RCEN Environmental Network Coordinator

Chemicals are integral to our lives. From the products we use daily, like cosmetics and cleaning supplies, to those we rely on, such as food items and medications, chemicals fuel our economy and inhabit our homes. Some of these substances occur naturally, while others are manufactured or formed as by-products of industrial processes. However, while chemical substances bring undeniable benefits, improper management can pose serious risks to both human health and the environment.

In order to prevent harm to Canadians and their environment, the Chemicals Management Plan (CMP) was launched in 2006 by Health Canada and Environment Canada (now Environment and Climate Change Canada). The CMP’s objective is clear: to safeguard Canadians and the environment from potentially hazardous chemicals.

Civil Society’s Role in Chemical Safety

The scope of managing chemicals is vast, and civil society organizations (CSOs) can play a crucial role in this effort. From research and risk assessment to monitoring and engagement in policy development, CSOs help shape the decisions that protect our environment and communities.

One of the key contributors to civil society’s engagement in Canada’s chemical management is the Canadian Environmental Network’s (RCEN) Toxics Caucus. With a history of collaboration with both Health Canada and Environment Canada that predates the Chemicals Management Plan (CMP), caucus members have consistently played a leading role in advancing chemical safety. Their efforts have been instrumental in shaping public participation to ensure that chemical regulations are effective.

Recognizing the importance of civil society engagement, the CMP introduced an outreach and contribution program in 2022. This initiative aimed to strengthen the participation of CSOs, especially those from communities disproportionately affected by toxic chemicals. The enhanced participation of CSOs would support a range of CMP activities, including risk assessments, risk management, research, monitoring and surveillance, and policy development.

Collaborating for Change: RCEN’s Toxics Caucus

As part of this effort, the Canadian Environmental Network (RCEN) convened the Toxics Caucus. Together, caucus members leveraged their national networks to bring the voices of Canadian civil society groups into the CMP. Their work ensured that civil society groups, including health and environmental NGOs, could engage meaningfully with both Health Canada and Environment and Climate Change Canada (ECCC).

The Toxics Caucus facilitated the exchange of crucial information, provided opportunities for consultation, and fostered stronger communication between civil society and the government. Most importantly, it empowered groups to collaborate on shared priorities, ensuring that diverse perspectives were heard in the decision-making processes.

The 2024 Bilateral Meeting: Shaping Future Engagement

A pivotal moment came on February 29, 2024, when RCEN’s Toxics Caucus met with CMP staff from Health Canada (HC) and Environment and Climate Change Canada (ECCC) in person in Ottawa. The meeting had three key objectives: to maintain an ongoing dialogue, to foster mutual understanding of current initiatives, and to identify priority areas for collaboration where possible.

During the meeting, Toxics Caucus members emphasized the need for greater transparency in chemicals management, calling for better data-sharing practices, stricter regulatory standards, and more rigorous chemical assessments. These concerns, along with the government’s responses, were compiled in the Toxics Caucus Position Paper. This document outlines key insights shared during the meeting, serving as a guide for future collaboration and improvements in the program.

Recommendations for CSO Involvement and Engagement

To strengthen CSO participation in Canada’s Chemicals Management Plan, the Toxics Caucus made several key recommendations. They emphasized the importance of CMP staff:

Providing timely consultation notices to give CSOs adequate time to prepare.
Establishing a sustainable funding mechanism for CSOs to ensure their effective participation in consultations.
Creating a platform for transparent data-sharing among government agencies, CSOs, industry stakeholders, and the public.
Publishing conflict-of-interest safeguards to ensure transparency in measures addressing companies profiting from toxic chemical releases.
Fulfilling the duty to warn by enhancing public access to information on hazardous chemicals and their impacts.
Consulting on the Canadian government’s plan to reduce chemical risks by 50% by 2030, as committed to in its Biodiversity Strategy.

Furthermore, to strengthen scientific rigour, the Toxics Caucus advocated for systematic reviews of published scientific literature to inform regulatory decisions and the development of plans to replace harmful chemicals with safer alternatives.

Caucus members also advocated for a reduction in the use of toxic chemicals and pesticides, a stance that echoes the World Health Organization's recommendations and Canada's commitments under the Convention on Biological Diversity. Article 7 of the Convention calls for “reducing the overall risk from pesticides and highly hazardous chemicals by at least half including through integrated pest management, based on science, taking into account food security and livelihoods”. In June 2024, the government introduced legislation in Parliament to recognize Canada’s international commitment in Bill C-73, an Act respecting transparency and accountability in relation to certain commitments Canada has made under the Convention on Biological Diversity. This could double down on Canada’s 2030 Nature Strategy: Halting and Reversing Biodiversity Loss in Canada.

Finally, the Toxics Caucus underscored the importance of regular quarterly meetings and transparent reporting on staff involvement in the CMP to ensure accountability and foster collaboration. These recommendations, detailed further in the Position Paper, aim to create a more inclusive, and effective chemicals management process that protects public health and the environment.

Moving Forward, But Facing Challenges

One significant outcome of the bilateral meeting was the development of the Toxics Caucus Position Paper, which outlines key insights and recommendations shared during the discussions. This document proposes a roadmap for future engagement between CSOs and the CMP, detailing the steps needed to ensure stronger civil society involvement in chemicals management.

However, just months after the bilateral meeting, funding for the CMP’s engagement and outreach contribution program was unexpectedly halted for the 2024-2025 fiscal year, with no advance notice provided to the Toxics Caucus and contrary to the recommendations of a February 2024 Health Canada internal audit of the Chemical Management Plan, that was neither disclosed at the bilateral meeting nor brought to the Caucus’s attention by the government.

This decision raised concerns among civil society organizations about their ability to continue amplifying the voices of those most impacted by exposure to harmful chemicals. In June 2024, Parliament approved $95 million annually to support the Chemical Management Plan activities, and as of August 2024, government data shows that 475 full-time equivalent staff’s time at Health Canada is dedicated to addressing the health impacts of chemicals. Additionally, 1,474 public servants at Environment and Climate Change Canada are tasked on substance and waste management, including pollution law enforcement. Surely there is room to support the work for civil society sounding boards and oversight in that mix!

Conclusion

The Chemicals Management Plan has been the federal government's marquee tool for safeguarding Canadians from harmful substances, but its success relies heavily on meaningful collaboration with civil society and ensuring that laws and policies are actually reducing measurable risk. The Toxics Caucus demonstrated the power of collective action and bringing diverse perspectives into the conversation. As we move forward, it is critical to ensure that these voices continue to be heard, even in the face of funding challenges.

The future of Canada’s chemicals management depends on transparent, inclusive engagement with all stakeholders, and it is up to us to continue advocating for a safer, healthier environment for all.

Get Involved with RCEN

Interested in collaborating with environmentalists from different non-governmental organizations? The Canadian Environmental Network (RCEN) provides a platform for individuals and organizations to engage in conversations on toxic chemicals, biodiversity, sustainable development goals, and environmental planning and assessment.

To get involved:

Become a Member of the Canadian Environmental Network to participate in our National Caucuses
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References

1. Health Canada. (n.d.). Chemicals Management Plan: Current Initiatives and Future Directions. https://www.canada.ca/en/health-canada/services/chemical-substances/chemicals-management-plan.html

2. Canadian Environmental Network (RCEN). (2024). Toxics Caucus Position Paper: Post-Bilateral Meeting. https://drive.google.com/file/d/1e6EOWq-F77QoS5Ol6weaBgUhIBP7M0-Z/view?usp=sharing

Enhancing CSO Engagement in Canada’s Chemicals Management Plan: Insights from RCEN’s Toxics Caucus