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Great Lakes Binational Toxics Strategy
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Integrated Workgroup Meeting
Canadian Centre for Inland Waters

Burlington, Ontario
June 2-3, 2008

Monday, June 2nd
Welcome and Introductions

John Menkedick, Battelle, facilitator for the meeting, welcomed everyone to the Great Lakes Binational Toxics Strategy (GLBTS) Substance/Sector Workgroup meeting.  John provided a few introductory remarks and outlined the agenda for the three days of GLBTS meetings in Burlington.  John then invited participants around the room to introduce themselves.

What We Have Heard So Far  

Suzanne Easton, Environment Canada (EC), explained the purpose of her presentation:  to summarize comments heard to date from stakeholders through conference calls, meetings, and other forms of communication since the inception of the two new groups.  The co-chairs of the two groups would like to ensure that stakeholders’ valuable input has been captured and understood. 

Context for Substance Workgroup 

Ontario:  Prioritization of Chemical Substances within a Toxics Reduction Strategy 

Julie Schroeder, Ontario Ministry of the Environment (MOE), introduced herself and provided an overview of the Ontario governments’ commitments for a Toxics Use Reduction Strategy. 

Update on Great Lakes Chemical Screening Project 

Ted Smith, United States Environmental Protection Agency (US EPA) Great Lakes National Program Office (GLNPO), introduced Derek Muir, EC, a researcher at the Canada Centre for Inland Waters in Burlington.  Derek provided an update on a project being conducted by himself, Philip Howard, and William Meylan with funding from US EPA GLNPO.  The project aims to screen chemicals in commerce to identify new persistent and bioaccumulative chemicals in the Great Lakes for the purpose of developing an analyte list for monitoring programs.  Ted noted that this project was presented at the April 8, 2008, Substance Workgroup meeting in Chicago. 

Great Lakes Environmental Monitoring Programs 

John introduced Alice Dove of EC, an environmental scientist in Water Quality Monitoring & Surveillance at the Canada Centre for Inland Waters in Burlington.  Alice described environmental monitoring being conducted on the Great Lakes. 


1.      Question (Sue Brauer, US EPA Region 5):  Is the rotation for monitoring sediments now every five years? 

Response (Alice Dove, EC):  At present, the rotation remains every 10 years.

2.      Question (Ted Smith, US EPA GLNPO):  How is the CMP changing your workload? 

Response (Alice Dove):  The CMP is requiring us to re-prioritize programs to accommodate new compounds.  We are dropping some analytes that are less frequently detected and closing a few stations that are not used often.  Some PCB congeners will no longer be monitored.  The CMP is also resulting in greater coordination with U.S. programs.  IADN is trying to identify efficiencies.  Rather than monitor for new substances universally, the most appropriate media should be monitored first, which has occurred in the Great Lakes, and EC is beginning to implement nationally (e.g., analyzing for bisphenol A in waste).  EC is also assessing analytical capabilities, which is a major impediment to monitoring.  

3.      Question (Fe de Leon, Canadian Environmental Law Association):  Is there any coordination between the Great Lakes and northern communities? 

Response (Alice Dove):  There is no coordination specifically in the open lakes.  EC is coordinating with the U.S. in the open Great Lakes and with MOE in the near-shore zone. 

Open Discussion 

Ted Smith presented a framework diagram for identifying new substances to be addressed in the Great Lakes Basin.  The framework is based on the GLBTS Level 1 assessment framework, but it will involve a different set of substances and questions.  Ted described the basic components of the framework.  Feeders for the identification of new substances will include Derek Muir’s screening work, Canadian and U.S. inventories, CMP and the U.S. Chemical Assessment & Management Program (ChAMP), and other sources (such as Ontario Toxics Reduction Strategy, academia, and international sources).  The “Consideration for Substance Selection” section will screen for use/release/exposure and possibly overlay with the CMP.  The questions asked in this section may be the same as those in the Level 1 assessment framework.  The boxes in the present draft of the framework contain no sequential order or flow, but comments and general impressions are invited as the framework evolves into a more detailed flow diagram.   

Suzanne Easton requested comments on potential omissions from the draft framework, or suggested areas of focus for the workgroup co-chairs.  John Menkedick added that the framework, when fully developed, is intended to provide a process for the workgroup to move forward. 

1.      Comment (Dale Phenicie, CGLI):  What is the endpoint for the middle (green) section?  Why are we concerned?  How cautious should we be, and what should we be cautious about?  For substances in commerce for a particular purpose, how will the need for those substances be addressed? 

Response (Ted Smith):  The purpose of the green section is to determine whether there is a reason for concern about a substance in the Great Lakes—which will answer your questions.  At this point, the co-chairs are looking for comments on whether the framework includes the right questions to determine whether there is a potential threat to the basin and, if so, whether management options should be considered.  Part of the charge of the new workgroups is to determine the reason for concern for new substances.  In cases where there are criteria, it may be easy to define.  In other cases, concerns may be harder to define. 

Response (Lin Kaatz Chary, Northwest Indiana Toxics Action Project and Great Lakes United):  The answer to your questions can be found in GLWQA Annex 12, which provides the basis for why we should be concerned about persistent toxic substances.  One issue in Annex 12 is identification of persistent toxic substances and a second issue is actions to be taken. 

2.      Comment (Allan Jones, Canadian Chlorine Chemistry Council):  Who else should be engaged as stakeholders?  The success of the GLBTS has been in engaging participants.  Decisions in the framework might require additional participants as we consider new substances. 

3.      Comment (Lin Kaatz Chary): 

  1.  The green section of the framework is missing a box on hazard.
  2.  The precautionary approach should be a separate box from the box labeled “Other reasons for concern.”
  3. The framework should identify limitations on the quality and accuracy of information available.
  4. The framework should discuss the default position when there is a lack of data and/or uncertainty.

4.      Comment (Julie Schroeder):  In the “Risk-based criteria” box, what is the significance of risk?  Some criteria are based simply on toxicity. 

Response (Ted Smith):  This box was borrowed from the GLBTS Level 1 assessment framework.  It could be revised to remove the words “risk-based.”  The intent is to compare data against available benchmarks that have been developed through a regulatory process. 

Response (Dale Phenicie):  The “Risk-based criteria” box suggests that you consider the risk of exposure to a substance.  For instance, a toxic chemical may not be used in a scenario that results in great exposure.  There would be limited concern for such a chemical. 

Response (John Jackson, Great Lakes United):  Changing the name of the “Risk-based criteria” box would help the non-governmental organizations’ (NGOs) concern about the process being only risk-based, with no precautionary consideration. 

5.      Comment (John Jackson):  Prevention should be used as criteria in identifying substances.  Substances with little presence in the environment but high hazard potential should be the focus of concern (and move through the diagram to management actions).  Recommend adding a box titled “Need for prevention.” 

6.      Comment (Fe de Leon):  The precautionary approach should be in the guiding principles, rather than in a box, to provide context for the process.

Context for Sector Workgroup

North American Sector Analysis and Commonalities

Edwina Lopes, EC, presented an analysis of North American industry sectors to identify those of potential interest in the Great Lakes Basin.


1.      Question (Dale Phenicie):  Regarding the 50 priority chemicals identified through Great Lakes surveillance, the term “priority” suggests that some decisions have been made concerning these chemicals, which may not be true.  Also, why is the term “surveillance” used to describe the Great Lakes Chemical Screening Project?  The project involves modeling to conduct screening based on physical/chemical properties. 

Response (Ted Smith):  The term “priority” used to refer to the chemicals screened by the Great Lakes Chemical Screening Project can be changed.  Also, while the term “surveillance” is used broadly, the Great Lakes Chemical Screening Project does employ modeling to predict persistence and bioaccumulative potential, and screening for toxicity. 

CMP Sector Strategies: Petroleum Sector

Indrani Hulan of EC described CMP sector strategies to address high priority substances in the petroleum sector. 


1.      Question (Frank Anscombe), US EPA GLNPO:  What was the origin of this sector?  Why weren’t other sectors selected under the CMP? 

Response (Indrani Hulan):  The petroleum sector was chosen for a sector approach due to the nature of substances and the fact that many substances were related to the petroleum sector. 

Response (Allan Jones):  The petroleum sector approach emerged not from the Challenge but from the stakeholder dialog process.  The petroleum industry realized that they had a subset of substances which were primarily associated with their sector.  The petroleum industry may not be representative of all industry sectors. 

2.      Question (Mike Murray, National Wildlife Federation):  Do the petroleum substances include byproducts or waste products? 

Response (Indrani Hulan):  Many substances are byproducts or intermediates, and not end products, but all substances must have an assigned Chemical Abstracts Service (CAS) number. 

U.S. Sectors and the Regulated Uses of Materials 

Frank Anscombe of US EPA, co-chair of the Sector Workgroup, discussed U.S. sectors and the regulated uses of materials. 

Industry Perspectives on Chemicals Management in North America:  Integrating National Programs with Great Lakes Regional Needs 

Allan Jones, Canadian Chlorine Chemistry Council, and Paul DeLeo, Soap and Detergent Association (SDA), presented a summary of industry perspectives gathered through discussions with CGLI, as the industry group most engaged in the GLBTS at present. 

Open Discussion

1.      Comment (Lin Kaatz Chary): 

  1. Be aware that ChAMP databases may not be as comprehensive as they need to be. They may not include all needed parameters.
  2. Regarding the sectoral issue, confidential business information (CBI) needs to be negotiated in the context of promoting safer alternatives because the development of substitutes should be discussed sector wide.
  3. The GLBTS should be consistent with national program management actions but not limited by them.

Response (Frank Anscombe):  We do want to be consistent with national programs, but individual stakeholders may be pursuing agendas outside of EC or US EPA programs.  We are not seeking one solution for all stakeholders.

Response (Paul DeLeo):  CBI generally pertains to human health data.  The least objectionable use of CBI data would be sharing it with US EPA.  States, for example, have not been able to access CBI data.

Response (Greg Carreau, EC):  Regarding maintaining consistency with national programs, a number of ongoing activities could inform the GLBTS, and vice versa (e.g., monitoring work on new substances, update of DSL, sector-based approach for the petroleum sector, and potential new sector approaches in Canada).  Canada is also pursuing new analytical methods for new substances.

2.      Comment (Allan Jones):  The Sector Workgroup can act as a starting point for the collection of information and identification of concerns within the basin.

3.      Comment (Mike Murray, addressing Paul DeLeo):  What is the status of the 350 orphan chemicals in the HPV Program?

Response (Paul DeLeo):  The ~350 orphan chemicals are not sponsored.  US EPA will use the QSAR approach where there is not sufficient data to make characterizations.  Also, note that consortia may not represent all companies that manufacture a chemical (i.e., there are some free riders).

Response (Allan Jones):  The ~350 orphan chemicals are a broad array of substances identified through OECD and national programs.  The HPV Challenge process was established with the intent for companies to provide information where they felt it was worth the investment to generate new information.  It is not as if industry is withholding information on these substances.  At least 90% of HPV substances have been sponsored.

4.      Comment (Sue Brauer):  CBI data can be used at the state level.  As an example, Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) information has been shared with states in the development of water quality standards.

5.      Comment (Ted Smith):  Regarding the new task elements proposed in industry’s presentation, the Substance Workgroup is beginning to undertake some of these tasks.  For instance, the governments are establishing a monitoring and surveillance program, and the proposed two-track effort is consistent with the governments’ current direction.  In addition, the five-year timeline for ChAMP will borrow from the DSL and IUR to develop risk profiles, which will serve as the basis for risk management activities under TSCA.  Industry’s proposed task elements reinforce the need to proceed with developing the framework for identifying new substances (presented earlier).

6.      Comment (Ted Smith):  We need to discuss the role of risk and hazard, which will impact any management scenarios that are developed.  Preferably, it need not be an either/or situation (risk or hazard).  Note that a risk-based approach is used at the national level.  There is not a national chemical management response to hazard, although voluntary approaches may be employed (e.g., green chemistry).  Risk is more regulatory in nature.

7.      Comment (Ray Vaughan, New York State Attorney General’s Office):  What is the timeline for monitoring chemicals that can be analyzed?

Response (Ted Smith):  Fish were analyzed in 2007.  Final results may be available by November 2008.

Response (Suzanne Easton):  There are existing monitoring programs in the basin.  As substances emerge from surveillance studies, some may be able to move along more quickly, for instance those with analytical methods in industry’s proposed two-track approach.

8.      Comment (John Menkedick, Battelle):  Is there any possibility of identifying a chemical to pilot test the new substance selection process?  Ten substances were identified in Edwina’s presentation as intersecting CMP, ChAMP, and Great Lakes surveillance work.  These might provide potential candidates for a pilot test.

Response (Edwina Lopes):  Several siloxanes would provide a good test case.  This would help identify issues and data gaps.

Response (Allan Jones):  The need to test the process with specific substances is understandable, but caution is urged if industry engagement is desired.  The final risk assessment process in CMP has not been completed.  It is too early in the process to expect industry to participate in the GLBTS.

