Comments re: EBR Registry #…

Comments re: EBR Registry # 013-4235 (Planning and Reporting Changes Under the Toxics Reduction Program and Ontario Regulation 455/09)

Government and industry in this province must always act in a manner that takes into account health, environmental, and quality-of-life issues that affect our citizens. Thus, it does not make sense to lessen the planning and reporting requirements under the “Toxics Reduction Program” and Ontario Regulation 455/09.

This proposal will purportedly cut red tape and reduce the regulatory burden for businesses. Current planning and reporting requirements have been developed, however, to safeguard environmental quality and protect public health and safety. This cannot be guaranteed if these requirements are diminished or eliminated. In addition, when governments change, so, too, does legislation. If federal oversight of toxic substances were to be weakened in the future (which is a possibility), it is essential to have provincial legislation in place that would address the development and use of such contaminants.

Instead of trying to weaken legislation for the benefit of industry, the Government of Ontario should ensure that current regulations remain effective by:

* continuing to require facilities with existing toxics-reduction plans to review AND implement such plans;
* requiring mandatory planning and reporting in the future for ALL toxic substances (with NO exemptions for individual facilities or contaminants).

The sole purpose of this legislative change is to support industry initiatives – which may have deleterious impacts on communities and the environment. Thus, I urge you not to defer to pressure from industry lobbyists. It is essential to at least maintain (and, ideally, strengthen) the planning and reporting requirements under the Toxics Reduction Program and Ontario Regulation 455/09.