Summary report of the Chemicals Management Plan Stakeholder Advisory Council Meeting, November 14-15, 2017

Purpose

The purpose of the Chemicals Management Plan (CMP) Stakeholder Advisory Council (SAC) meeting is to provide stakeholders the opportunity to offer advice and input to Government on the implementation of the CMP, and to foster dialogue on issues pertaining to the CMP between stakeholders and government, and among different stakeholder groups.

Meeting objectives

The objectives of the November 2017 CMP SAC meeting were to seek stakeholder views on:

  • informed substitution under the themes of encouraging safe/green chemistry, building expertise/capacity and taking action or influencing policy
  • which CMP activities motivate action to reduce human exposure and releases of chemical substances

DAY 1

Opening remarks

The Co-chairs welcomed the members of the CMP SAC, and introduced the observers present. They provided an overview of the agenda, and explained that the number of topics presented by government officials was reduced in order to dedicate more time to discussions. They encouraged members to provide feedback on this new approach during the discussion on that agenda topic. The Co-chairs asked members if they had additional items to add to the agenda.

SAC members:

  • requested changes to the format of the meeting summary, indicating that it was important to reflect more of the discussion and any specific points raised for action
    • Co-chairs acknowledged comments, noted that improvements would be made, and encouraged members to provide input and/or changes to the summaries during the member comment period
  • expressed that it was important to receive meeting material in advance in order to consult with their constituents' members and provide feedback
    • Co-chairs acknowledged members' request and discussed amenable timing

Agenda item: discussion on proposed changes in meeting structure and format

A review of the mandate and purpose of the SAC was presented by government officials.  Members were informed that the changes in meeting format were based on comments received from members and government participants at previous meetings, including:

  • the time allowed for the many subjects was insufficient for a fulsome discussion
  • while improvements had been made recently, many topics did not provide sufficient opportunity for members' input to be considered as the topics or items were often at an advanced stage of development and focused more on updates than discussion

SAC member responses:

  • Members generally supported the change to focus on a couple of key topics for discussion, allowing for a more substantive and focused discussion
  • Some members reserved judgement until going through the process, and government officials indicated they would provide a follow-up survey to capture member comments
  • Members noted the time and resource burden of having 3 consecutive days of meetings, and suggested that a teleconference or webinar be held in advance of the meeting to share background materials and information.
    • This would provide more focus for future discussion, thus spreading out (and perhaps shortening) the face-to-face interaction required while still maintaining a meaningful and constructive dialogue
  • While some members welcomed the reduced number of topics, it was suggested that this change be kept in mind when prioritizing topics and reviewing the forward agenda
    • It was also noted that specific working groups for member engagement and/or further discussion on certain the topics may be required
  • Members would like to have meeting materials as early as possible to allow time to prepare for the meeting
    • It was recommended that 6 weeks in advance would provide enough time for members to consult with their constituents
    • Background material and links to information are appreciated
    • The CMP Science Committee was suggested as a model for material distribution: material is circulated 6 weeks in advance of meetings for this group, followed by an information webinar 4 weeks in advance of the meeting
  • Members were very supportive and welcomed the idea of having external experts present on themes being discussed at SAC meetings (for example, Informed Substitution presentation by Dow Chemical Company scheduled on Day 2) and suggested that additional time should be considered to permit more discussions

Action item:

  • Co-chairs indicated that they would work on distributing meeting materials 6 weeks in advance and scheduling information teleconferences or webinars 3 to 4 weeks in advance of the face-to-face meetings, as needed

Agenda item: high level updates on the CMP

Government officials provided updates on recent and ongoing activities under the CMP, which include research and monitoring, information gathering activities, stakeholder activities, risk assessment, risk management, international work and the work taking place on post-2020 chemicals management.  A presentation summarizing the updates was distributed.

Members were invited to respond to a short survey planned for 2018 soliciting their feedback on the new "information sheets".  Information sheets are web pages that summarize CMP risk assessment and risk management activities.  They replace what were called the "public summary" web pages. The changes made reflect feedback received from SAC in 2014.

