NGO response to the Draft Science Assessment of Plastic PollutionChemicals in Products
HEJSupport, the Canadian Environmental Law Association (CELA), and the Citizens’ Network on Waste Management provided a response to the Draft Science Assessment of Plastic Pollution released for public comment on January 30, 2020.
The Draft Science Assessment of Plastic Pollution was published by Environment and Climate Change Canada and Health Canada. The Assessment confirms that larger plastic items like bags and straws can physically harm animals and negatively affect their habitat. Wildlife worldwide are injured or die when they mistake plastic for food or become entangled. The report also highlights microplastic pollution, noting evidence of negative effects on animals and the environment and uncertainties regarding the potential for effects on humans.
NGOs welcome the release of the Assessment as it will advance Canada’s efforts to address a growing global environmental crisis on plastics. The scope of the Draft Science Assessment provides a good overview of the science currently available outlining the extent of plastic pollution.
However, it has not been explicit as to the purpose and conclusion of the assessment. While the evidence presented in the Draft Science Assessment provides the necessary foundation to develop measures addressing plastic pollution, the format of the Science Assessment differs from recent assessments done under the Canadian Environmental Protection Act (CEPA) and the Canada’s Chemicals Management Plan.
NGOs further suggest that the Draft Science Assessment reconsider the scope of products that would be considered plastic waste, particularly with the focus on single use plastic products. Substantial gaps exists in this area.
The urgency in addressing plastic pollution includes a commitment to strengthening the life cycle approach. In this regard, the use of toxic substances in the manufacture of plastics and the consideration of the impacts of toxic substances, including those substances that are considered persistent organic pollutants or endocrine disrupting substances, throughout the life of the plastic items should be given substantial consideration in the Draft Science Assessment report.
Detailed comments and recommendations are presented in the attached paper.