The Environment and Climate Change Canada and Health Canada jointly published a Notice of Intent (NoI) on the development of a strategy to guide the replacement, reduction, or refinement of vertebrate animal testing under the Canadian Environmental Protection Act (CEPA) on November 30th. This long-anticipated Notice is the 1st of several consultation steps that the Government of Canada will be pursuing, as they look to move away from the dependence of animal tests under the Canadian Chemicals Management Plan (CMP), following explicit call out for this need, materializing from the recent modernization of CEPA.
This notice of intent is a very general overview of the earliest indications of the likely policy direction that will be explored over the course of the next year.
Some key observations of interest:
- New approach methods (NAMs) are defined within this NoI.
- Commits to the establishment of “frameworks and tools” to guide incorporation of NAMs for regulatory prioritization and risk assessment purposes
- The scientific advances align with other regulatory bodies such as the USA, EU and Australia.
- Clear reflection on the need for “strategies and research programs to accelerate development and implementation of NAMs for regulatory decision making”
- The NoI states in Element 2 that “building confidence” regarding NAMs with both government and external stakeholders is “critical for successful progression”
- Element 4 indicates that flexibilities from HC and ECCC will be applied as new NAMs gain regulatory acceptance to meet regulatory requirements.
- Clear linkages to OECD work and engagement
Bottom line – although very early in the process, this Notice indicates that Canada is suitable for consideration as a key target and a pilot for case studies and proof of principles for accelerated adoption of NAMs and non-animal methods in the chemical management space.
You will see that there is a 60-day comment period for feedback on the general direction of the strategy elements as outlined (and beyond). CA Canada will of course be engaging with this consultation and would propose that our engagement could provide for the basis for collaborative and active input from ICCS. The deadline for comments is January 29, 2024. As for next steps, we anticipate that ECCC/HC will be proceeding with a more detailed formal proposal for early consideration in Q3 (summer 2023).
Cosmetics Alliance will work with other trade organizations and ICCS to develop feedback on this guide.
