1. The Ministry should…

1. The Ministry should require a more rigorous investigation into the environmental harms associated with zinc oxide before setting a regulatory standard for that substance. This investigation should include broad consideration of regional and geographical factors.
2. Likewise, the Ministry should engage in more extensive consultation with the public before setting that standard.
3. The methodology relied on in the report for assessing the safety of emissions levels does not account for the cumulative effects of multiple emitters and threatens to allow a “death by 1000 cuts.”
4. The Report is contrary to the precautionary principle, which urges governmental bodies to err on the side of caution when the effects of an official decision are scientifically unclear.
5. A more thorough investigative and consultative process stands to promote innovation and industry competition.
6. The history of poor environmental performance by the applicant firm merits additional caution on the part of Ministry, particularly regarding the firm’s use of an Upper Risk Threshold, rather than a regulatory standard, with respect to its hydrochloric acid emissions.