Coherent Identifier About this item: 20.500.12592/32tgdq

Re: Bill S-5, An Act to Amend the Canadian Environmental Protection Act, 1999, etc. CANADIAN ENVIRONMENTAL LAW ASSOCIATION

10 May 2022


In materials we submitted to the Committee, the Canadian Environmental Law Association (CELA) has focused on the emission of cancer-causing agents to illustrate that Bill S-5 will not help solve the problem unless the Bill improves the approach of the Canadian Environmental Protection Act (CEPA) to pollution prevention. [...] The Problem Pollution Data Reveals CELA analyzed 13 years of national pollution data and found that while federal requirements are reducing on-site air emissions of some of the most harmful chemicals to human health and the environment, on-site disposal and land releases of the same chemicals have been dramatically increasing over the same period. [...] It is not a solution to the problem for the 150 chemicals the federal government has designated as “toxic” and placed in Schedule 1 of CEPA, let alone the forty-three cancer-causing agents in that Schedule. [...] Letter from CELA - 3 Why CEPA Contributes to the Problem and Bill S-5 Does Not Help There are three things wrong with the existing statute that Bill S-5 does not correct on the issue of pollution prevention: 1 - pollution prevention is discretionary not mandatory for toxic substances listed in Schedule 1 (this situation has resulted in only one-sixth of all substances in the Schedule in the last 2. [...] How Should Bill S-5 Amend CEPA? CELA proposals to amend the Act, as set out in our March 2022 document provided to the Committee, would: (1) make pollution prevention mandatory for all chemicals Canada has designated as toxic under the law; (2) enshrine analysis of safer alternatives to chemicals as a central pillar of CEPA; (3) impose mandatory chemical testing obligations on the private sector w.