General issues raised during member discussions included:

  • some members cautioned that an absence of comments received during the 60-day public comment periods for draft screening assessment reports (dSARs), may not necessarily mean that there are no public comments but rather could be attributed to a lack of capacity or knowledge on behalf of organizations or the public
  • members would like to see a presentation on how the precautionary principle is considered for risk assessment decisions
  • questions from members on the Identification Risk Assessment Priorities (IRAP) processes and on how substances are prioritized for re-assessment in light of new information becoming available on a substance
  • suggestions for improvements were made for the search engine for the results of Domestic Substances List (DSL) categorization given its limitations in searching a substance's common name versus its technical name
    • government officials will investigate how improvements can be made and provide updates at a future meeting
  • regarding research and monitoring, one member noted that there is a need to emphasize research on  the effects of substances and not simply concentrations, as concentrations in living organisms can fluctuate dramatically and are not necessarily correlated with the effects of these substances on the organisms
  • concern was expressed regarding the general perception that low concentration poses low risk
    • one example of this is endocrine disrupting substances; it was suggested that the subject of endocrine disruption should be an integral component of the Government's agenda for post-2020 chemicals management
  • members emphasized that there should be a focus on hazard-based approaches rather than risk-based approaches
    • a public policy discussion on the burden of substances along with the importance of vulnerable populations could be an interesting discussion/topic in the future

Agenda item: brief review of process and discussion of topics for day 2

A government official provided an overview of the proposed changes to the format and structure for the SAC meetings. These changes are designed to better capture members' feedback. He also introduced the procedures and charge questions for the 2 topics planned for day 2.

DAY 2

The Co-chairs welcomed the members and observers to the second day of the meeting. Co-chairs indicated the second day would focus on 2 specific topics:

  1. informed substitution
  2. results and impacts of the CMP

Agenda item: informed substitution

Government officials introduced the topic, and then gathered specific input and advice from members. A presentation was provided by Dow Chemical Company experts, which illustrated a real-life perspective by a practitioner in informed substitution.  The objective of this part of the meeting was to seek advice and input from members on specific questions and themes related to informed substitution.

The government presentation described the role of informed substitution in the CMP to date, defined specific concepts and terms, and outlined why this was an important topic for the government. The discussion with SAC members will help inform future approaches or work related to the recommendations in the Standing Committee on Environment and Sustainable Development (ENVI) report, along with post-2020 chemicals management work in Canada. A summary of recent activities on this topic was provided; including the results of an international scan that was conducted by an international expert in the field of informed substitution, as well as discussions with regulatory experts from the United States and Europe. Government officials then presented 3 themes for members to provide written input on. The themes were identified on flip charts around the room and included:

  1. encouraging safe/green chemistry
  2. building expertise and capacity
  3. taking action or influencing policy

Members were invited, through a series of questions under the themes, to provide advice according to their positions or their constituencies. A fourth theme was put forward by members, related to adding criteria to the evaluation of substitutes to consider whether or not a chemical is really needed.

Members were also encouraged to vote for, or prioritize, specific themes or ideas.

Following the exercise there was a brief discussion on the highest prioritized themes, and government officials stepped away to document and capture all the written comments provided, and summarize them in a presentation that was brought back to the members.

Practitioners' example from Dow Chemical Company in identifying an alternative or substitute

This presentation was made by guest presenters David Shortt and Dr. Christine Lukas from the Dow Chemical Company. The presentation was a practical application example of the process undertaken by industry to identify and evaluate alternatives to a flame retardant. Presenters acknowledged that some information was either not provided, or was masked in order to protect confidential business information.

The presentation was well-received by SAC members and generated an engaged question and answer period and discussion.  Specific discussion items included:

  • members appreciated the presentation from Dow Chemical Company and noted that these types of expert presentations should occur again
  • these types of innovative research initiatives are very costly
    • members noted the need for regulation as an important driver for them
  • members asked about the costs associated with finding the specific substitute and also commented on the need to explore the environmental costs in finding safer alternatives
  • the importance of lifecycle consideration for chemicals is an important aspect of the informed substitution because the hazardous substances may lead to the production of toxic by-products in the environment

Government officials presented a summary of the discussion.  The presentation identified key themes that could be priority areas to advance informed substitution, including:

  • networking
    • international experts/best practices
    • identifying common priorities/approaches
  • capacity building/expertise
    • public outreach/education
    • supply chain communication/transparency (for example, workshops)
  • funding/resources
    • research and development
    • prioritizing funding/Canadian considerations
    • linking/accessing funding sources
  • science/technical capacity
    • data needs
    • methodology development and communication

Action items:

  • A follow-up teleconference was proposed to further refine member comments presented and seek specific recommendations
  • A verbatim capture of flip charts would be distributed to members for their consideration and information with the draft minutes

Agenda item: results and impacts of the CMP

Government officials wanted to better understand how the CMP motivated external stakeholders to take action to reduce exposure and release of chemical substances. They provided an overview of the CMP process, highlighting where there are opportunities for stakeholders and the public to provide comments, and sought input from members on when and how they typically take action.

Member discussion included the following comments:

  • results and impacts of the CMP should be about improving the health of Canadians through the reduction of exposure to chemicals
    • the question of who bears the most burden should be considered
  • members noted the need to seek input from their constituencies on this topic, in particular whether or not early risk management actions are initiated before a final assessment conclusion is published
  • noted the gap in knowledge between what industry is doing and what workers know and understand about chemical hazards and risks
  • noted that different sectors have responded to CMP in different ways (for example, some have focused on education within, some have focused on robust data, some have adapted to CAS RN lists, and some have developed sector-based approaches)
  • one industry member noted that much of the work done to mitigate risks is driven internationally by initiatives put in place before the CMP
    • it was also noted there is a need to leverage CMP results at the international level, as greater buy-in globally could lead to more effective results
    • requirements of other jurisdictions (for example, REACH) also influence domestic actions and/or activity, where products are exported
  • members commented that the public comment period related to publications in the Canada Gazette does not reach the general public
    • there needs to be another mechanism to ensure that people can provide input
    • one example is Health Canada's website for health consultations
  • members also noted a number of ideas for further consideration:
    • more public education regarding protection is needed
    •  the public needs legal avenues for participation
    • examine end of life of chemicals and products they're in
    • consider consumerism and growth of chemical production

Action item:

  • A verbatim capture of flip charts to be distributed to members for their consideration and information with the draft minutes

Discussion of future agenda items

Government officials indicated that considerations for future agenda topics may include aligning similar topics with the Science Committee. This would allow government officials to receive input from SAC members on broader program or policy implementation, which could be complemented by technical considerations from the Science Committee. This could allow for more comprehensive understanding of some topics.

Co-chairs noted that they had received a proposal from some members, led by Anne Rochon Ford, to have a panel discussion at a future SAC meeting (potentially May 2018) related to vulnerable populations and the potential impact of chemicals on these populations. Co-chairs invited Anne to introduce the topic to fellow members.

Anne introduced the topic, noting that the intent of such a panel is to provide clarity and insight into the impact of chemicals on vulnerable communities, and to inform the narrative going forward, including for post-2020 chemicals management. Recommendations following the panel may include:

  • the need to identify and improve research (for example, biomonitoring) in key populations
  • enhancement of communications strategies with select communities to inform the Government's planning for post-2020 chemicals management work and the Canadian Environmental Protection Act, 1999 (CEPA 1999) review, in June 2018

Comments and discussion on this proposal included:

  • members noted the need to clearly identify the purpose and intention of the panel discussion in order to manage expectations of both participants and communities
  • other SAC members volunteered to help contribute to the subject

Action item:

  • Anne Rochon Ford, with input from the group will provide further clarification and identify any potential resource requirements to Co-chairs following the SAC meeting

A future discussion would be required to address several other topics previously identified on the forward agenda and to potentially prioritize them given the new format and processes of SAC meetings.