Response (Ray Vaughan):  Use of the 10 common substances might depend on whether they are able to be monitored.  Is this known?  (It was not known whether these substances can be monitored.)

Response (Frank Anscombe):  We do not have background information on substances, such as environmental releases, uses, and management of wastes.

9.      Comment (Fe de Leon):  Lessons can be learned from the pilot process employed at the beginning of the DSL process (e.g., the time limitation and the reason for selecting chemicals).  The DSL pilot process faced many challenges and did not help to speed the process.  Do not identify chemicals too early.  If a pilot process is implemented for the GLBTS, it should be transparent and specify the end goal for the pilot process.



Highlights from Day 1

John Menkedick presented a summary of comments from the previous day.

NGO Perspectives – Criteria for a Great Lakes Regime:  Identification and Actions for Substances of Concern

Lin Kaatz Chary, Northwest Indiana Toxics Action Project and Great Lakes United, presented a summary of NGO perspectives on the new GLBTS Substance and Sector Workgroups.

principle of taking a cautious, environmentally conservative approach to avoid and prevent pollution, according to threats of serious or irreversible damage, even with a lack of full scientific certainty.”[1]


1.      Question (Edwina Lopes):  To clarify, the CMP was not volume-based.  Why is the initiation of action plans six months prior to the end of the screening process?

Response (Lin Kaatz Chary):  The intent is that discussions regarding action plans would begin in January, six months before the screening process is completed, so that we are not starting from zero after chemicals have been identified.

2.      Question (Allan Jones):  How do we focus this process on actions that are doable within the GLBTS?  We may want to consider how to scope future GLBTS activities so that the needs of both industry and NGOs are more aligned.

Response (Lin Kaatz Chary):  It is important for the GLBTS to identify data gaps and needs and, given the limitations of the GLBTS, ask national programs to fill the gaps or address them for the Great Lakes.

3.      Question (Ray Vaughan):  What is the relative importance of screening vs. monitoring data for toxic chemicals in wildlife?

Response (Lin Kaatz Chary):  Toxicity is important.  Sometimes chemicals that were not predicted to become chemically active have been demonstrated to be (e.g., deca brominated diphenyl ether).  A balance of all tools is needed, considering which is most appropriate in a certain context.

Discussion of Path Forward

Ted Smith began the discussion by acknowledging receipt of a letter from NGOs that requested greater input to the new GLBTS process.  Ted explained that the workgroup co-chairs have been slogging through a long-term process and not much headway has been made except for the sector analysis presented by Edwina, the Great Lakes surveillance work, and development of the new substance selection framework.  The governments would like stakeholders to be engaged in the process, but he asked participants for suggestions on the public engagement process and how the workgroup should interact (if the normal quarterly meetings are not sufficient).  Edwina added that, over the past few months, conference calls have been held among the workgroup co-chairs to obtain a better understanding of each nation’s programs (CMP and ChAMP).  Outside of these, there have not been hidden conversations or workgroup conference calls.

1.      Comment (Lin Kaatz Chary):  There was no discussion of or request for stakeholder input to the screening process that has been undertaken as part of the Great Lakes Chemical Screening Project.  Stakeholders would like to be part of the co-chairs’ long-term process, regardless of how slow the process is going.  Also, it would be interesting to solicit public input on the new substance process.  The International Joint Commission (IJC) conducted a successful online submission of public comments that could be replicated by the GLBTS.

Response (Ted Smith):  Stakeholder input on the Great Lakes Surveillance Project was not solicited because the project began before the new workgroups were formed.  However, the project could be changed per stakeholder comments.

Response (Frank Anscombe):  There has not been a Sector Workgroup meeting since last December (2007).  It may be a good idea to hold quarterly conference calls to hear from stakeholders and to update the status of workgroup activities.

2.      Comment (Allan Jones):  Two suggestions –

  1. The outcomes of the Great Lakes Surveillance Project and how they translate into GLBTS actions are crucial for the new GLBTS process.  This project should be advanced because it will inform monitoring efforts and guide the GLBTS sector work.

  2. Another issue is timing of the GLBTS process over the next 12 to 18 months with respect to the CMP on the Canadian side and ChAMP on the U.S. side.  At present, the GLBTS can identify actions that were successful for other substances, and thus could be repeated, as well as issues that need to be addressed differently by the new GLBTS workgroups.

