Archived [2022-03-21] Summary report November 25, 2015 - Chemicals Management Plan Stakeholder Advisory Council
Chemicals Management Plan Stakeholder Advisory Council Meeting
- David Morin (Director General, Science and Risk Assessment, Environment and Climate Change Canada [ECCC])
- Amanda Jane (AJ) Preece (Director General, Safe Environments Directorate, Health Canada [HC])
- Council members present:
- Susan Abel
- Philippe Cantin
- Shannon Coombs
- Shelagh Kerr
- Fe de Leon
- Rob Hoffman
- Amardeep Khosla
- Gary Leroux
- Gordon Lloyd
- Maggie MacDonald
- Sandra Madray
- Mary Richardson
- Dr. Donald Spady
- Delegated representatives:
- Greg Basham for Bruce Cran
- William David for Curtis Scurr
- Government officials present:
- Andrew Beck (Acting Director, Risk Management Bureau, HC)
- Greg Carreau (Executive Director, Program Development and Engagement Division, ECCC)
- Robert Chénier (Director, Ecological Assessment Division, ECCC)
- Vincenza Galatone (Executive Director, Chemicals Management Division, ECCC)
- Sonia Johnson (Manager, Environmental Health Science and Research Bureau, HC)
- Nav Khera (Manager, Emerging Priorities Division, ECCC)
- Suzanne Leppinen (Director, Chemicals Policy Bureau, HC)
- Jake Sanderson (Manager, Horizontal Policy and Planning, ECCC)
- Angelika Zidek (Acting Director, Existing Substances Risk Assessment Bureau, HC)
- Dr. Joseph Byers
- Eric Loring
- Keith Mussar
- Lee Wilson
- Sheila Cole (Nova Scotia Environmental Network)
- Meg Sears (Children's Hospital of Eastern Ontario)
- Liz Smith (New Brunswick Lung Association)
Participants were welcomed and observers and delegated representatives were introduced. The chairs started off by acknowledging this meeting as being the last Stakeholder Advisory Council (SAC) meeting under the second phase of the Chemicals Management Plan (CMP). Recognition of the members' engagement throughout the second phase of the CMP (CMP2) was underlined during a brief ceremony at lunch.
Recap of the November 24, 2015, multi-stakeholder workshop on the CMP moving forward
Government officials and SAC members provided their reflections on the November 24 workshop on the CMP moving forward. The workshop was well received by SAC members as it provided a more detailed picture of what lies ahead under the third phase of the CMP (CMP3). Workshop presentations included a review of CMP Phase III priorities, information gathering priorities, the Domestic Substances List Inventory Update, risk management in the CMP, and nanomaterials. SAC members acknowledged the important effort that went into the organization of the workshop and appreciated the level of detail that was provided in the presentations. Some members requested a more in-depth session on risk management, including timing considerations and how vulnerable populations are taken into account. Other members mentioned that public engagement should be more prominent and that the government should strive for even more balanced representation from non-governmental organizations and civil society at these types of workshops. Occupational health was also raised as an area that requires further discussion as we move forward with the CMP.
Based on the feedback received at the workshop, there is a need to clearly communicate timelines for the third phase of the CMP via regular updates and highlighting where modifications have been made to the initial plan as the work progresses. There is also a need to rethink early stakeholder engagement with respect to specific data needs for assessments. Feedback on the initial proposal to have one overarching Notice of intent published with the general type of information the government is seeking indicated that more specific information on a more regular basis would be preferable.
- ECCC and HC to provide November 24 multi-stakeholder workshop meeting notes to SAC members.
Agenda item 1 - Program updates
Government officials gave a quick overview of recent publications and of the upcoming CMP Progress Report. Participants were advised of the planned publication of the fifth issue of the CMP Progress Report, scheduled for December 2015.
A brief summary of recent activities under the Regulatory Cooperation Council was provided. Specifically, two Multi-stakeholder Technical Working Groups have been formed to assist in developing and implementing the Chemicals Management work plans – one to support the Risk Assessment initiative and one for the Significant New Activity/Significant New Use Rule initiative. For both initiatives, the work plan has progressed through the background information gathering stage and is currently focused on identifying more specific areas of focus and discussions on possible work plan outcomes. Both Technical Working Groups met face-to-face in Washington at the end of October for full day meetings to further discuss and identify work in specific areas.
A brief update on the CMP Science Committee activities was provided. Science Committee meetings were held on June 2-3 and November 18-19, 2015. Topics discussed included the proposed level of complexity-based assessment framework for efficiently addressing the remaining priorities under the planned next phase of the CMP and proposed approaches for how combined exposure to multiple chemicals is being considered in risk assessment respectively. SAC members indicated that it should be standard practice for the SAC secretariat to share with SAC members the CMP Science Committee Meeting Record and Committee Report as soon as these are made available.