Action Item:

  • To be brought forward for a future discussion

Closing remarks

The Co-chairs thanked members for their valuable contributions towards the topics presented during the meeting. Members provided positive feedback with regards to the new format and processes.  Co-chairs indicated that an intersessional teleconference would be planned in 2018 to finalize the informed substitution discussion. The next face-to-face meetings were planned for May and November 2018, with information webinars 4 to 6 weeks in advance of the meetings, as needed.

Action item:

  • members to send SAC secretariat any dates that are potential conflicts in order to establish and share meeting dates as early as possible

Participants at the November 14-15, 2017 SAC meeting

Visit the Stakeholder Advisory Council Members' web page for biographical information.

  • Co-chairs:
    • Jacqueline Gonçalves, Director General
      Science and Risk Assessment Directorate, Environment and Climate Change Canada
    • David Morin, Director General
      Safe Environments Directorate, Health Canada
    • Gwen Goodier, Executive Director, Chemicals, Environment and Climate Change Canada, on behalf of Marc D'Iorio, Director General,
      Industrial Sectors, Chemicals and Waste Directorate, Environment and Climate Change Canada
  • Council members present:
    • Aleksandra Pogoda, Director, Environment, Canadian Steel Producers Association
    • Amardeep Khosla, Executive Director, CEPA Industry Coordinating Group
    • Angie Clark, Regional Director, Responsible Distribution Canada
    • Anne Rochon Ford, Co-Director, National Network on Environments and Women's Health
    • Barb MacKinnon, President and Chief Executive Officer, New Brunswick Lung Association
    • Beta Montemayor, Environmental Science and Regulation, Canadian Cosmetic Toiletry and Fragrance Association
    • Curtis Scurr, Policy Analyst, Assembly of First Nations
    • Dr. Donald Spady, Canadian Paediatric Society
    • Dr. Elaine MacDonald, Senior Scientist, Ecojustice
    • Dr. Elizabeth Nielsen, Consumers Council of Canada
    • Eric Loring, Senior Researcher, Environment and Health, Inuit Tapiriit Kanatami
    • Fe de Leon, Researcher, Canadian Environmental Law Association
    • Joshua McNeely, IKANAWTIKET Executive Director, Maritime Aboriginal Peoples Council
    • Justyna Laurie-Lean, President, Environment and Regulatory Affairs, Mining Association of Canada
    • Muhannad Malas, Toxic Program Manager, Environmental Defence
    • Philippe Cantin, Manager, Environment, Retail Council of Canada
    • Sandra Madray, Research and Education, Chemical Sensitivities Manitoba
    • Scott Thurlow, Legal Counsel and Director, Environment and Health Policy, Chemistry Industry Association of Canada
    • Shannon Coombs, President, Canadian Consumer Specialty Products Association
    • Shelagh Kerr, President and Chief Executive Officer, Electronics Product Stewardship Canada
    • Yasmin Tarmohamed, Vice President, Environment, Health and Safety, Canadian Vehicle Manufacturers' Association
  • Council members absent:
    • Andy Dabydeen, Manager, Product Stewardship Strategy and Governance, Canadian Tire Corporation
    • Gary LeRoux, President and Chief Executive Officer, Canadian Paint and Coatings Association
  • Observers:
    • Aiñe Curran, President, Vinyl Institute of Canada and Chair of the Global Vinyl Council (day 2 only)
    • Anne McConnell, Member of the Canadian Consumer Specialty Products Association
    • Jennifer Beeman, Executive Director, Breast Cancer Action Quebec (day 2 only)
    • Liz Smith, Project Manager, New Brunswick Lung Association and Canadian Network for Human Health and the Environment (CNHHE)
    • Dr. Olga Speranskaya, Co-chair, International Political Economy Network (IPEN) and Director, Eco-Accord Program on Chemical Safety, Russia (day 2 only)
  • Informed substitution experts and guest presenters:
    • David Shortt, Employee, Dow Building and Construction, Dow Chemical Company
    • Dr. Christine Lukas, Product Stewardship & Fire Safety Manager, Dow Building Solutions (DBS), part of Dow Building and Construction, Dow Chemical Company based in Europe
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