3.      Comment (George Kuper, CGLI):  It is frustrating to not know what the governments plan to do.  While stakeholders cannot make decisions for the governments, stakeholders can make sure that the governments make the right decisions.  The new GLBTS process needs a hierarchical strategic plan that reiterates the GLBTS mission, defines a scope, and establishes objectives and operating principles.

Response (Edwina Lopes):  The Terms of Reference for the new workgroups contain some of these strategic plan elements.  Please specify elements that are missing from the Terms of Reference or need to be clarified.

4.      Comment (George Kuper, CGLI):  The strategic plan elements are included in the Terms of Reference, but the relevant pieces should be put into a strategic plan and placed in hierarchical order because a situation analysis for screening purposes must follow the operating principles.

Response (Ted Smith):  The language in the GLWQA and GLBTS Terms of Reference is intentionally broad.  The objectives of the GLBTS Substance Workgroup, as stated in the Terms of Reference, are to:

We need to define how these objectives will be achieved.  Developing a strategic plan might help to determine the goal over the next 12 to 18 months.  A work plan specific to surveillance work could be developed, with input from stakeholders.

5. Comment (Mike Murray):  With respect to the language in the GLWQA and GLBTS, there is a wide range of potential substances about which the workgroup could reasonably be concerned.  The scope of the GLBTS is not to address leftover issues that were not addressed by national programs.  The Great Lakes region has been at the leading edge for the past several decades, and we should maintain that edge by being ambitious.  The GLBTS has the potential to influence national programs, for example, by recommending substances for surveillance.  The GLBTS is an important, independent entity from the CMP and ChAMP and should not rely solely on those programs. 

Response (Frank Anscombe):  This idea seems to be consistent with the Great Lakes Screening Project.  The intent of the project is to propel some monitoring, beginning in the Great Lakes, that would not otherwise be conducted. 

Response (Suzanne Easton):  The CMP is a strong national program, and the CMP and GLBTS could be seen as two programs feeding each other.  That is, the GLBTS may be able to influence the research and surveillance work performed under the CMP. 

Response (Sue Brauer):  At a recent Lakewide Management Plan event, John Austin of the Brookings Institute spoke about the academic excellence in the Great Lakes region and the need for participation from all groups in the region to maintain sustainability.

6.      Comment (Greg Carreau):  What type of substances will be considered, persistent, toxic substances?  What is the end product of the workgroup, a list of substances for monitoring in the next 6 months?  The framework will take a long time to implement, if populated with the help of national programs.

Response (Lin Kaatz Chary):  The Great Lakes encompass a unique area.  This area first observed problems in wildlife related to the effect of chemicals (e.g., endocrine effects).  I have a checklist of the potential effects in animals, and if substances cause these effects, we develop substitutes for them.  Many different groups are approaching this problem and developing lists of chemicals.  I know which chemicals affect wildlife in the Great Lakes region.

Response (Ted Smith):  The GLBTS could entertain the idea of hazard as a basis for action.  As a non-regulatory program, the GLBTS could employ voluntary approaches such as green chemistry or substitution.  The GLBTS also needs to learn more about endocrine disruptor research programs.

Response (Edwina Lopes):  There are data availability issues and other concerns with the endocrine disruptor work.  The GLBTS will need to consider the scope of what it can accomplish, in a given time frame.

7.      Comment (Fe de Leon):  The Canadian Environmental Law Association has a long history of working in the Great Lakes, and we use that experience to promote an international approach to POPs.  The GLBTS should seize the opportunity to expand the Canadian CMP approach beyond persistent toxics.  The CMP has some limitations, notably:

The GLBTS can use various lists that are being developed and can learn from other jurisdictions; this can be raised to national programs to inform them of their limitations.

8.      Comment (Dale Phenicie):  This discussion demonstrates how difficult the process is.  For example, we cannot determine what an endocrine disruptor is.  We need to utilize other work presently being undertaken.  Also, we should consider the task elements for the GLBTS proposed by Allan Jones and Paul DeLeo.  Monitoring and surveillance researchers could be invited to speak and participate in the new GLBTS workgroups to inform discussions of potential management actions.  The process elements proposed by Allan Jones and Paul DeLeo describe how the GLBTS can accomplish its work.

