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Published bySamuel Hood Modified over 8 years ago
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1/29/2016 1 Geoff Granville n Background: Ü Confusion within industry (and the public) about the meaning of DSL, NSN, PSL, CSDSL, Schedule 1, etc Ü Issues range from high-level to very detailed < PSL2 for ammonia, road salt < Using a Schedule 1 listed substance, eg benzene < Presence in a product Risk Communication for Substances
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1/29/2016 2 Geoff Granville n Industry Recommendations: Ü More precision and context in all forms of communication, eg < surveys, assessments, (and esp) Schedule 1 Ü Minimize potential for the lay reader to misunderstand what is requested/what has been concluded Ü We appreciate this ties into recent proposals to delete use of “toxic” < Needs further analysis and discussion, but where and when? Risk Communication for Substances
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1/29/2016 3 Geoff Granville n Address likely impacts of CSDSL in timely manner Ü Assume hundreds or thousands of substances to become instant “concerns” < Supply chain, esp at retail end < Sharing of Lists by some groups Ü Anticipate the impacts, and prevent them by careful communication now and later < General awareness now, plus plan for specific communications over next 16 months < Lead-in for Shannon and de-selection… Risk Communication for Substances
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1/29/2016 5 Geoff Granville n Recent, additional, driver: Ü “Human Health” being seen as the critical outcome of most environmental concerns < Requires both depts to work even more closely together ã PBT aspects: “PB often not discriminating” < Cost-Benefit considerations when weighting “health” in socio-economic terms for substances undergoing SLRAs? ã How does one do this for a small-volume or a limited- use substance vs dispersive uses? Consistency issue? Need for really good working and mgmt relationships EC/HC Interface - 1
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1/29/2016 6 Geoff Granville n Recognizing visible outcomes associated with CEPA are likely to increase, it is imperative to recognize the 2 Depts are generally seen from the outside as being a single entity n Joint issues must be better co-managed Ü Previous difficulties for ICG to engage consistently across the depts must be avoided Ü Availability & timing of communications, assessments, dept processes/guidelines < Use of policies and approaches, eg PrecPrinc; uncertainty factors; int’l assessments… n Equally, the 2 depts must clearly communicate when their approaches/actions should not be consistent EC/HC Interface - 2
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1/29/2016 7 Geoff Granville n Very significant activity from numerous perspectives Ü Precedent-setting in coverage and timing Ü Prioritization component (vs “categorization”) Ü SLRA aspect Ü Impact of surveys on industry Ü Impact of conclusions on industry n May end up as a great success, or as a frustrating failure Ü Criteria: Manageability, Prioritization, RA (SLRA/PSL), RM, end user pressure, public reaction, etc. Ü Brief review of current issues… CSDSL - 1
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1/29/2016 8 Geoff Granville n Numbers of substances Ü We receive and make various estimates < Few hundreds to few thousands Ü Now understand how HC will work the issue Ü Still uncertain about EC’s ability to work it, given complexity of UVCBs and other considerations n Improving the database on which the depts depend and preliminary decisions/refinement processes n Prioritization of SLRAs Ü What approaches/tools will be used? n Coordination of surveys and assessments n Communication issues, previously itemized CSDSL - 2
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1/29/2016 9 Geoff Granville n Coordination: Ü Both depts MUST ensure good coordination at all times < Cost to industry (0.5 py for 10 Pilot surveys) < Canadian vs int’l components < Likelihood of HC having own process Ü Asking the right questions < Not a fishing expedition Survey Management - 1
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1/29/2016 10 Geoff Granville n Prior review: Ü ICG “Sect 71 s/c” provides good model Ü Some recent problems – HFCs Ü Given number of surveys possible required in the future, this mechanism might not be sufficient….future discussion point? Survey Management - 2
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1/29/2016 11 Geoff Granville n Level of drill-down and detail: Ü Levels in substances, mixtures, products Ü National vs int’l info < Ease of access < Other assessments / evaluations Ü Uses – “major” vs “all known” < Value chain issue Survey Management - 3
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