The Toxics Reduction Act is…

ERO number

013-4234

Comment ID

14172

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

The Toxics Reduction Act is not a duplicate program of any environmental reporting program anywhere in Canada. It is unique by requiring industrial facilities to report their USE of toxic substances (as opposed to only RELEASES like the federal NPRI program), which provides us with knowledge on the volume of toxic chemicals being used in particular industries, by particular workers. As a scientist working in cancer prevention, I have used the data from the Toxics Reduction Act to study how many workers may be exposed to cancer-causing chemicals in their workplace, where these workplaces are located in the province and which chemicals may need to be prioritized for reduction in order to reduce the number of Ontario workers diagnosed with occupational cancers. I have published two studies in the scientific literature using data from the Toxics Reduction Act, highlighting the program's utility in shining a light on what kind of hazardous exposures may be taking place inside Ontario's industrial workplaces. It has also helped us to prioritize which sectors and which regions in Ontario may need to be targeted for future workplace health and safety measures based on patterns in their volumes of hazardous chemicals used. Not only was this program filling a huge data gap on potential harmful exposures in the workplace, it is a very valuable program that fills a big regulatory gap by encouraging businesses to find and plan innovative ways to increase the efficiency of their manufacturing processes and to reduce their use of toxic chemicals with less harmful substitutes. Ontario was a Canadian leader in this regard, following the example set by numerous states in the U.S. with their own toxics reduction programs, namely Massachusetts, New Jersey and Oregon. Axing the program in Ontario would be incredibly short-sighted and would convey a total disregard for workplace health and safety. Therefore, we would urge for the reporting of chemical use and plans to reduce toxics use be retained.