In his 2008 December Report, the Commissioner of the Environment and Sustainable Development, Scott Vaughn examined how the federal government manages and controls air emissions. Specifically, the Commissioner evaluated four different approaches that Environment Canada uses to reduce emissions.

These four approaches included an agreement with the Canadian Chemical Producers’ Association (CCPA), which is a Memorandum of Understanding (MOU) with the Governments of Canada, Ontario and Alberta for the reduction of 25% of volatile organic compounds between 2001 and 2005.

The report concludes: “The agreement met many of the requirements for a voluntary agreement: it set clearly defined objectives and targets, and provided for the reporting of results. Data from Environment Canada and the Association show success in meeting the agreement's target of a 25-percent reduction in emissions for volatile organic compounds by the end of 2002.”

There were a number of ways that the MOU was verified. First, the agreement included outside stakeholders, including representatives from Pollution Probe and STOP, a Montreal based environmental group. This group reviews the data, the actions and technologies behind the data and reviews the results against the targets that were set.

In addition, CCPA and its members use a public-peer verification protocol which is updated every three years with new areas of focus. Verification teams consisting of advocates, industry experts and neighbours, visit every member company immediately following their three year code implementation period to ensure that the ethic and all the code systems are in place. Every three years, repeat visits by the verification team emphasize performance, ascertaining that management systems are delivering the results expected by the public. Compared to other approaches, only Responsible Care companies can claim to have the combination of a structured, codes based initiative, public and peer verification and stakeholder input.

CCPA believes that governments at all levels are missing the opportunity to encourage initiatives like Responsible Care by working with business associations and companies to improve approaches like the ones reviewed by the Auditor General. Unlike the EPA in the United States, Canada does not have a credible environmental leadership program that recognizes sustainability leaders. The President of CCPA, Richard Paton said: “These agreements and leadership initiatives can produce enormous progress at very low cost to government with all the required accountability and transparency required for public support. I am very pleased to see the Commissioner reviewing these initiatives for their effectiveness.”