9.      Comment (Tom Tseng, EC):  The GLBTS was written 12 years ago to address persistent toxic substances in the Great Lakes with a mission of reducing substances.  Today’s discussion involves a larger scope, which the GLBTS may not have the capacity to address.  National programs in both countries will be ongoing for the next 10 to 20 years and will provide guidance for the GLBTS in due course.  In the interim (3-5 years), we should focus on additional reductions in emission and use of persistent toxic substances in the Great Lakes.  We should not branch out into surveillance and monitoring; the GLBTS cannot contribute significantly to national monitoring program efforts.

Response (Ted Smith):  Article II(a) of GLWQA states that “it is the policy of the Parties that the discharge of toxic substances in toxic amounts be prohibited and the discharge of any or all persistent toxic substances be virtually eliminated.”  The GLWQA is not domestic law, and the GLBTS is not regulatorily driven.  It is up to us to decide the future scope of the GLBTS, and monitoring and surveillance is an essential component.  Similarly, there is no regulatory component to ChAMP.  US EPA headquarters is looking to monitoring and surveillance to help prioritize ChAMP efforts.  No other ecosystem in North America is undertaking such surveillance and monitoring as the Great Lakes.  This is a great asset for the region.

Response (Suzanne Easton):  The Canadian perspective on the relationship between the GLBTS and the CMP is that the two programs are not the same but are in alignment with one another.  The GLBTS is seen as building on national Canadian work and not re-creating those efforts (e.g., developing criteria for substances, sector work).  The two groups can inform each other.

In terms of future management options, there are opportunities for the GLBTS to move ahead of national programs, to complement national programs, or to let national programs suffice, as warranted.  Having parallel processes allows some substances to move through the GLBTS substance selection process quickly, while others may take longer.  The GLBTS substance selection process can be viewed as an ongoing, continuous identification of substances as information develops.

Wrap Up & Next Steps

Ted Smith suggested that Substance/Sector Workgroup discussions continue at the GLBTS Integration Workgroup meeting on the following day, June 4, 2008.  The co-chairs will consider stakeholder comments and present preliminary recommendations at that meeting.

Closing Comments

John Menkedick summarized the morning’s comments and noted that one remaining item for discussion was the stakeholder engagement process for the GLBTS Substance/Sector Workgroups (e.g., establishing a schedule of teleconferences).  This item was tabled for the Integration Workgroup meeting on the following day.



1 Anderson Krysta-Lee Environment Canada
2 Anscombe Frank US EPA GLNPO
3 Bailey Bob Bailey Associates
4 Belleau Blaine Chiefs of Ontario
5 Brauer Sue US EPA Region 5
6 Brunski Christine Environment Canada
7 Carreau Greg Environment Canada
8 Chary Lin Kaatz NW IN Toxics Action Project & Great Lakes United
9 Cooke Marcus Cooke Companies International
10 De Leo Paul The Soap and Detergent Assoc.
11 de Leon Fe Canadian Environmental Law Assoc.
12 Dove Alice Environment Canada
13 Easton Suzanne Environment Canada
14 Hulan Indrani Environment Canada
15 Jackson John Great Lakes United
16 Jones Allan Canadian Chlorine Chemistry Council
17 Kirschner Bruce International Joint Commission
18 Krauel Bob Environment Canada
19 Kuper George Council of Great Lakes Industry
20 Lapczynski Aurelia Research Institute for Fragrance Materials
21 Lopes Edwina Environment Canada
22 McLeod Ron ALS Canada Ltd.
23 Menkedick John Battelle
24 Muir Derek Environment Canada
25 Murray Michael National Wildlife Federation
26 Nantel Martin Environment Canada
27 Phenicie Dale CGLI
28 Pineault Denis Environment Canada
29 Roewer Jim Utility Solid Waste Activities Group
30 Rossi Sandy Environment Canada
31 Sabo Elisabeth Environment Canada
32 Schroeder Julie Ontario Ministry of the Environment
33 Smith Ted US EPA Great Lakes National Program Office
34 Strader Evelyn Council of Great Lakes Industry
35 Thomas Amy Battelle
36 Tseng Tom Environment Canada
37 Vaughan Ray New York State Attorney General’s Office
38 Waffle Alan Environment Canada
39 Wines E. Marie US EPA Great Lakes National Program Office
40 Wong Savio Environment Canada

[1] International Joint Commission on the Great Lakes, Eighth Biennial Report, 1996, Chapter 3.

[2] International Joint Commission on the Great Lakes, Eighth Biennial Report, 1996, Chapter 3.


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