Response to the Proposed Prohibition of Asbestos and Asbestos Products Regulations and Proposed Amendment to the Export of Substances on the Export Control List Regulations under CEPA, 1999

The Canadian Association of Physicians for the Environment and supporting organizations argue that the proposed asbestos regulations contain critical gaps, specifically regarding legacy asbestos, mining residues, and industry exclusions. They recommend a comprehensive National Asbestos Strategy that includes a total ban on exports, the elimination of a 7-year exclusion for the chlor-alkali industry, and harmonized federal-provincial-territorial standards for end-of-life asbestos management.

• The proposed regulations are criticized for failing to adopt a life cycle management approach, as they do not establish a regulatory regime for managing asbestos stockpiles or the end-of-life disposal phase, which could lead to inconsistent outcomes across provinces and territories.
• The authors oppose the exclusion of asbestos mining residues from the regulations and specifically reject the provision allowing provinces to authorize the use of these residues in construction or landscaping, arguing it creates public and occupational risks.
• The document strongly opposes a proposed 7-year exclusion for the chlor-alkali industry, arguing that non-asbestos technology is achievable within 4 years and would result in annual energy savings of $29 million.
• The coalition argues that Canada should ban all exports of asbestos-containing materials to prevent the transfer of liability to countries with inadequate legislation to protect workers and the public.
• The authors identify a lack of clarity in the proposed regulations due to the absence of formal definitions for the terms "asbestos mining residues" and "incidentally present".

APA

Canadian Association of Physicians for the Environment (2018). Response to the Proposed Prohibition of Asbestos and Asbestos Products Regulations and Proposed Amendment to the Export of Substances on the Export Control List Regulations under CEPA, 1999. https://cape.ca/wp-content/uploads/2018/10/18-03-21Response-to-Proposed-Prohibition-on-Asbestos-and-ESECLR-submission-final.pdf

Chicago

Canadian Association of Physicians for the Environment. Response to the Proposed Prohibition of Asbestos and Asbestos Products Regulations and Proposed Amendment to the Export of Substances on the Export Control List Regulations under CEPA, 1999. 2018. https://cape.ca/wp-content/uploads/2018/10/18-03-21Response-to-Proposed-Prohibition-on-Asbestos-and-ESECLR-submission-final.pdf.

Wikipedia

{{cite report |author=Canadian Association of Physicians for the Environment |title=Response to the Proposed Prohibition of Asbestos and Asbestos Products Regulations and Proposed Amendment to the Export of Substances on the Export Control List Regulations under CEPA, 1999 |date=21 March 2018 |url=https://cape.ca/wp-content/uploads/2018/10/18-03-21Response-to-Proposed-Prohibition-on-Asbestos-and-ESECLR-submission-final.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{canadianassociationofphysiciansfortheenvironment2018response, author = {{Canadian Association of Physicians for the Environment}}, title = {{Response to the Proposed Prohibition of Asbestos and Asbestos Products Regulations and Proposed Amendment to the Export of Substances on the Export Control List Regulations under CEPA, 1999}}, institution = {Canadian Association of Physicians for the Environment}, year = {2018}, month = mar, url = {https://cape.ca/wp-content/uploads/2018/10/18-03-21Response-to-Proposed-Prohibition-on-Asbestos-and-ESECLR-submission-final.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }