Letter Template and Instructions: Please go to (http://www.ebr.gov.on.ca/ERS-WEB-External/searchComment.do?actionType=add¬iceId=MTA0MzAy&statusId=MTU1ODkz¬iceHeaderIdString=MTA0MzAy) and tell John Gerretsen, Ontario Minister of the Environment, you are an RN and you support strong, comprehensive toxic use reduction legislation guided by the precautionary principle, to protect human and environmental health, and to promote sustainable greener industry in Ontario. You could deliver a more detailed message by using or modifying the model letter below. If you do, it would be good to at least include the points in the first set of bullets. For very detailed analysis, you could review Canadian Environmental Law Association (CELA) toxics documents at http://www.cela.ca/coreprograms/detail.shtml?x=4014, including the CELA submissions on the government discussion paper at http://www.cela.ca/publications/cardfile.shtml?x=4039. Dear Minister Gerretsen: I am a nurse who is very concerned about the risk to health from the widespread use and release of many toxic chemicals in Ontario. I therefore welcome the introduction of toxic reduction legislation, and urge Minister Gerretsen to ensure that the legislation is strong and comprehensive, and is guided the precautionary principle. Strong toxic use reduction legislation must include: . ambitious targets for reductions in toxic releases, which have proven achievable in other jurisdictions like Massachussetts .broad coverage of use and emission .this would include more chemicals than proposed in the discussion paper .this would include all significant sources of toxics, and not just large users in the manufacturing and mineral processing sectors .substitution of safer alternatives to toxics .mandatory pollution prevention plans by industry, to be certified by planners .materials accounting of use and release of toxics .regular reporting on progress in toxic reduction by facilities .comprehensive community right to know about toxics in the environment, in the workplace and in consumer products (including labelling) .allowing the most health protective laws and bylaws to prevail (unlike the recent Bill 64, which voided municipal pesticide bylaws) .establishing an independent university-base research institute that will build Ontario's capacity for toxic use reduction, safe substitution and green chemistry .establishing programs to deliver technical assistance on toxic use reduction for facilities, for labour, and for communities. .adequate funding for the above programs, through fees on toxic use and release. .strong compliance remedies for government and the public The Ministry discussion document delivers some of these requirements, but not all: .It proposes new requirements for toxics: materials accounting (for use, release and disposal); toxic reduction plans; reporting; and public disclosure. Compliance with reduction plans is voluntary; voluntary programs generally experience difficulties with compliance. .Aggressive targets must be added. .A focus on substitution of safer alternatives must include identification of priority toxics for substitution and company toxic reduction plans based on government alternative action plans. .It proposes to cover only certain users and emitters. It would only include those using designated toxics: if the toxic use exceeds a designated threshold; and if the facility is in a designated sector (manufacturing or minerals processing); and if the facility exceeds an employment threshold (10 full-time employees) or use threshold (10,000 kilograms or federal threshold). This misses smaller emitters and other sectors; in cities like Toronto, the large majority of emissions would not be covered. .More chemicals should be covered, and the phase-in of coverage should be simplified and accelerated. .It proposes a ban or restriction on toxics in consumer products, and require public reporting on toxics in those products. This is welcome, but a requirement for inclusion in labeling must be added. .Technical assistance is proposed, but this must be backed by the creation of bodies mandated to provide this assistance and funded through toxic use fees. .It proposes to provide Ontarians with information on toxics in the environment and in consumer products. This is essential. .It proposes economic and other incentives for toxic reduction. This must be supplemented by strong compliance remedies for government and the public. To repeat, I am pleased that the Government is committed to toxic use reduction legislation, but the proposed strategy must include all the features I have mentioned, in order to protect human and environmental health, and to promote a greener economy. Thank you for your attention in this matter of importance to nurses.