Summary report May 16, 2013 - Chemicals Management Plan Stakeholder Advisory Council
Chemicals Management Plan Stakeholder Advisory Council Meeting
- David Morin (Director General, Science and Risk Assessment, Environment Canada [EC])
- Amanda Jane (AJ) Preece (Director General, Safe Environments Directorate, Health Canada [HC])
- Council members present:
- Susan Abel
- Andrew Black
- Dr. Joseph Byers (for Dr. Victor Goldbloom)
- Shannon Coombs
- Bruce Cran
- Fe de Leon
- Roger Keefe (for John Skowronski)
- Shelagh Kerr
- Amardeep Khosla
- Gary Leroux, Gordon Lloyd, Eric Loring
- Maggie MacDonald
- Sandra Madray
- Keith Mussar
- Mary Richardson
- Dr. Don Spady
- Government officials present:
- Michelle Bowerman (Manager, Program Liaison, EC)
- Greg Carreau (Executive Director, Program Development and Engagement Division, EC)
- Robert Chénier (Director, Ecological Assessment Division, EC)
- Nicole Davidson (Director Emerging Priorities Division, EC)
- Brad Fisher (Manager, Nanotechnology Section, EC)
- Vincenza Galatone (Executive Director, Chemicals Management Division, EC)
- Doug Green (Senior Policy Advisor, Director's Office, New Substances Assessment And Control Bureau, HC)
- Stephanie Haddad (Policy Analyst, CEPA Governance and Reporting, EC)
- Doug Haines (Director, Chemicals Surveillance Bureau, HC)
- Alexandra Halkett (Manager, Program Development and Engagement Division, HC)
- Michael Hodgins (Program Development and Engagement Division, HC)
- Michelle Lee (Program Liaison Section, EC)
- Barb Minish (Manager, Regulatory Policy Section, EC)
- Christine Norman (Director, Existing Substances Risk Assessment Bureau, HC)
- Virginia Poter (Director General, Chemicals Sector, EC)
- Nellie Roest (Manager, National Biomonitoring Division, HC)
- John Worgan (Director, Director's Office in New Substances Assessment and Control Bureau, HC)
- Dr. Victor Goldbloom, Lorena Ligori, John Skowronski, Lee Wilson
Participants were welcomed and changes to membership were announced, Karen Lloyd (former Council co-chair) and Margaret Kenney (DG, Chemicals Sector Directorate, EC) have retired and have been replaced by Amanda Jane (AJ) Preece and Virginia Poter, respectively.
An update on the Chemical Management Plan (CMP) Science Committee was provided. Members were reminded that the objective of the Committee was to bring broad scientific expertise to new and emerging issues pertinent to the program in its current phase (for example, use of analogues in risk assessment). Good progress was being made on the formation of the committee including:
- Nominations ended in mid-April, over 20 applications from Canadians and from abroad were received.
- Evaluations are currently underway and once the Committee is established, it will be posted on the Chemical Substances Website.
- An orientation session will be held this summer or fall, followed by one or two meetings this fiscal year.
It was suggested that for continuity it would be useful to have members from the previous Challenge Advisory Panel sit on the new CMP Science Committee. Government informed the members that former Challenge Advisory Panel members could apply and would be given the same consideration as other nominees.
Agenda Item 1 - Stakeholder Engagement under the CMP: Activities to move forward and the CMP Progress Report
HC and EC staff provided an overview of current Stakeholder engagement activities under the CMP and proposed new activities with the goal of expanding program wide communication and engagement. The second component of this agenda item was the presentation of a conceptual CMP Progress Report with the intention of soliciting feedback on the level and type of content included. There was discussion about CMP outreach in general which included:
- The Chemical Substances Web site (CS Web site) was viewed positively but there were concerns expressed that transition to one government web site may lead to lack of content control or a loss of content. It was also suggested that information about Nanomaterials and Endocrine disruptors be added to the CS Web site. There was also concern raised that recent activities to reduce the number of pages on the web site would result in a decrease in transparency.
- Members supported suggestions of regular face to face meetings and increased outreach to complement the update document. It was highlighted that the web site and web-based consultation are important but need to be balanced with building personal relationships.
