A/HRC/45/12/Add.3 Para 61, 2nd sentence, comments: Please note that this statement does not take into account the consultations held in November 2018 to broaden the definition of vulnerable populations in the context of federal chemicals management activities. The consultations on a broadened definition of vulnerable populations in the assessment and management of chemicals is part of the efforts for setting new directions and objectives for CMP post 2020. The proposed definition encompasses “individuals, who for occupational reasons, may be exposed to higher levels of chemicals”. A link with further information here: https://www.canada.ca/en/healthcanada/services/chemical-substances/consulting-future-chemicals-managementcanada/defining-vulnerable-populations.html Further, occupational health exposure was consulted on in late 2019 for consideration in CEPA reform. We recommend that these considerations be reflected in the statement in question. Para 65, 1st sentence, comments: Please note that in our view this does not take into account Canada’s Hazardous Waste Regulations under Part 7, Division 8 of CEPA, which does not allow the export of hazardous waste to other countries (including, developing countries) if they cannot be managed in an environmentally sound manner. The paragraph also does not mention the Prior informed consent procedure for hazardous chemicals: Rotterdam Convention and Canada’s efforts through the Rotterdam Convention which can be found at the following link: https://www.canada.ca/en/environment-climatechange/corporate/international-affairs/partnerships-organizations/informed-consenthazardous-chemicals-rotterdam.html. Canada has ratified the Rotterdam Convention and is a strong contributor of notifications of final regulatory action and these notifications have led to the inclusion of a number of substances to Annex III of the Convention, making them subject to the Prior Informed Consent (PIC) procedure. Para 65, 2nd sentence, comments: To be more accurate, we recommend that this sentence should begin with a qualifier that, "Although such movements are controlled under the Basel Convention, exporting hazardous…” Para 69, 3rd sentence, comments: Please note that this sentence does not take into account the information gathering powers under CEPA Part 3. Section 46 of CEPA Part 3 outlines the instances in which the Minister may request information, including outside the review of certain chemicals. https://lawslois.justice.gc.ca/eng/acts/c-15.31/page-5.html#h-63687 Para 75, last sentence, comments: If this is meant to refer to the recommendation made by the House of Commons Standing Committee on Environment and Sustainable Development, then for accuracy, we recommend changing to: “A Parliamentary Committee recommended that “[…] CEPA be amended to require mandatory hazard labelling of all products containing toxic substances”. Para 76, 1st sentence, comments: Please note that the term CEPA review is imprecise. We would recommend changing this to “parliamentary review of CEPA by the House of Commons Standing Committee on Environment and Sustainable Development.” Para 76, comments: Please note that the footnote here is misleading, as it refers to ECCC’s Follow-up Report to the House of Commons Standing Committee on Environment and Sustainable Development. It suggests that ECCC’s report is the source for Special Rapporteur’s statement regarding 5