A/HRC/45/12/Add.3 insufficient information available so far to assess whether or not there was a violation of the Convention. This sentence should be constrained to just the Philippines case. Comments from Health Canada Para 8, last sentence, comments: Not all chemical regulation in Canada falls under CEPA. To improve accuracy for pesticide regulation, there should be a mention in this paragraph on the Pest Control Products Act – and the framework it provides for the protection of human health and the environment. Jointly managed by Health Canada and Environment and Climate Change Canada, the Chemicals Management Plan (CMP) brings all existing federal chemical programs together under a single strategy. This integrated approach allows the Government of Canada to address various routes of exposure to chronic and acute hazardous substances. It also enables use of the most appropriate management tools among a full suite of federal laws, which include the Canadian Environmental Protection Act, 1999 (CEPA), the Canada Consumer Product Safety Act (CCPSA), the Food and Drugs Act (F&DA), the Pest Control Products Act (PCPA), the Fisheries Act and the Forestry Act Para 22, last sentence, comments: This number was compiled by the David Suzuki Foundation prior to the coming into force of Canada’s Pest Control Products Incident Reporting Regulations in 2007. Between 2007 and 2017, over 20 000 incidents were reported to Health Canada’s Pest Management Regulatory Agency (PMRA), the majority of which were domestic animal incidents of minor to moderate severity. In 2017-18, 198 human incident reports were submitted to Health Canada’s PMRA. https://www.canada.ca/en/health-canada/services/consumer-product-safety/reportspublications/pesticides-pest-management/corporate-plans-reports/report-pesticideincidents.html Para 23, 1st sentence, comments: It would be good to have a reference to further support this statement or specify which hazardous substance is being referred to here—unless this is meant to only speak to air pollutants (i.e. PM2.5). Para 25, last sentence, comments: All products currently registered and used in Canada must have acceptable risk. Special review provisions exist where if all uses of an active ingredient are banned in an OECD country, Health Canada must proceed with a Special Review. Also, at any time, if the Minister of Health becomes aware of information that would indicate potential unacceptable health or environmental risk, a Special Review can be initiated. https://www.canada.ca/en/health-canada/services/consumer-product-safety/reportspublications/pesticides-pest-management/policies-guidelines/regulatorydirective/2014/dir2014-01-approach-special-reviews-dir2014-01.html Para 25, 1st sentence, comments: In reference to “unlike occupational laws”, it is unclear what occupational laws do not require exposure to be considered or require risk assessments to be completed in Canada. Para 30, 2nd sentence, comments: Children and infants are considered as a specific vulnerable sub-population in the risk assessments conducted by Health Canada for pest control products. A pest control product will only be registered if that risk is acceptable, including the risk of Pest Control Products used on food. 10

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