If I understand the purpose…

Numéro du REO

013-4234

Identifiant (ID) du commentaire

15420

Commentaire fait au nom

Individual

Statut du commentaire

Commentaire

If I understand the purpose of this repeal properly, it will reduce unnecessary duplication and the burden on industry to comply with provincial legislation. What ‘burden’ does it currently impose?

This act was supposed to prevent pollution and reduce the use and creation of toxic substances, while informing Ontarians about those substances. Industry was required to develop VOLUNTARY toxic reduction plans, and report publicly each year. Since plans were voluntary, it is no surprise the Toxic Reduction Program did not achieve meaningful reductions -- noted as one reason for its repeal. Voluntary participation should never be an option where regulation and oversight are required. It would be interesting to see how many people would file tax returns if that exercise ever became voluntary. As members of society (whether we are talking about individuals, companies, or the public service), there are obligations that bind us together as a society. One of those obligations must surely entail NOT releasing toxic substances that may result in costly (potentially long-term) damage and clean-ups, as well as increased medical costs for affected individuals. Those toxic substances must be understood, named, measured, monitored, and minimized through regulation.

It is puzzling that the government has decided to repeal the act, instead of making toxic reduction plans mandatory. The government states the provincial Toxic Reductions Act, 2009, will be replaced by the federal Chemicals Management Plan, but the federal plan does NOT exempt provincial participation.

Here’s what the federal plan states: “In Canada, every order of government plays a part in protecting against risks from chemical substances: municipalities, the PROVINCES and territories, and the federal government. The Government of Canada makes regulations and develops guidelines and objectives that apply across the whole country.” Then, the federal government expects lower tiers of government to follow and ENACT those guidelines, tailored to address specific industries within each province.

I ask the government to re-consider this appeal. I believe it would be preferable for the Toxic Reductions Act, 2009 to be re-written, so it becomes a provincial regulation. It is possible to protect health, AND create jobs while protecting the all-encompassing environment within which all human endeavours occur ... all at the same time. Often, regulatory discipline can help to improve an industry's performance. Sometimes, industry itself asks for regulatory measures so all participants will operate on a level 'playing field'. There are a number of responsible companies in Ontario. By repealing this act, the province may inadvertently be 'inviting' some irresponsible 'players' who could tarnish an entire industry's reputation over time. Let's not give the 'bad apples' a foothold in Ontario just because they think they have a free pass to pollute in the absence of such regulatory oversight.