We once again encourage the MOL to expedite the development of a formal policy and procedure to address this issue and make the substitution of hazardous substances a priority initiative.  A priority initiative that should include a priority list of substances that the MOL will target and clear goals for the reduction and elimination of the use of those targeted substances.  The MOL needs to prepare a Toxic Use Reduction plan to make this initiative effective.

Substances that the MOL should make a priority include carcinogens, mutagens and teratogens. In fact the report Prevention of Occupational and Environmental Cancers in Canada:  A Best Practices Review and Recommendations1 published in May 2005 identifies substitution as one of the best practices for preventing exposures to carcinogens.

Mandatory Substitution

While a policy of “encouraging the substitution of hazardous substances with those that are less hazardous” would be a nice first step, we feel very strongly that mandatory substitution is needed to drive toxic use reductions to protect the health of workers.  The results of a survey by KPMG interestingly enough supports our position.  The KPMG Canadian Environmental Management Survey of Canadian Corporate Executives reported:

# 16% were motivated to take action on environmental issues when government programs were voluntary; and

# 95% were motivated to take action on environmental issues to ensure compliance with government regulations.