Take Charge on Toxics supports the government’s initiative on toxic use reduction. However, in order for this legislation to effectively reduce toxic chemicals, adequately inform the public and ultimately protect public health, the campaign feels the proposed legislation should be enhanced by addressing the following.

1. Reduce the release of toxic chemicals in places where people live, work and play by 50 per cent within 5 years in Ontario to protect public health.
   
   
   • Targets need to be established
     It is important to set clear and ambitious goals for toxics use reduction in order to spur innovation as well as provide benchmarks to measure progress. The campaign recommends the Government of Ontario set targets for reduction on both the release and usage of priority chemicals with annual public reporting.
     
     
2. Reveal to all Ontarians the toxic chemicals in their workplaces, community and homes through an identifiable product label or symbol and access to a public database.
   
   
   • Community Right-to-Know
     The Take Charge on Toxics campaign supports the government’s commitment to inform the public about toxic chemicals in their environments. The campaign believes all Ontarians should be informed of exposure to cancer-causing substances at home, at work and in their environment.
     
     
   • Community Right-to-Know - Product Labelling
     The Government of Ontario has the opportunity to show leadership in Canada and follow other jurisdictions by implementing product labelling in Ontario. The Take Charge on Toxics campaign believes all ingredients in consumer products should be fully disclosed on product labels. In addition, if cancer-causing substances are present in products, they should be identified by a hazard symbol.
     
     
3. Replace toxic chemicals where a safer alternative exist.
   
   
   • Stronger focus on substitution
     The government should require Ontario companies to substitute and/or phase out all non-essential uses of toxic substances in order to accelerate elimination and to protect industry capacity in Ontario, with particular and urgent reference to the requirements of the European Union’s REACH program.
     
     
4. Restrict the use of toxic chemicals that are still in use through guidance from an Ontario Toxic Use Reduction Institute (OTURI).
   
   
   • Development of a Toxic Use Reduction Institute
     The Take Charge on Toxics campaign recommends the Government of Ontario establish an independent university-based research institute to advance the province’s capacity for toxic use reduction activities, safe substitution, green chemistry, education and information outreach and to provide training on toxics reduction planning.
     
     
5. Report annually on progress and monitor emissions, holding industry accountable to reduce their use of toxic chemicals through enforcement of regulations.
   
   
   • REACH (Registration, Evaluation, and Authorization of Chemicals)
     The campaign believes Ontario needs to design a system in order to fully account for the impact of off-shore toxic reduction control strategies. Ontario companies must meet REACH’s standards in order to remain competitive and export to the world’s largest market.
     
     
   • Too many schedules
     The campaign recommends consolidating all NPRI chemicals from Schedules 1 and 2 into a single schedule that becomes subject to all the requirements of the law by 2012. Also, the campaigns recommends consolidating all non-NPRI chemicals from Schedules 3 & 4 into a single schedule and impose reporting requirements on them upon implementation of the legislation, with materials accounting and toxics reduction planning requirement imposed on these substances within a reasonable time thereafter.
     
     
   • More substances need to be addressed
     The Take Charge on Toxics campaign believes there are too few substances designated for immediate action in phase one.
     
     
   • Thresholds are too high
     The campaign recommends adopting a much lower threshold (50 kilograms) for designated substances that are (1) carcinogenic or toxic to reproduction or that are (2) persistent, bioaccumaulative and toxic.
     
     
   • Funding
     The campaign recommends the establishment of a fund dedicated to financing the programs and institutions that will be needed to ensure proper implementation of the legislation.
     
     
   • Confidential Business Information
     Industry should be required to provide full justification and documentation in writing as to why certain information should be kept confidential. Health and safety information should not be eligible for confidential business information protection.
     
     
   • Guidelines are needed for enforcement
     The Government of Ontario needs to ensure companies are penalized if they do not submit a Toxic Reduction Plan. There is also no clear prohibition on withholding health and safety information.
     
     
   • Stronger purpose statement
     Ontario’s Toxic Use Reduction legislation purpose section should focus on Ontario families and workers who need strong Toxic Use Reduction legislation to reduce the health risks associated with exposure to toxic chemicals.
     
     

For more information about the Take Charge on Toxics recommendations read our Environment Bill of Right Registry submission.

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