Comments on the Proposed Watch List Approach

A joint statement by Ecojustice, the David Suzuki Foundation, the Canadian Association of Physicians for the Environment, Breast Cancer Action Quebec, and Environmental Defence criticizing the proposed Watch List approach under CEPA for being overly complex. The organizations advocate for a hazard-based listing process that bypasses risk assessments and public consultations to avoid industry lobbying and delays, urging publication by Spring 2025.

• The authors argue that the Watch List should be primarily hazard-based, focusing on inherent dangers of substances regardless of current exposure levels, and should not be limited to risk-based assessments.
• The organizations contend that requiring public consultations and formal assessments for adding substances to the Watch List is unnecessary under CEPA and would create inefficiencies and opportunities for industry lobbying.
• The document recommends that the Watch List be clearly distinguished from Significant New Activity (SNAc) provisions, noting that the Watch List is a non-regulatory early warning tool while SNAcs are regulatory prohibitions on new uses.
• The authors urge the Minister to publish the Watch List by Spring 2025, noting that over 1.5 years have passed since the CEPA amendment mandating its creation in June 2023.

APA

Canadian Association of Physicians for the Environment (2024). Comments on the Proposed Watch List Approach. https://cape.ca/wp-content/uploads/2024/12/Comments-on-the-Proposed-Watch-List-Approach-EJ-ED-DSF-CAPE-and-BCAQ-Dec-4-2024.pdf

Chicago

Canadian Association of Physicians for the Environment. Comments on the Proposed Watch List Approach. 2024. https://cape.ca/wp-content/uploads/2024/12/Comments-on-the-Proposed-Watch-List-Approach-EJ-ED-DSF-CAPE-and-BCAQ-Dec-4-2024.pdf.

Wikipedia

{{cite press release |author=Canadian Association of Physicians for the Environment |title=Comments on the Proposed Watch List Approach |date=4 December 2024 |url=https://cape.ca/wp-content/uploads/2024/12/Comments-on-the-Proposed-Watch-List-Approach-EJ-ED-DSF-CAPE-and-BCAQ-Dec-4-2024.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{canadianassociationofphysiciansfortheenvironment2024comments, author = {{Canadian Association of Physicians for the Environment}}, title = {{Comments on the Proposed Watch List Approach}}, publisher = {Canadian Association of Physicians for the Environment}, year = {2024}, month = dec, url = {https://cape.ca/wp-content/uploads/2024/12/Comments-on-the-Proposed-Watch-List-Approach-EJ-ED-DSF-CAPE-and-BCAQ-Dec-4-2024.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }