers/products as not being contributors to plastic pollution (e.g., PET and PVC). Further, several comments highlighted that the report does not assess products and therefore should not be used to support a ban on a specific product, which is incongruous with political level statements.It is not the intent of the report to draw conclusions on individual polymers or specific products but rather to survey the state of science on plastic pollution. When specific polymers are mentioned in the science assessment, it is because the cited references pertain to those specific polymers.
Potential ActionsSome commenters expressed concern that action on plastic pollution may unnecessarily impose regulations on polymers and products that are not a concern to the environment or human health.Stakeholders will be given opportunities to participate meaningfully in informing any measures taken.
Potential ActionsSeveral commenters recommended that certain products or polymers be exempt from risk management actions.Stakeholders will be given opportunities to participate meaningfully in informing any measures taken.
Potential ActionsMany commenters were supportive of initiatives to reduce plastic pollution such as extended producer responsibility programs, circular economy, incentivizing stakeholders to support efforts to minimize plastic pollution, labelling and recycling recommendations, standards for compostable plastics and bans of particular single use plastics.Stakeholders will be given opportunities to participate meaningfully in informing any measures taken.
Potential ActionsSeveral factors should be considered when developing risk management strategies for plastics. For example, recommendations included improving the recyclability of plastics, evaluating the impacts of actions on specific industries, economic considerations, consideration of the benefits of plastics, and existing infrastructures.Stakeholders will be given opportunities to participate meaningfully in informing any measures taken.
Potential ActionsRecommendation for further stakeholder engagement on plastics initiatives.Stakeholders will be given opportunities to participate meaningfully in informing any measures taken.
Potential ActionsA full lifecycle assessment (considering both start of life and end of life factors) and evaluation of potential plastic replacements (e.g., biodegradable plastics) should be carried out prior to potential regulation.Stakeholders will be given opportunities to participate meaningfully in informing any measures taken.
OverarchingQuantitative conclusions and individualized findings have not been made on specific polymers.The intent of the Science Assessment is not to draw conclusions on specific polymers, but rather to review the state of science on plastic pollution.  
OverarchingThe report does not always clearly distinguish between plastic waste and pollution.All instances of the terms “plastic waste” and “plastic pollution” have been verified and clarified where necessary.     Furthermore, the information in Section 3 has been reorganized to clarify this delineation.
OverarchingThe Science Assessment is a reasonably complete and up‑to‑date document.Noted
OverarchingComments were received relating to technical accuracy and clarity of statements made and recommendations to verify references.All appropriate technical changes have been made, statements clarified and references have been verified.
OverarchingPlastic pollution in Canada should be quantified and Canadian sources should be further characterized.To the extent possible, the Science Assessment presents currently available data on the occurrence and sources of plastic pollution in Canada. However, as discussed in the report, quantification is not possible due to a lack of appropriate and standardized methods and a lack of data across all environmental compartments.  
OverarchingThe report contains statements that support that plastics are non-toxic.The assessment presents publicly available scientific information, identifies data gaps and presents recommendations based on the findings of the report. 
OverarchingPlastics are inert and this is not recognized in the report. Moreover, Health Canada and Environment and Climate Change Canada evaluate polymers under various programs and have found some to be not toxic.The report is focused on plastic pollution and not individual polymers.
OverarchingComments were received questioning the level of scientific rigour involved in selecting and verifying references used in the Science Assessment. Recommendations were made to thoroughly validate the credibility of the sources of information presented. The Science Assessment reviews the current state of science regarding plastic pollution, and clearly acknowledges that uncertainties exist and high quality information is lacking in several study areas. Further, the report underwent external peer review from both domestic and international experts. Scientific studies discussed in the report were validated against a set of qualitative criteria (discussed in the relevant sections of the report, and now more clearly described). These criteria were based on the quantitative criteria established by Koelmans et al. (2019)1 and Hermsen et al. (2018).2 Where study limitations were identified, this is clearly indicated in the text.
OverarchingThe Science Assessment should better delineate between Canadian and global data on plastic pollution and, where no Canadian data are available, a rationale for using global data should be provided.Where possible, the Science Assessment presents Canadian data; however, in the absence of Canadian data, information from other countries is presented, and the text clearly indicates whether the data is from Canada or elsewhere. In addition, given that there are multiple ways that plastic can enter the environment, and the fact that it is not always possible to elucidate that source of environmental plastic pollution, international sources may also be relevant for Canada.
DefinitionsSeveral comments were received pertaining to definitions. These comments ranged from requests to define terms (for example, single-use plastic) to requests for clarity on existing terminology in the report.   The Science Assessment explains the terminology used in the report.  Consequently, the “Terminology” subsection was added and clarification was provided to indicate that the report discusses plastic pollution in an environmental context. No additional terms were added to this section.
Definitions  Some commenters urged the Government of Canada to work towards developing a regulatory definition for microplastics, while others recommended refraining from doing so.Stakeholders will be given opportunities to participate meaningfully in informing any measures taken.
ConclusionsA conclusion of toxic should not be made under section 64 of CEPA, whether in this report or elsewhere, for plastic pollution.The government is satisfied that the Science Assessment shows that plastic is having an immediate and long-term harmful effect on the environment, in particular to wildlife and its habitat. This provides the scientific basis to proceed with action to address and prevent the harms caused by plastic pollution.
ConclusionsThe science assessment should be amended to conclude toxic under section 64 of CEPA.The government is satisfied that the Science Assessment shows that plastic is having an immediate and long-term harmful effect on the environment, in particular to wildlife and their habitat. This provides the scientific basis to proceed with action to address and prevent the harms caused by plastic pollution.
Executive SummaryThe Executive Summary does not accurately reflect the lack of reliable studies and associated uncertainties.The Executive Summary was reviewed and changes were made where appropriate to better convey the state of science as presented in the body of the report, including reflecting the issue of quality studies and associated uncertainties.
Scope  The report should be altered to align with the scope.As stated in the Science Assessment, the focus of this report is on plastic pollution, and it is limited to a review of the occurrence of macroplastics and microplastics resulting from plastic entering the environment. 
Composition, properties and usesAdditional polymer types should be included in Table 2‑1 as well as in the text.Some additional discussion on polymer types and uses was included, where appropriate. Table 2-1 is a list of examples and not a complete list; therefore, no change was made.
Sources of plastic pollutionRequest to clarify that waste from vehicle parts, including managed end-of-life tires, do not result in plastic pollution as these generally enter managed waste streams.This has been clarified.
Sources of plastic pollutionTire wear should not be identified as a source of microplastics in outdoor air.  Tires are made of rubber, which is not considered to be plastic.It is not the intent of this report to define plastics and it is recognized that whether or not rubber is considered a type of plastic is the subject of some debate at this time.     This has been clarified in the report.
DegradationClarity is required with respect to degradation. Specifically, it was noted that there is a need to differentiate degradation pathways under different conditions, that not all plastics degrade at the same rate, or in the same manner and that many plastics are not recyclable or compostable.It is acknowledged in section 4.1 that there are multiple factors that may influence degradation.     Further, the text regarding biodegradable, compostable, biobased, and oxo-degradable plastics was rewritten.
DegradationMany commenters stated that bioplastics should be referred to as biobased plasticsThe term bioplastic has been changed to biobased plastic.
DegradationCommenters noted issues with section 4.1.1. These issues included the incorrect treatment of compostable, biodegradable, and biobased materials (CBBs) as conventional plastics as well as inaccurate definitions and statements.This section was rewritten. CBBs are now discussed separately from other types of plastic. In addition, all terms have been clarified and references have been checked for accuracy.
Environmental occurrenceComments were received expressing concern regarding the lack of identified plastic debris in the report.A thorough review of available information on plastic pollution in Canada was presented and data gaps were identified. Individual items were discussed when possible and uncertainties surrounding the quantification of plastic litter were acknowledged. Further, surveys on litter have been included to provide additional information on the issue of plastic debris.
Impacts on human healthKnowledge of the health effects of airborne particles, and general concepts from particle toxicology should be used to inform the human health effects of inhalation exposure to microplastics, and the proportion of microplastics in the respirable size range should be quantified.The Science Assessment includes a broad discussion of potential inferences that can be made from concepts in particle toxicology; however, a discussion of the results of toxicity studies on particulate matter was considered beyond the scope of the report. Moreover, the report acknowledges that further inferences could possibly be made from the large body of knowledge that exists on particulate matter, but additional information on the relationship between airborne microplastics and particulate matter would be required before this is possible.
Impacts on human healthSome studies cited have significant weaknesses that were not sufficiently explained in the Science Assessment. Uncertainties in the scientific literature regarding the human health effects of microplastics should be more adequately represented, both in Section 7 and in the Executive Summary.Weaknesses in studies have been identified where appropriate, and uncertainties in the database made clear.
Impacts on human healthThe Science Assessment inaccurately states that human exposure to macroplastic pollution is not expected to occur.This statement has been revised in order to clarify that people regularly observe and interact with macroplastics; however, this exposure is not anticipated to pose a concern to human health.
Impacts on human healthMore emphasis should be given to recent international reviews of microplastics in drinking water and food (i.e., EFSA 20163; FAO 20174; WHO 20195), which found that there is currently no concern for human health as a result of exposure to microplastics.The Science Assessment does cite these references.  Additional information has been added to the Executive Summary and the findings sections to more clearly communicate that the current literature has not identified a concern for human health.
