Comments on the Proposed Watch List Approach

A joint statement by five environmental and health organizations—Ecojustice, the David Suzuki Foundation, the Canadian Association of Physicians for the Environment, Breast Cancer Action Quebec, and Environmental Defence—providing recommendations on the Proposed Watch List Approach for implementing section 75.1 of the Canadian Environmental Protection Act (CEPA). The organizations argue for a streamlined, hazard-based process to prevent regrettable substitutions and avoid industry-driven delays.

• The organizations advocate for a hazard-based approach to the Watch List, emphasizing that substances should be listed based on inherent dangers regardless of current exposure levels. They argue that the process should not be limited to risk-based assessments, particularly for substances like endocrine disruptors that have no safe exposure level.
• The authors contend that the Proposed Approach introduces unnecessary steps, such as public consultations and formal assessments, which are not required under CEPA. They argue these steps will cause inefficiency and allow for industry lobbying to delay the listing of hazardous substances.
• The statement recommends that any substance on the Watch List requiring further assessment to determine toxicity must be added to the Priority Plan with clear, specific timelines to avoid delayed action.
• The document distinguishes the Watch List from Significant New Activity (SNAc) provisions, noting that the Watch List is a non-regulatory, preventative tool for early warning, whereas SNAcs are regulatory prohibitions on new uses and activities.
• The organizations urge the Minister to publish the Watch List no later than Spring 2025, noting that over 1.5 years have passed since the CEPA amendment mandating its creation in June 2023.
• The authors request that the Watch List include substances and groupings that impact vulnerable populations, intergenerational equity, and environmental injustices, and that it be informed by research on chemical mixtures.

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} }