LETTER TO MINISTERS: Re: Amending the Canadian Environmental Protection Act, 1999October 15, 2018
The Hon. Catherine McKenna The Hon. Ginette C. Petitpas Taylor
Minister Minister
Environment and Climate Change Canada Health Canada
200 Sacre-Coeur Boulevard House of Commons
Gatineau, Quebec Ottawa, Ontario
K1A OH3 K1A OA6
Transmission:
ec.ministre-minister.ec@canada.ca hcminister.ministresc@canada.caDear Ministers McKenna and Petitpas Taylor:
Re: Amending the Canadian Environmental Protection Act, 1999
The undersigned organizations attach to this letter selected amendments to the Canadian Environmental Protection Act, 1999 (CEPA). We have undertaken this work because of the need for sound federal environmental law reform that addresses control of toxic substances, including carcinogens and endocrine disrupting substances, which pose serious risks to the health and well-being of present and future generations of Canadians and the natural world. We also have undertaken this work for the following additional reasons:
1. CEPA is long overdue for reform and further delay that could last years before a Bill is introduced is not in the public interest;
2. The proposed amendments focus on several key areas in major need of reform that were identified by the Standing Committee on Environment and Sustainable Development, including areas the Government appears to have rejected, or remains uncertain about;
3. The proposed amendments can be of assistance in the Government’s on-going work in addressing matters such as the future structure of the Chemicals Management Plan (CMP) and protecting vulnerable populations; and
4. The proposed reforms are supported by diverse groups across the country.
Many of the undersigned organizations participated in the hearings on review of CEPA that took place throughout 2016 before the Standing Committee. We hoped for timely adoption by the Government of the 2017 recommendations made by the Standing Committee for reforming CEPA that resulted from that process.
Unfortunately, while the Government’s June 2018 response to the Standing Committee made some positive statements about future reform of the law in certain areas, it rejected other key reform proposals. Furthermore, the timeline for bringing amendments forward
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as expressed in the Government response appeared very uncertain due to statements contained in the response which suggested: (1) “the Government will work towards legislative amendments as soon as possible in future Parliamentary sessions”; (2) that reforms to the Act on toxic substances, if needed, will be shaped by the outcome of the CMP post 2020 review process, which will continue into at least 2019; and (3) reform proposals may be preceded by a further multi-stakeholder consultation process.
While we strongly support maximizing consultation opportunities, we also support timely action to address long understood but neglected problems with CEPA, a law that has not been significantly amended in two decades.
In this spirit, the undersigned are attaching proposed amendments to CEPA that we trust will expedite getting a robust Government Bill before Parliament much sooner than might otherwise have been the case on issues such as: (1) control over endocrine disrupting substances; (2) protection of vulnerable populations from toxic substances; (3) substitution of safer alternatives for toxic substances; (4) establishment of enforceable national ambient air quality standards; and (5) civil enforcement of CEPA by the public. Each issue noted above was raised by various witnesses appearing before the Standing Committee and supported in the Committee’s 2017 report. The attached amendments simply put into statutory language principles supported by the Committee.
We trust the attached will be of assistance to the Government in moving rapidly to introduce in this session of Parliament a reformed CEPA meeting the environmental health needs of all Canadians.
We would be pleased to meet with you to discuss the proposed amendments if that would also be of assistance.