Transport of chemicalsRecommend to further consider chemicals known to be present in plastic, and to clarify which additives are used for which plastics.As stated in Section 8, it is beyond the scope of the report to evaluate exposure and toxicity of chemicals that may be present on plastic. This has been reviewed in the context of drinking water and food by the World Health Organization (WHO), the Food and Agriculture Organization of the United Nations (FAO) and the European Food Safety Authority (EFSA), and within the Government of Canada in other initiatives. Further, the report did not aim to attribute additives to specific plastics; rather it provides examples of additives used for plastics in general.
Transport of chemicalsClarification on the amount of residual monomers present in plastic is required.The text was clarified to present an appropriate range of monomers.
Research needsMany submissions expressed support for future research in line with the research needs identified in the report.Noted
Research needsThe research needs identified in the Science Assessment are insufficient to fill knowledge gaps. Various suggestions were given such as initiating research to improve packaging, conducting research on biodegradable, compostable and bioplastics, and investigating social and economic barriers.The intent of this report was to review the current state of science on plastic pollution. Consequently, many of the suggested initiatives, while important avenues to explore, are not within the scope of this report.  For more information on Government of Canada initiatives on plastic waste, please see:  /content/canadasite/en/environment-climate-change/services/managing-reducing-waste/zero-plastic-waste/canada-action.html 
Research needsThe research recommendations in the draft report are not specific enough and should be further delineated.The science assessment clearly highlights the uncertainties and subsequently makes broad research recommendations to help resolve these uncertainties. The Government of Canada has a diverse set of research initiatives currently underway. For more information, please see: /content/canadasite/en/environment-climate-change/services/managing-reducing-waste/zero-plastic-waste/canada-action.html and/content/canadasite/en/environment-climate-change/services/environmental-funding/programs/increasing-knowledge-plastic-pollution-initiative.html.
FindingsThe precautionary principle should not be used to support taking action on plastic.Measures developed under CEPA will be guided by the precautionary principle, which in the Act states that "where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation." This mirrors the language of Principle 15 of the Rio Declaration, to which Canada is a signatory. The government is of the opinion that actions to address plastic waste and eliminate plastic pollution would be in accordance with this principle, given the findings and recommendations of the Science Assessment.
FindingsSome commenters indicated support for the use of the precautionary principle.Noted
FindingsMany commenters indicated support for the findings of the Science Assessment.Noted
ReferencesReferences to articles in the popular press should not be cited in the Science Assessment.These references have been removed.
ReferencesSeveral commenters provided suggested references to add to the report and suggested that some references be removed.All references provided were reviewed and added, if appropriate (e.g., were checked against appropriate criteria for inclusion, if applicable). Similarly, references suggested for removal were reviewed and, when appropriate, were removed. 
OtherSome submissions commented that the science assessment is in violation of the Canada-United States-Mexico Agreement (CUSMA). Notably that each party shall endeavour to use a risk-based approach to assessment of specific chemical substance and mixtures, where appropriate. Further, it was noted that actions could implicate the Technical Barriers to Trade (TBT) Chapter of CUSMA and World Trade Organization (WTO) TBT Agreement Articles 2.2 and 2.9.  The Government of Canada is aware of its international trade commitments and will continue to respect them. It also recognizes the importance of regulatory cooperation. A central pillar of the government’s commitments to regulatory cooperation in trade agreements is the maintenance or enhancement of standards for environmental protection and public health and safety. A risk-based approach to managing chemicals is reflected in the Chemicals Management Plan and relevant trade agreements. However, the government is not limited to chemical risk assessments in order to better understand threats to environmental quality and determine whether action is necessary to prevent pollution and protect the environment.
OtherThe title of the report should be changed from Science Assessment of Plastic Pollution to State of Science of Plastic Pollution.The title accurately reflects the scope and intent of the report and was not changed to avoid confusion.
OtherCollaboration and synergies with the US on plastics initiatives is encouraged.Noted
OtherA commenter noted that other polymers are being explored as options for sustainable products.Noted. Consideration of alternatives to plastic is beyond the scope of this report.

a Hermsen E, Mintenig SM, Besseling E, Koelmans AA. 2018. Quality criteria for the analysis of microplastic in Biota Samples: A Critical Review. Environ Sci Technol. 52(18):10230-10240.
b Koelmans AA, Mohamed Nor NH, Hermsen E, Kooi M, Mintenig SM, De France J. 2019. Microplastics in freshwaters and drinking water: Critical review and assessment of data quality. Water Res. 155:410-422.
c [EFSA] European Food Safety Authority. 2016. Presence of microplastics and nanoplastics in food, with particular focus on seafood. EFSA J. 14(6):e04501.
d [FAO] Food and Agriculture Organization of the United Nations. 2017. Microplastics in fisheries and aquaculture: Status of knowledge on their occurrence and implications for aquatic organisms and food safety. Technical Report. Rome (IT): FAO. 126 p. Report No. 615.
e [WHO] World Health Organization. 2019. Microplastics in drinking-water. Geneva (CH): WHO. 101 p.

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