| dc.contributor.author | Richardson, Mary | |
| dc.date.accessioned | 2009-07-30T20:26:57Z | |
| dc.date.available | 2009-07-30T20:26:57Z | |
| dc.date.issued | 2009-07-30T20:26:57Z | |
| dc.identifier.uri | http://hdl.handle.net/2149/2270 | |
| dc.description | This interdisciplinary conference was exceptional in that the papers were individually excellent, and there was a thread weaving through many of the papers, especially those presented by ecological economists, concerning the inadequacy of neo-classical economics to analyze and provide solutions to environmental problems, that was related to my presentation. Although I am a philosopher, not an economist, I work in the applied ethics field of environmental ethics, and the thesis of my paper was that the requirement by the Canadian federal government that recommendations from Health Canada and Environment Canada to Cabinet and the Treasury Board for regulating toxic chemicals be supported with cost-benefit analyses undermines the application of the ethical principles that ground the Canadian Environmental Protection Act (1999). I presented the paper to try out my ideas in preparation for my sabbatical, during which I will attempt to deepen the analysis and strengthen the paper.
As at many conferences, the time allotted for discussion was very short, and I had to work hard to glean ideas for improvement from the questions and comments received. The paper was well received (one person suggest that I start a blog similar to Don Brown’s on ethical aspects of climate change). However, I realized that my argument to show that cost-benefit analysis would work against the principle of pollution prevention was weak. One of the comments helped me to realize that I could strengthen it by discussing the assumptions behind the practice of calculating in monetary terms the benefit of saving a human life in order to show that the benefit of reducing, for example, a certain number of cancer deaths is not outweighed by the cost to industry. Also, of course, I am not an expert in cost-benefit analysis, and I learned from two comments how to state the implications of the practice of discounting for intergenerational equity more accurately.
I plan to revise this paper and submit it for publication. It is part of a broader study of Canada’s Chemicals Management Plan, which will bring in problems with risk assessment as well as risk management. The broader study will also place more emphasis on a comparative approach than I was able to in this presentation. | en |
| dc.description.abstract | ABSTRACT In Canada, environmental regulation is circumscribed by several directives, framework documents and guidelines such as “The Cabinet Directive on Streamlining Regulation,” the “Canadian Cost-Benefit Analysis Guide,” and “Assessing, Selecting and Implementing Instruments for Government Action,” that instruct the ministries of Health and the Environment how to discharge their legal obligations to protect human health and the environment. The central agency that oversees regulation in the broad sense, the Treasury Board Secretariat, clearly favours any legal instrument other than legally-binding regulation, such as voluntary initiatives, economic instruments, and involving a variety of actors in “distributive governance” schemes. It will be argued in this paper that the considerations the Treasury Board requires the ministries to take into account in assessing and selecting governance instruments, such as cost-benefit analysis using discounting of future benefits, and an analysis of the degree to which various instruments constrain individual liberty, limit the ministries’ ability to enact effective environmental regulation. The argument will be made using the risk management plans for toxic chemicals published to date as part of the Chemicals Management Plan as an example. It will be shown further that the Canadian approach to regulation mirrors that of the United States under the Office of Information and Regulatory Affairs (OIRA) in the United States Office of Management and Budget, and that while that the REACH regime for chemicals management in the European Union may be superior in some respects, it suffers from many of the same constraints as the North American regulatory system. The paper ends with suggestions for reforming the regulatory process for environmental protection. | en |
| dc.language.iso | en | en |
| dc.relation.ispartofseries | 83.R020.1008; | |
| dc.subject | environmental regulation | en |
| dc.subject | cabinet directive | en |
| dc.subject | treasury board | en |
| dc.title | Circumscribing Regulation or Reforming the Regulatory Process | en |
| dc.type | Presentation | en |