Government officials provided an update on the CMP2 evaluation. The final Report indicates that there is a demonstrated ongoing need for the CMP to manage risks to human health and the environment associated with some chemicals. It demonstrates that the CMP is well-managed and aligned with the priorities of the Government of Canada. It also confirms that the program was able to advance the implementation of planned activities for all six CMP functional activity areas: risk assessment, risk management, compliance and enforcement, research, monitoring and surveillance, and stakeholder engagement and public outreach. The CMP2 Evaluation Report includes five recommendations concerning:
- reviewing the governance framework to clarify roles and responsibilities,
- taking steps to address CMP commitments for the petroleum sector stream approach,
- communicating the effectiveness of non-regulatory measures,
- strengthening performance measurement and reporting, and
- improving understanding of information needs of Canadians to support risk communications.
Finally, government officials reported back to SAC members on action items that were identified at the May 7, 2015, SAC meeting and how input provided at that meeting had been considered. Specifically:
- Chemicals Awareness Learning Modules (CALM) were to be shared with SAC members. Unfortunately, a generic example of these modules was not available prior to the November 25 meeting.
- Government and SAC members were to explore ways of enhancing public outreach. Item 5 of the current meeting agenda provides SAC members with a first glance at the proposed CMP Public Outreach Strategy.
- Input provided by SAC members was included in the procedures document for the implementation of section 75 of the Canadian Environmental Protection Act, 1999 (CEPA 1999). Notably, criteria for a review to be considered under section 75 have been clarified. The proposed procedures document will be published for a 60-day public comment in winter 2016.
- The final SAC Evaluation Report was to be shared with SAC members, which was done on October 14, 2015. Item 4 of the current meeting agenda will address how the government intends to implement some of the recommendations.
- SAC secretariat to proactively share CMP Science Committee reports and meeting minutes with SAC members when these become available after each meeting.
- SAC secretariat to inform SAC members when the CMP2 Evaluation Report is published in December 2015.
- HC to share a generic CALM module with SAC members.
Agenda item 2 - CMP research and monitoring program
Government officials presented how CMP research and monitoring results are communicated and sought input on how to increase awareness of these results. Research, monitoring and surveillance activities support the development of sound and effective policies and support risk assessment and risk management activities under the CMP. Research and monitoring results are communicated in risk assessment or State of the Science Reports, in indicator and departmental reporting, in monitoring and surveillance data reports, in publications and proceedings and/or as open data available to the public.
SAC members were very much interested in getting to know more about the open data initiative. Specifically, compatibility of data and linkage to geospatial information were highlighted as important factors to help make the information more accessible and usable. SAC members also inquired about source attribution and government officials indicated that data gathered was meant to inform potential exposures across large cohorts. This information is then used in risk assessments where the source of exposure is looked into more closely to help characterize the risk. SAC members were also interested in knowing how substances were identified as candidates for research or monitoring. Government officials provided additional input on how substances are triaged based on the information available, their hazard and exposure profiles, the applicability for modelling and the resources available, recognizing that not all substances can be included in research and monitoring programs.
Agenda item 3 - Risk management - Substance-Based Risk Management Performance Measurement - Update on progress and case study
The concept of Substance-Based Performance Measurement (SBPM) was presented as well as an update on activities to date. The prioritization process for the selection of substances for performance measurement was discussed. An example of the results was provided using bisphenol A as a case study. Feedback and input was sought from members regarding the prioritization criteria and the communication of the SBPM project results.
SAC members raised questions about some of the indicators being used to inform performance measurement. Specifically, some SAC members questioned whether law compliance was a true indicator of performance if the ultimate objective is reducing levels of a particular substance in the environment. Other SAC members indicated that law compliance is a pre-requisite to measure efficacy of the risk management tool towards the ultimate environmental or human health objective. Some SAC members also had specific questions with regard to the case study. Analysis of potential substitutes for substances being managed (in this case bisphenol A) was raised as an area that required further discussion. Government officials indicated that any new substance not already in the Canadian market is subject to a pre-market notification which allows government officials to review information and make decisions on risk. Furthermore, the Identification of chemicals and polymers as risk assessment priorities under the Canadian Environmental Protection Act, 1999 (CEPA 1999) is the approach that the government uses to review a wide range of information sources on a regular basis to identify potential new candidates for assessment or re-assessment. Any new data available on substitutes, for example, would be captured in that approach.