- It was also suggested that CMP could leverage business development groups within foreign consulates to increase knowledge and communication of CMP to an international audience.
Commentary for CMP Progress Report
There was support for the draft progress report. Members agreed that the product will fill the gap identified at the last Council meeting to improve and broaden communication about CMP activities. Some specific suggestions and comments included:
- Better consideration of diverse audiences and varying knowledge levels by:
- Including introduction on the overall history and goals of the CMP to add context and explain how various aspects of the program fit together.
- Defining terms and acronyms by potentially including a glossary.
- The upcoming dates/forward agenda portion of the Progress Report was seen as valuable but emphasized that the report needed to be timely enough for people to be able to use this information effectively.
- Members suggested that publication should be twice per year to provide better information flow and to allow a more focused approach with each issue.
- It was agreed that improved graphics and more precise language would be required prior to final publication. Government indicated that that was the intention.
Agenda Item 2 - Overview of the Results of Biomonitoring Data from the Canadian Health Measures Survey (2009-2011), and Linking Monitoring Data with CMP Initiatives
HC officials presented background information and highlights from the biomonitoring component of the second cycle of the Canadian Health Measures Survey (CHMS), 2009-2011. This is a follow-up to the presentation given in November 2012 which was focused on communicating the release of the results. The next steps in using this valuable information were outlined.
A second presentation by EC provided an overview of the CMP environmental monitoring program.
With respect to the biomonitoring program, questions were asked about whether there were any specific concerns about these chemicals in humans. Government responded that almost all of the chemicals monitored were covered under CEPA regulations or had been assessed domestically and were known to be harmful. However, the presence of chemicals does not necessarily mean there will be an effect. It was also noted that CHMS is a cross-sectional study with new people being sampled for each cycle.
There was also discussion on if and how First Nations and Inuit groups were reflected in the studies and a question about whether sites selected for environmental monitoring sufficiently represented the Aboriginal situation. Additionally, based on the statistical analysis approach in the study, there was a question regarding how to address specific groups of people with higher levels of chemicals. Government responded that monitoring sites are selected by certain criteria and therefore may not represent the situation in Aboriginal communities. It was agreed that more discussion between Government and Aboriginal representatives could improve the monitoring on reserves. It was also clarified that the CHMS includes Aboriginals who live off-reserve. Aboriginal groups who live on reserve are covered by the First Nations Biomonitoring Initiative (FNBI) which is being led by the Assembly of First Nations (AFN) and the report will be coming out later this summer. The presenter also indicated that the Northern Contaminants Program (NCP), a partnership with Aboriginal Affairs and Northern Development Canada (AANDC) has been providing funding for research and monitoring for northern Inuit populations providing time trends since 1991.
There was discussion about how data collection influences policy decisions and whether there is an evaluation of previous policy against new data. Government officials said that there are requirements in place that ensure they review policy instruments as new information is gained so this analysis does happen.
Agenda Item 3 - Improving the Use of Science in Regulatory Decision-Making
Dave Shortt from Dow Chemicals presented a paper from The Keystone Center dealing with conflict of interest and bias in scientific advisory panels and improving systematic scientific reviews. The paper represented the perspective of a broad range of participants, including non-governmental organizations, Government and Industry with the overarching goal to improve credibility, quality and results of science based decision making. Members were asked to discuss how the ideas presented in the paper could be used to benefit CMP.
- It was suggested that an applicable example in CMP could be the selection of members to the Challenge Advisory Panel.
- There was a discussion about the systematic reviews mentioned and concern over whether narrow enough questions could be asked as well as the issue of dealing with insufficient data. Both narrow and broad questions could be relevant and where data was deficient it would perhaps be a good idea to stop a review at that point and acquire the additional data. However, it was acknowledged that stopping a review would be difficult given the speed at which society and industry now move.
- It was highlighted that industry can and has contributed to increasing knowledge by taking a lead on developing exposure modelling which is then shared with government.
- There was a discussion about the perceived adversarial nature of scientific panels, which is somewhat similar to the Council's multi-stakeholder approach. Mr. Shortt highlighted the importance of a willingness of all to make it work. It was also pointed out that Government needs to be accepting of the feedback and advice it receives from these groups.