Yours truly,
CANADIAN ENVIRONMENTAL LAW ASSOCIATION
Theresa McClenaghan, Executive Director and Counsel
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Supporting Organizations
Canadian Environmental Law Association
[Ontario]
Theresa McClenaghan, Executive Director and Counsel
Email:
Theresa@cela.caPrevent Cancer Now
[Ontario]
Meg Sears, PhD, Chair
Email:
Meg@PreventCancerNow.caCitizens' Network on Waste Management
[Ontario]
John Jackson
Email:
jjackson@web.caAction cancer du sein du Québec [Québec] Jennifer Beeman, Executive Director Email:
Jennifer.beeman@acsqc.caAssociation pour la santé environnementale du Québec – Environmental Health Association of Quebec (ASEQ-EHAQ)
[Québec]
Rohini Peris, President
Email:
office@aseq-ehaq.caWest Coast Environmental Law
[British Columbia]
Jessica Clogg, Executive Director and Senior Counsel
Email:
Jessica_Clogg@wcel.orgWatershed Sentinel Education Society
Anna Tilman
Email:
annatilman@sympatico.caHealth and Environmental Justice Support International (HEJSupport International)
Dr. Olga Speranskaya, Co-Director
Email:
olga.speranskaya@hej-support.org4
Nova Scotia Environmental Network
[Nova Scotia]
Sheila Cole Advisor
Email:
sheilacole108@yahoo.caEnvironmental and Occupational Work Group,
Toronto Cancer Prevention Coalition
[Ontario]
Sarah Miller, Co-chair
Email:
reachsandbarsarah@gmail.comCanadian Association of University Teachers /
Association canadienne des professeures et
professeurs d'université
Laura Lozanski, Occupational Health & Safety Officer
Email:
lozanski@caut.caCitizens Environment Alliance of Southwestern
Ontario
[Ontario]
Derek Coronado, Coordinator
Email:
dcoronado@cogeco.netBreast Cancer Action Manitoba
[Manitoba]
Louise Schoenherr, President
Email :
kschoenh@mymts.netQuill Plains (Wynyard) Chapter, Council of
Canadians
[Saskatchewan]
Elaine Hughes, Chair
Email:
tybach.1933@sasktel.netFriends of the Earth
[National]
Beatrice Olivastri, CEO
Email:
BEATRICE@FOECANADA.ORGGeorgia Strait Alliance
[British Columbia]
Christianne Wilhelmson, Executive Director
Email:
christianne@georgiastrait.org5
Healthy Nail Salon Network
[Ontario]
Anne Rochon Ford, Co-Lead
Email:
annerf@sympatico.caSaint John Citizens Coalition for Clean Air
[New Brunswick]
Gordon W Dalzell, Chairperson
Email:
dalmar@nbnet.nb.caEnvironmental Law Centre
[Alberta]
Jason Unger, Executive Director
Email:
Junger@elc.ab.caIngersoll District Nature Club
[Ontario]
Sheila Fleming, President
Email:
Sheila.fleming@lawsonresearch.comMiningWatch Canada
[Ontario]
Jamie Kneen, Communications and Outreach
Coordinator
Email:
jamie@miningwatch.caOntario Rivers Alliance
[Ontario]
Linda Heron, Chair
Email:
lindah@ontarioriversalliance.caWallaceburg Advisory Team for a Cleaner Habitat
(WATCH)
[Ontario]
Kris Lee, Chair
Email: ecowrappin(at)hotmail.com
Windsor on Watch (WOW)
[Ontario]
Randy Emerson
Email:
remerson3860@gmail.com6
Montreal chapter, Council of Canadians
[Quebec]
Abdul Pirani, chair
Email:
apirani.coc.montreal@gmail.comGeorgian Bay Association
[Ontario]
Rupert Kindersley, Executive Director
Email:
rkindersley@georgianbay.caOntario Headwaters Institute
[Ontario]
Andrew McCammon, Executive Director
Email:
andrew@ontarioheadwaters.caProvincial Council of Women of Ontario
[Ontario]
Edeltraud Neal, President
Email:
edeltraud.neal@rogers.comThe Oxford Coalition for Social Justice
[Ontario]
Bryan J. Smith, Chair
Email:
bryasmit@oxford.netUFCW 1518
[British Columbia]
Larry Stoffman, Occupational Health and Safety
Email:
larrystoffman@gmail.comWHEN - Women's Healthy Environments Network
[Ontario]
Cassie Barker, Executive Director
Email:
cassie@womenshealthyenvironments.caWorkers United Canada Council
Ryan Hayes, Communications and Research
Email:
rhayes@workersunitedunion.ca7
Canadian Association of Physicians for the Environment (CAPE)
[Ontario]
Kim Perrotta MHSc, Executive Director
Email:
kim@cape.caOccupational Health Clinics for Ontario Workers (OHCOW)
[Ontario]
Michael Roche, Chief Executive Officer
Email:
mroche@ohcow.on.caExperts
James Brophy, PhD
[Ontario]
University of Windsor, Sociology Department
Email:
jimbrophy@yahoo.comMargaret Keith, PhD
[Ontario]
University of Windsor, Sociology Department
Email:
margkeith@yahoo.comDr. Gail Krantzberg
Professor
Engineering and Public Policy Program
McMaster University
Email:
Krantz@mcmaster.ca