A/HRC/45/12/Add.3
Para 38, 1st sentence, comments:
Rather than “Mercury exposure poses various health risks, especially to children whose
developing nervous systems are extremely sensitive”, it should be mentioned: “…especially
to the fetus and children whose nervous systems are…”.
Para 43, last sentence, comments:
Information was supplied to the Special Rapporteur on the consultations with Canadians:
Canadians are consulted for all proposed major pesticide registration decisions, such as new
registrations or major new uses of a pesticide, re-evaluations or special reviews. The
consultation documents outline major findings of the evaluations and the proposed decisions,
and are made available on the Health Canada website. The use of registered pesticides in
forestry applications on traditional territories of Indigenous groups falls under provincial
jurisdiction, and each province has its own set of regulations and requirements.
Para 53, 1st sentence, comments:
This is not technically true: children and adults likely absorb chemicals to the same extent,
both dermally and via inhalation.
Para 57, comments:
Wording from Existing Substances, HC 57. “Varying gender specific activities contribute to
differentiated burdens and impacts from toxic exposures. [1] CEPA reviews strive to
incorporate the best available science to assess the potential for vulnerability to individuals
whose activities might place them at higher risk of harm from chemical exposures. These
considerations include sub-population specific exposure data and the use of additional safety
factors to protect vulnerable populations where appropriate. While various chemicals may
inordinately affect women (including many endocrine-modulating chemicals), these possible
effects are routinely factored into CEPA screening assessments.
Para 61, 1st sentence, recommended language:
The Chemicals Management Plan could help to better protect workers. Canada does not
recognize workers as a vulnerable population under the Plan, despite workers being one of
the most vulnerable groups to toxic chemicals.
Para 68, last sentence, comments:
It is not entirely clear what this is referring to—most likely a reference to the formulants in
registered pest control products. All formulants are considered by scientists at Health Canada.
The end product must be acceptable for use, including if it is to be mixed with another pest
control product.
Para 81, 2nd sentence, comments:
Health Canada has corresponded with a number of stakeholders on the re-evaluation of
glyphosate – and when used according to label is acceptable for use. The actual use of the
product in specific situations, such as forestry, is determined by the provincial government.
Para 82, 2nd sentence, comments:
Canadians are consulted for all proposed major pesticide registration decisions, such as new
registrations or major new uses of a pesticide, re-evaluations or special reviews. The
consultation documents outline major findings of the evaluations and the proposed decisions,
and are made available on the Health Canada website. The use of registered pesticides in
forestry applications on traditional territories of Indigenous groups falls under provincial
jurisdiction, and each province has its own set of regulations and requirements.
Para 112 (l), comments:
Health Canada is not aware of this situation occurring in Canada for pesticides.
11
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