The proposal suggests that…

The proposal suggests that the Ontario plan is not needed because there is a federal plan covering the same substances however I note that the federal plan was started in 2006, three years before the Ontario legislation. This suggests that the Ontario legislation provides elements not covered by the federal plan.

In particular the federal plan seems to focus on the development of studies and plans for risk management where substances used by industry are deemed to be toxic. The Ontario plan requires industry itself to continually monitor its use of these toxic chemicals and, where possible, reduce their use by developing better, less toxic processes.

Industry complains that this involves extra costs however it is desirable that the use of more toxic chemicals should incur extra costs to industry as a spur to research and development of less toxic processes just as we should be taxing the production of greenhouse gases to encourage the development of processes that reduce such production.