Agenda item 4 - Discussion on SAC operations
In response to the final SAC Evaluation Report government officials provided members with a summary of the actions proposed to implement the recommendations included in the Report including:
- maintaining the diversity of SAC members and balancing the need for continuity versus the need for renewal of members as we move forward with CMP3,
- communicating more clearly the different roles of meeting participants (for example, observers),
- considering extending SAC meetings to 1.5 days, or setting up sub-committees on specific issues, to permit more time for discussions, and
- developing methods to track and communicate how members' input has been taken into account or influenced decisions.
SAC members indicated that the renewal process for establishing the SAC CMP3 should be as simple as possible. Furthermore, members expressed the importance of the current members' broad knowledge base of the program and the balance between industry, non-governmental organizations and National Aboriginal organizations on the council as the SAC is renewed. On the topic of clarifying the roles of meeting participants, the role of observers was highlighted as one that should be revisited to allow observers to have a more active role at SAC meetings, by perhaps providing them an opportunity to speak at a certain point during SAC meetings. The possibility to have ad hoc members or presenters for specific topics was also raised as an item that deserves further consideration. SAC members indicated that the current format of adjoining SAC meetings to a previous day workshop is a good format which allows members to distill information and discussions held the previous day and put these into perspectives for the SAC meeting. Some members indicated that there would be value in having separate fora to discuss issues that may be of interest to a subset of members by setting subcommittees, teleconferences, webinars, etc., in between bi-annual SAC meetings. Finally, SAC members also acknowledged the government's efforts to now include updates on how members' input has been taken into account in the "Program Updates" standing item of SAC meeting agendas.
Agenda item 5 - Public outreach strategy for CMP3
Government officials summarized the drivers to improve public outreach and outlined a new draft five-year strategy to guide CMP work going forward. The strategy is based on research and calls for increased partnerships and collaboration in order to raise awareness of the potential risks and safe use of chemicals and maximize reach of the program's messaging. Government officials also elaborated on how explaining the Government of Canada's role in chemicals management will enhance public confidence in the CMP as a regulatory program. Feedback from SAC members was sought on the draft strategy and how members could contribute to implementation.
SAC members requested clarifications on the concept of "environmental health" being conveyed in the strategy. Government officials indicated that the strategy is meant to be broader than just the CMP to include topics that are all related from a general public health perspective, such as air, water, contaminated sites, etc. SAC members noted that government communications have not always hit the mark and they are interested in knowing if an analysis of communications products is being conducted to inform best practices. Government officials indicated that conducting research is the first pillar included in this strategy to understand the information needs of Canadians and identify best practices to inform the strategy and development of key messages, information products, and tools. SAC members indicated that having appropriate communication pieces (brief summaries or factsheets aimed at the general population) would facilitate their engagement with their constituents. Overall, members were supportive and engaged on the topic of public outreach, acknowledging the importance of effective communications to Canadians in the area of environmental health.
Agenda item 6 - Re-cap and debrief from International Conference on Chemicals Management (ICCM4) and SAC discussion on chemicals management post-2020
A summary of outcomes of the International Conference on Chemicals Management (ICCM4), held September 27 to October 2, 2015, provided some international context for a discussion with SAC members on chemicals management post-2020. With five years remaining to the 2020 goal of the Sound Management of Chemicals (SMOC), the main objective of participants at ICCM4 was to set the direction for the Strategic Approach for International Chemicals Management (SAICM) for the next five years and to set in motion a process to prepare for discussions regarding next steps beyond 2020.
Climate change was raised by SAC members as an area that requires further attention as it relates to chemicals management post-2020. Government officials indicated that climate change was not specifically raised during these international discussions on chemicals management; however, this input was noted for further considerations. Some SAC members raised the issue of accessibility to these international discussions. Non-governmental organizations have typically participated in such fora but limited resources have prevented meaningful participation lately. SAC members suggested consideration for capacity-building should be included in discussions as we move forward. Finally, a SAC member inquired about whether human rights were discussed at ICCM4. Government officials indicated that there was a statement made by the United Nations Special Rapporteur on human rights and chemicals although it was not discussed at any length at ICCM4. SAC members also discussed their desire to be more engaged in international discussions, recognizing the challenge of the volume of documents which typically arrive only days before international meetings. Government officials agreed to examine options for more engagement on international issues. This could be done, for example, through ongoing CMP webinars and an international page on the Chemicals Substances Web site (if possible with canada.ca web transformation) to raise the level of understanding of issues and considerations for the development of Canada's positions at future international meetings.
The co-chairs thanked SAC members for the valuable discussions and for their active participation throughout CMP2. SAC members were asked to bring forth any topic they would like to see discussed as the SAC is renewed for CMP3.
The inaugural meeting of the renewed SAC for CMP3 is planned to be held in fall 2016.
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