Mr. Shortt closed by saying that governments need some flexibility but they should have more openness and transparency. The paper showed that a number of groups can come together and build some consensus. The paper's measure of success can be shown by how often it is cited.
Agenda Item 4 - Operational Policy for Significant New Activity Notices
EC officials provided an overview of the draft operational policy for use of the Significant New Activity (SNAc) provisions of CEPA 1999. The draft operational policy includes key elements of when SNAcs are considered, design and information requirements, assessment of new information, and action taken after assessment. The policy was released to various groups for comment in April 2013. Comments will be integrated to finalize the document along with feedback received from Council members.
- There were questions raised regarding the rigidity of the information requirements. Government explained that it is able to specify the type of additional information needed in the SNAc depending on the potential data needs regarding the new activity with the substances.
- There was a question about the timelines to respond to notifiers and whether Government was able to meet these timelines with regularity. Government was pleased to inform members that they have never missed a timeline to notify. There was also a question about the role for consumers in the SNAc process. Members pointed out that there were additional challenges to contribute to SNAcs on the New Substances Program given the constraints around confidential business information. Government agreed that responding to a SNAc is primarily the responsibility of industry. It was highlighted that there are other avenues for consumers to express concerns or input new information to the program.
Agenda Item 5 - Update on Nanomaterials
EC and HC officials provided an overview of the domestic and international work on nanomaterials. The presentation reviewed briefly the current regulatory context of nanomaterials, including definitions and frameworks; domestic and international research; and the Regulatory Cooperation Council.
There was a question raised regarding potential risk to human health and the environment associated with these substances. Government indicated that similar to other substances, risk is assessed prior to use by industry. Also, research on potential hazards is ongoing and will continue to increase the knowledge of this group of substances. Much of the ongoing and recently completed work under the Organization for Economic Cooperation and Development (OECD) has tried to address these types of issues.
Some questions were also raised regarding the assessment of nanomaterials with respect to the risk assessment paradigm and the tools available to manage the potential risks, if identified. It was noted that the OECD Working Party on Manufactured Nanomaterials (WPMN) released a mid-term review which concluded that the risk assessment approach for chemicals is generally applicable to nanomaterials, although minor modifications may be required (for example, modifications to test guidelines). As more knowledge is acquired, such as through the Sponsorship Programme of the WPMN, this will further inform the risk assessment process. Since nanomaterials are addressed under the New Substances Program, the same mechanisms are available to control or manage nanomaterials in the event of a conclusion of potential risks (for example, SNAcs, conditions).
A question was raised regarding how information will be gathered since there is probably not a wealth of domestic information available. Similarly, the group requested more information on the global production and database of nanomaterials and their products. Government explained that part of the work of the WPMN was the recognition that no one jurisdiction has the capacity to do all the work so it was imperative to work cooperatively with international partners. While Canada is benefitting from the collaborative work of the WPMN, the Government is also supporting research both in-house and with academia to address a number of issues. Government also committed to sharing OECD documents on the global production of nanomaterials.
A question was raised on how many nanomaterials have been added to the Domestic Substances List. To date, only one substance, nano-crystalline cellulose has been added to the Domestic Substances List. Several tests were conducted and there was no evidence of any toxic effects. Regarding nanoforms of Domestic Substances List substances, an advisory letter was published in 2007; however, Government is considering an update of the advisory letter to provide further clarification.
There was one suggestion that the Government provide plain language communication on nanomaterials. This suggestion was noted.
Closing remarks and Proposed Agenda Items
The co-chairs thanked Council members for the valuable discussion and invited any additional input on the day's discussion. Both AJ Preece and Virginia Poter each addressed the group indicating how they appreciated the discussions that occurred throughout the day and how they looked forward to working with the group in the future.
The following topics were raised as future agenda items:
- Linkages between the CMP and the National Pollutant Release Inventory (NPRI);
- Results of monitoring studies outside of the CHMS, in particular in First Nations communities;
- Alternative assessments, safer alternatives and green chemistry in the context of CMP (follow-up request to cover this topic was made at a previous CMP SAC meeting); and
- Application of the precautionary principle in decision making.
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