The Ontario Bar Association, Environmental Law Section, prepared OBA comments on Bill 167, the proposed Toxics Reductions Act. On the whole, the OBA is cautiously supportive, provided that the Act is restricted to the same list of toxic substances that is identified and regulated through the federal Chemical Management Plan, and is limited to planning and reporting, not mandatory reductions. The OBA asks the province to do everything it can to avoid duplicating regulation, to reconsider absolute liability, and to make provision for confidential business information and security concerns. We also asked for evidence that the province has truly weighed the costs and benefits of the Bill.