Submission on Bill S-5, Strengthening Environmental Protection for a Healthier Canada Act

A joint submission by five environmental and health organizations, including the Canadian Association of Physicians for the Environment and Ecojustice, providing recommendations to strengthen Bill S-5, the Strengthening Environmental Protection for a Healthier Canada Act. The brief focuses on the recognition of the right to a healthy environment and the modernization of the Canadian Environmental Protection Act (CEPA) regarding the management of toxic substances.

• The submission supports Bill S-5's recognition of the human right to a healthy environment in Canadian federal law, aligning with a 2022 UN General Assembly vote. The authors recommend that the principles of environmental justice, non-regression, and intergenerational equity be incorporated into Section 2 of the Act as administrative duties to give them "greater force and create consistency and continuity of purpose throughout the Act."
• The authors argue that the implementation framework for the right to a healthy environment must include specific actions for when Canadian Ambient Air Quality Standards (CAAQS) are exceeded in a geographic area, noting that air pollution risks are "disproportionately experienced in communities with higher levels of air pollution, often where racialized, Indigenous, and poor people live."
• The brief recommends strengthening CEPA's priority planning by requiring the plan to include specific timelines for assessments and control measures, and mandating that the plan be updated at least every five years to "improve accountability, and help prevent lengthy delays."
• The submission calls for mandatory labelling of hazardous substances in consumer products to uphold the "consumers' right to know," arguing that current limited access to chemical information is an "environmental justice issue" that particularly burdens women.
• The authors identify failures in the public request for assessment mechanism, stating that current vague language allows for "non-committal responses" and that the Minister has previously missed deadlines to respond. They propose that granted requests be added to the priority plan and completed within a two-year limit.
• To prevent "multi-year delays" in substance assessments, the submission recommends a one-year time limit to finalize an assessment after a proposed assessment is published, with extensions allowed only for additional data collection or studies.
• The brief proposes a more rigorous accountability framework for toxic substance risk management plans, suggesting that timelines for all planned actions should not exceed two years to avoid "years of unnecessary risk to human health and the environment."
• The submission advocates for a "presumption of non-confidentiality" regarding information on health or environmental risks, arguing that the onus should be on the party requesting confidentiality to demonstrate its necessity, similar to practices in the European Union and the U.S.

APA

Canadian Association of Physicians for the Environment (2022). Submission on Bill S-5, Strengthening Environmental Protection for a Healthier Canada Act. https://cape.ca/wp-content/uploads/2021/08/Bill-S5-Brief-to-ENVI-English.pdf

Chicago

Canadian Association of Physicians for the Environment. Submission on Bill S-5, Strengthening Environmental Protection for a Healthier Canada Act. 2022. https://cape.ca/wp-content/uploads/2021/08/Bill-S5-Brief-to-ENVI-English.pdf.

Wikipedia

{{cite report |author=Canadian Association of Physicians for the Environment |title=Submission on Bill S-5, Strengthening Environmental Protection for a Healthier Canada Act |date=14 November 2022 |url=https://cape.ca/wp-content/uploads/2021/08/Bill-S5-Brief-to-ENVI-English.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{canadianassociationofphysiciansfortheenvironment2022submission, author = {{Canadian Association of Physicians for the Environment}}, title = {{Submission on Bill S-5, Strengthening Environmental Protection for a Healthier Canada Act}}, institution = {Canadian Association of Physicians for the Environment}, year = {2022}, month = nov, url = {https://cape.ca/wp-content/uploads/2021/08/Bill-S5-Brief-to-ENVI-English.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }