Evidence of meeting #11 for Environment and Sustainable Development in the 39th Parliament, 1st Session. (The original version is on Parliament’s site, as are the minutes.) The winning word was chemicals.
Conservative
The Chair Conservative Bob Mills
Thank you, Mr. Schwarcz.
Are you both planning to speak? We took about 13 minutes there. We should to try to keep it to about 10 minutes so that our members have an opportunity to question you fully. Certainly you may share the time, however you plan to do it.
Dr. Gail Krantzberg Professor and Director, Dofasco Centre for Engineering an Public Policy, McMaster University
Thank you, Mr. Chairman and committee members, for the opportunity to speak to you today.
I would like to begin my remarks with some of the impartial findings of the International Joint Commission, the IJC. Many of you know the IJC was created under the Boundary Waters Treaty and they hold the Great Lakes Water Quality Agreement as a standing reference.
The binational treaty organization is responsible for oversight of government progress in restoring and maintaining the integrity of the waters of the Great Lakes basin ecosystem. To address toxic threats, they articulated a new approach that the governments of Canada and the United States committed to when they signed the revised agreement.
The IJC's position is that given the inherent complexities and limitations of evaluating chemicals in isolation from each other, in addition to the scientific uncertainties proving causal relationships between specific chemicals and corresponding health effects, society should eliminate the production and release of chemicals that can not be safely regulated.
The IJC identified a class of chemicals, called “persistent toxic substances”, that cannot be safely regulated. These chemicals include those that cause death, disease, behavioural abnormalities, cancer, genetic mutation, physiological or reproductive malfunctions, or physical deformities in an organism or its offspring. Please note that cancer is not the only end point that the commission was discussing; there are many other end points. It's also worth remembering that cancer is an end point that can take decades to emerge, and its etiology--its cause--can be even much longer to determine.
Article II, to which Canada committed with the United States, says in part 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.
In fact, in this entire annex that Canada committed to signing when they signed the Great Lakes Water Quality Agreement--annex 12, on persistent toxic substances--the general principle, the intent, of the program specific to this annex is to virtually eliminate the inputs of persistent toxic substances in order to protect human health and the continued health and productivity of aquatic living resources.
The list of chemicals also includes those that bioaccumulate--that become more concentrated as they work up the food chain--and chemicals that are persistent. “Persistent” is defined as a half-life greater than eight weeks in water, soil, or living things. If a chemical falls within these classifications, the IJC says it should be eliminated. The approach does not require exhaustive causal proof of harm; rather, decisions are based on a weight of evidence. When there is reasonable documentation that certain chemicals are linked to certain effects, this evidence is sufficient to trigger preventative measures to eliminate the toxic sources. For example, since many chlorinated chemicals studied to date exhibit one or many of these characteristics, the IJC recommended, in its 1992 biennial report, that these chemicals be eliminated from the Great Lakes ecosystem.
Let's turn to government, then. Governments typically regulate chemical releases in order to reduce the occupational, environmental, and public health threats of toxic chemicals. They do this assuming that there are acceptable levels of emissions. End-of-pipe control technology is now at odds with the more sustainable green chemistry that invests in innovative, clean production technologies that eliminate the use of toxic or unnecessary chemicals in the first place.
Further, typical government standard-setting and regulatory approaches to date have been based on risk assessment that evaluates chemicals in isolation from each other to determine the relative risk they pose to environment and health. This approach has allowed the continued production and use of thousands of chemicals, despite their potentially destructive impacts. We've heard approximately 70,000 to 85,000 different chemicals are now in commercial use; most have not been screened to learn whether they cause cancer or have any other effects on the nervous system, immune system, endocrine system, or reproductive system.
Based on quantitative structure activity relationships, which is the relationship between the structure of a chemical and its pharmacological action, one could predict that one chemical will act like another class of chemicals if they look similar in structure. For example, one would predict that the polybrominated diphenyl ethers would have properties very similar to those of PCBs. In fact, they're both highly stable at high temperatures. We understand the toxicity threats posed by PCBs and take measures to stop PCB production, so when the use of QSAR principles shows the likelihood they will behave like PCBs is high, why would we have to prove PBDE toxicity?
In my submission, which is more detailed, I actually present to you the structures of PCBs and PBDEs, and you'll see that they look very much alike.
So what's the European Union doing? Let's look elsewhere for some guidance.
The proposal on the new EU regulatory framework for the registration, evaluation, and authorization of chemicals, REACH, which some of you have heard of, was adopted in 2003. And I'll quote:
REACH aims to improve the protection of human health and the environment while maintaining the competitiveness and enhancing the innovative capability of the EU chemicals industry. A preventive and precautionary approach seeks to shift the burden of proof onto the chemical manufacturers to prove that a chemical is not hazardous to human health or the environment before it is introduced to commercial use, rather than wait for massive injury before any protective action is taken.
I want to come down to some terminology.
There's a lot of research and debate about the ability of certain chemical compounds to cause endocrine disruption at critical stages of fetal and childhood development. This kind of disruption fundamentally challenges the current policy assumptions that there is a safe threshold for exposure to toxic chemicals. It also challenges the regulatory paradigm of the last quarter of a century, which has evaluated chemicals on their ability to cause cancer. I frankly think we've learned a bit more since the sixteenth century about chemicals--the dose causes the disease.
Here's the precautionary principle, as defined right within CEPA, an internationally recognized principle for action that states:
where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation;
Let's contrast this with sound science. Wikipedia offers the following definition of “sound science”, and I quote:
Sound science is a phrase often used by corporate business and industry public relations and by government agencies to describe the scientific research that is used to justify their political claims or positions, or to vilify research threatening their interests hence safeguarding their revenue. Sound science, however, has no specific scientific definition itself, so the phrase is used subjectively.
Wikipedia offers the following definition of “junk science”, which I rather like: “Junk science is a term used to derogate purportedly scientific data, research, analyses or claims which are driven by political, financial or other questionable motives.”
And then there's the really interesting phrase “scientific certainty”. I'm a scientist and I've never, ever encountered scientific certainty. So scientists could define “scientific certainty” as “being 95% sure that cause and effect have been correctly identified.” It is exceedingly rare for a large group of scientists to be 95% certain about anything, especially about anything as complex as environmental problems. When you're talking about living systems, great scientific uncertainty is the norm.
How is scientific uncertainty currently treated in environmental protection? Well, let's look at the classic case.
The classic case is the introduction of tetraethyl lead into gasoline. When chemical and automobile corporations announced that they were starting to put highly toxic tetraethyl lead into gas in 1922, numerous public health officials thought it was a bad idea and they urged delay and careful studies. The corporations argued that there was no scientific agreement about the threat, and in the absence of convincing evidence of widespread harm, which was impossible because they hadn't even taken the action yet, they insisted that they had the right to proceed. The consequences of that decision are now a matter of record: tens of millions of Canadians and Americans suffered brain damage, their IQs permanently diminished by exposure to lead dust.
Finally, I'd like to conclude with the Canada-Ontario agreement and come back to the Great Lakes Water Quality Agreement. The Canada-Ontario Agreement Respecting the Great Lakes Basin Ecosystem, COA, is a federal-provincial agreement aimed at enhancing and protecting Great Lakes basin ecosystems. The agreement outlines how the two governments will cooperate and coordinate their efforts. The most recent COA was signed in 2002. It expires in 2007. The agreement fundamentally has been helping Canada meet some of its commitments under the Great Lakes Water Quality Agreement.
The COA has an annex called harmful pollutants. Under the goals of the harmful pollutants annex are to virtually eliminate or reduce harmful pollutants in the Great Lakes. Of the ten expected results under the annex, six are focused on reductions of prioritized chemicals.
Let me note some of the principles in the 2002 COA--and these are included in more detail in my submission--I'll just name a few: adaptive management, openness, continuous learning, progress, improvement, pollution reduction, the precautionary principle, prevention, stakeholder engagement, and sustainability.
As we examine and currently witness the government's review of the Great Lakes Water Quality Agreement that's under way right now, it will become increasingly important to examine the current science policy and the emerging concepts in ecosystem protection and the protection of human health. The CEPA review is highly relevant to this review. It could set Canada's tone for addressing chemical insults for which the Great Lakes Water Quality Agreement contains many federal commitments.
Finally, most risk assessment and risk management methodologies consider that the greater the persistence of the chemical, the greater the potential risk to the ecosystem. I'd like for CEPA to consider that some pollutants arise from substances that are in use on a continual basis, high-production chemicals, chemicals that are in personal care products, pharmaceuticals that have value to society but are constantly introduced into the environment, and of which, for all intents and purposes, the supply is continuously replenished. Therefore, even substances that don't have long half-lives in the environment should be subject to scrutiny through CEPA.
To conclude, I recommend the precautionary principle of CEPA be not only upheld but applied vigorously to protect the most sensitive use; that debates that centre around sound science be excused as immaterial; and that scientific certainty is recognized to be a myth--as no such thing exists. I'm not arguing that toxic substances can derive from natural or man-made sources, there are toxic substances that are in use that the precautionary principle of CEPA needs to look at extremely carefully.
Thank you.
Conservative
The Chair Conservative Bob Mills
Thank you.
Mr. Weinberg, I would ask you as much as possible to address Mr. Schwarcz's comments. Rick Smith did give us some very definite studies that had been done on the families he looked at, and then Mr. Schwarcz did an interview where he questioned some of those findings. The intent of the committee was to look at both sides of the issue to try to balance that off, to really understand the studies better. The more you can address that, the better it would be for us, if you can, please.
Jack Weinberg Senior Policy Advisor, International POPs Elimination Network
Thank you. I'm honoured to be invited to testify before this committee.
My name is Jack Weinberg. I'm a senior policy adviser to the International POPs Elimination Network, which is a network of non-governmental organizations in 70 countries. It started around the negotiation of the Stockholm Convention and now works more generally on chemical policy.
I got a call from colleagues on Monday—I live in Chicago—to come in on this, so I will try to shed as much light as I can. Although I've not been following your debates, I did prepare some notes.
Without talking about the study per se, although we can go into what I can share on it, my heart sank when I heard Dr. Schwarcz's comments, since I thought we had gone beyond some of those debates some time back. Let me give some examples, and then maybe I can go into more detail on how they might relate.
First of all, while the precautionary principle is embraced in most of the world, there is nowhere that it's embraced as a no-risk policy. The precautionary principle balances three important components. The first is that there is substantial reason to believe there's a cause-and-effect relationship—not necessarily definite proof, because that's almost impossible, but some substantial reason. The second is that the potential for harm is large-scale and irreversible. The third is a socio-economic consideration: what are the relative social implications and cost implications, and are alternatives available, and so forth.
A policy that's based on the precautionary principle, which CEPA has been and which it needs to continue to be, is a policy that balances in a proper way those three considerations and doesn't get stampeded by efforts to create scientific doubt and the whole manufacture of scientific uncertainty, which was begun with the public relations organizations supporting the tobacco industry, where the term “sound science” was first initiated.
The whole manufacture of doubt has become a large-scale industry. We've seen it with climate change. The cause and effect relationships in toxicology are much more complicated and the issues are much more individual, and therefore the manufacture of doubt is a much more lucrative industry and much easier to pursue.
I want to give an example of the kinds of things we heard that sound good on the surface but then fall apart. We talked about PBDEs. The study said there were 0.5 micrograms per litre in the blood, and since there are five litres of blood in a human body, we're talking about 2.5 micrograms in the human body. Well, that would make sense if blood were the main place where these pollutants are stored. But we know these pollutants are lipophilic; they're primarily stored in the fat. They only appear in the blood because there is some fat in the blood. So the kind of “sound science” that takes the only thing we know, which is what was found in somebody's blood, and therefore generalizes to a full-body burden of 2.5 micrograms in the body, is not sound science at all. It is public relations.
Let me give another example. We were told—and it's correct—that there are many forms of dioxin. The four-chlorine—the tetras, with a chlorine on the four corners—are the most toxic. That's well known. It's also well known that the octas, which are the common dioxin form—not the bichlorine, but the octas—are the really not highly.... But we've all known that for many years, and no place in the world that I know of regulates dioxin by individual congeners.
Scientists and policy people have come up with a notion of “toxic equivalency factors”, taking the tetras as one and then assigning all the other congeners a fraction; then, whenever you analyze for dioxin you come up with a toxic equivalency, the TEQ. All regulation on dioxin is based on TEQ, because there's recognition.
So again that was throwing smoke. That was not based on any real debate that's going on.
Also, as to this stuff about the apples and oranges, CEPA, I presume, like other chemical policy legislation, addresses anthropogenic toxic substances. It doesn't represent all chemicals; we're all made of chemicals. It's anthropogenic.
By anthropogenic, it's either things that are synthetic, things that are man-made, or since a lot of things that are man-made also exist in nature and because there are other ways of getting toxic materials into nature other than their manufacture, there are also toxic substances that are mobilized in nature, in the environment, by human activity in unnatural quantities. So it's anthropogenic toxic substances that we are talking about, not all chemicals.
The reason this is an important matter is that we started out, as you recall, when there was a hole in the ozone layer, and there was the question of the science, tying ozone-depleting substances to the stratospheric ozone depletion. That was debated for a while. It was opposed and the science was debated, but it was finally resolved.
Then we went through a much more bitter debate about greenhouse gases in the atmosphere. Again, the actual basic mechanism is extremely simple, so the manufacture of doubt was on all the actual climate science and the mechanisms and sinks, and all that sort of thing. So we lost a good decade, and maybe we'll lose more, in dealing with an extremely difficult problem that, once we recognize it, we'll find that the things we have in place are not sufficient to deal with it. It's a very serious problem to the world.
But the question before us today, anthropogenic toxic substances, is much more complicated. The stratosphere is a rather simple mechanism. For the atmosphere, the mechanism was simple but the climate models were difficult. Now we're talking about the biosphere--that is, humans and all living things evolved in a particular chemical environment, and everything about us is chemical.
Biochemistry is the miracle under which the fetus develops. We develop into full human beings. All our bodily functions are managed by a biochemical process.
We are now introducing a large number of anthropogenic toxic substances into this biosphere, and some of the impacts are known, and some are less known, but we cannot accept any longer....
We thought this was resolved with science that originated in the Great Lakes of U.S. and Canada in the 1980s and early 1990s. LD 500, where you see how much it takes to kill a fish, is not the be-all and end-all of toxicology. That's one aspect. That's for acute poison; that's what kills.
What we learn is in regard to what has been called endocrine disruption, but I think sometimes that gets confusing. So even though this is not the normal word, I prefer to call it signal disruption, because that's a more general term.
Most biological processes are managed through receptors on cells. Chemicals, then, are attached to that receptor, and they trigger some kind of activity. That's how development occurs. That's how bodies function. So that's receptors. It's very complicated. So you have a chemical information exchange system that goes on in the human body. It's also through smelling. Some animals exchange information that's necessary through hormones, but you have very complicated chemical information exchange systems.
Signal disruption comes when chemicals that are synthetic or anthropogenic, either in their existence or in their quantities in the environment, which are different from the conditions under which these organisms evolved, are suddenly in the environment in quantities that are putting noise into a very complicated signaling system. That noise can take the form of a chemical that attaches to a receptor and triggers an action that's not supposed to be triggered. It can take the form of a chemical that attaches to a receptor and prevents it from reacting when it should react. Or in other ways it can interfere with the chemical before it reaches the reactor.
So a large number of health effects that began to be understood only in the 1980s and early 1990s, largely initiated by research in the Great Lakes, are mediated by these signal disruption mechanisms. Endocrine disruption is the mostly commonly discussed, but it's broad, and the dose equals the poison.
While it might have been adequate for the 16th century, science no longer addresses this. I think most scientists believe that for dioxin in the vicinity of zero, the dose response curve is linear to zero. I think that's been disproved, although there are many efforts to fudge it.
I think the dioxin dose response curve in the vicinity of zero.... But in large quantities of dioxin, as we saw, the prime minister to be of the Ukraine was poisoned with a large quantity of pure dioxin, and he didn't die. A lot of the signal-disrupting chemicals have very strange dose response curves. Some scientists have even been finding U-shaped dose response curves. Where it's close to zero, it's going up quite rapidly. Then not only does it taper off, but in larger doses it starts going down. This is because biological systems will respond to small doses as a signal of some kind, but when the dose gets large, that whole system shuts down, so as not to overreact the system.
We're not dealing with LD500s, and we're not dealing with how much will kill you and not much under that. We're dealing with a large number of effects that affect intelligence, learning ability, behaviour disorders, and a developing fetus. We're dealing with reproductive effects, such as the one that was mentioned from Servaso, and many other reproductive effects. We're dealing with immunological system dysfunctions that we still don't fully understand. Very likely, we're dealing with the prevalence of prostate cancer and other prostate problems in males of my age, caused by events that occurred when I was a fetus. It took all that time to develop.
These things were all discussed when I was following Great Lakes environmental issues ten years ago, and more. These are the problems that we have to address.
More was said in that presentation and in question and answer, but I'm sorry to say I'm not a trained toxicologist. I'm just a well-read layperson. I do admit to being an advocate.
I think those are very important questions, and I want to say a little, if I can conclude, about this committee.
Conservative
Senior Policy Advisor, International POPs Elimination Network
I wanted to say something about CEPA, but maybe you've been talking about CEPA enough and want to discuss this issue. Maybe we can come back to some thoughts on CEPA in the question and answer.
Thank you.
Conservative
The Chair Conservative Bob Mills
As our members ask questions, I encourage our witnesses to interact. When you hear something you want to respond to, please do so.
Mr. Godfrey.
Liberal
John Godfrey Liberal Don Valley West, ON
That's exactly what I'd like to happen. I'd like to turn my ten minutes over to an interchange between Mr. Weinberg and Dr. Schwarcz.
It seems to me you have more things to say, but I think Dr. Schwarcz would like a comeback.
Go to it, gentlemen. You have ten minutes.
Director, Office for Science and Society, McGill University
I don't think we're at odds in terms of trying to protect the public. I mean, this is motherhood and apple pie. Of course we want to eliminate dangerous substances from our environment. The question is how we go about doing this. We can both spew data, but it comes down to a question of judgment and making educated guesses.
I would dispute the dioxin curve. I think there certainly is evidence for dioxin having a hormesitic effect. I would direct you to a number of papers by Ed Calabrese, who has looked at this issue extensively with his colleagues. There's a lot of information on this, that it's not a linear curve.
The reason I looked at the blood chemistry when we were talking about the ethers is that this is exactly what Environmental Defence did. They took subjects from across the country and measured blood levels. They did not relate it to fatty deposits and how much was in the fat. They looked exclusively.
Incidentally, the polybrominated diphenyl ethers have been extensively looked at both in terms of total body burden and in terms of what is present in the blood. I've searched the literature on this really thoroughly, and I don't find any animal data that would suggest the doses we are exposed to represent a risk.
I keep coming back to the fact that, as you well pointed out, there is no certainty in science. We make decisions. We have come to be accustomed to a certain mode of living wherein we make use of a large variety of substances. The number of chemicals to which we are exposed is immense. If you just think back to what you may have done in the last 24 hours, you've probably drunk out of plastic cups, eaten out of plastic dishes, or used cosmetics.
These are chemically extremely complex things. Each of these has to be manufactured. It's impossible to manufacture them without releasing some substances. Just the fact that substances are there and are measurable really doesn't say anything more than that we have tremendous analytical capabilities, in that we can now measure things down to parts per trillion or even less.
And just one more thing: you were talking about changes in molecular structure and how subtle that concept is. That, of course, is true. But you can't always predict. If you look at methanol and ethanol, what could be more similar than those? You're looking at the two fundamental alcohols, with one carbon difference, and yet methanol is far more toxic than ethanol. I think if you didn't know that and only looked at the toxicity of ethanol, you would not predict the methanol toxicity, or vice versa.
Liberal
John Godfrey Liberal Don Valley West, ON
I didn't mean to exclude, by the way, Dr. Krantzberg from this or—
Professor and Director, Dofasco Centre for Engineering an Public Policy, McMaster University
I'd like to make one point, if I can.
Conservative
The Chair Conservative Bob Mills
I think Mr. Weinberg was next. Then, Ms. Krantzberg, we will come to you right after.
Please try to keep it—and I think you'd agree, Mr. Godfrey—as brief as you can so that we get the maximum.
Senior Policy Advisor, International POPs Elimination Network
I really hope that the debate over chemicals can become a good-faith debate and not a spin debate. To find one-sided sets of arguments from all kinds of places always tracing back to the same sources is discouraging.
Yes, they looked at blood, because you can't take a human body and cook out all the fat. Blood is the best. You can take a fat incision; you can do all kinds of medical procedures. That's why they looked at blood, but we know these are fat-loving content and we know the body burden exists in fat. I consider that to be just the manufacture of confusion to people who don't know this.
On the question of the dose response on dioxin, I remember that in the early 1990s there was a big conference. The industry then put out big press releases saying that this conference concluded the dose response was near zero, that it was not toxic; then, in Scientific American, all the scientific associations said those were not the conclusions, that was just a public relations spin on the conclusions.
Originally the U.S. EPA was going to reassess its dioxin based on those findings. Now it's been 15 years, and because they couldn't make that case, they haven't ever concluded that reassessment and have reached no conclusions, because either you'll reach the right conclusion or there's enough money and enough influence to keep you from reaching any conclusion.
Hormesis, though, is different. There's a dioxin curve. I only said “linear” in the vicinity of zero. The dioxin curve is not linear. In very small quantities it has profound impacts, but as those quantities go up--that's what Seveso and other things say, and this poisoning in Ukraine--when populations, whether people or animals, are exposed to small amounts, it disrupts a lot of the basic biochemistry, and particularly affects development.
We have studies on PCBs in the Great Lakes of children whose mothers ate Great Lakes fish. These are old studies now. Their children had substantial learning deficits relative to mothers who didn't eat Great Lakes fish. We knew this a long time ago, but the scientists who found that in studies eventually were intimidated, and all kinds of other things happened.
I think the discussion should be a discussion in good faith, in that we are really trying to not just look for all of the partial scientific factoids that support one particular case.
Chemical regulation is a complicated matter. I think it's very fortunate that CEPA is reviewed every five years; that allows a possibility of updating maybe every eight or nine or ten years. New things are found out. I think that CEPA is finally--and in your last review--starting to take up these chemicals for which there are very little data. I forget the name of the list, but you have a list of 23,000 chemicals that were originally grandfathered in, and you've now characterized them. I think that's a very important step. The question now is what's going to come next.
We think the European Union is moving in a good direction. They're actually starting to require the development of data on all these chemicals in more detail. Then they can move into regulatory decisions on them. If I understand, I believe your inherent toxicity criteria are still based on how many fish will die--the lethal dose 50--and do not take into account many of the other toxicological approaches.
Chemicals policy in a world where the environment of life is full of anthropogenic substances that are different from the chemical composition of life when things evolved is a very important responsibility on all of you. I believe that you need very sensitive legislation that goes for increased data and applies the precautionary principle--that is, a no-risk principle--but that also includes another principle that's different from the precautionary principle and that is also discussed and included in law in some places, a principle called the substitution principle. That is, if you have a substance, and it has hazardous properties that are well known but there are alternatives that do not have those hazardous properties or have less hazardous properties, if the economics and the utility are sufficiently compelling, there is sufficient reason to require substitution. You don't need to ban a chemical.
The final thing is, it's not the case that all chemicals can be safely managed. There are some chemicals that, if you produce them and they use them, end in the environment, particularly if they go into products, and so forth.
I very much hope you take a very close look at CEPA and continue to update it as the global debate on chemicals policy moves forward.
Professor and Director, Dofasco Centre for Engineering an Public Policy, McMaster University
Thank you.
To keep the dialogue open and balanced, I want to draw attention to statements such as that there's no evidence that PBDEs at current levels are a risk. That's a true statement, but we also know that PBDEs are increasing in the environment and in animal tissues on a logarithmic scale.
The question we might want to ask is what the projected future is, and maybe we ought to take action before we're at a point where we're approaching concentrations that cause risk, because we know certain of these substances are toxic to invertebrates. Why are we waiting?
That's one point. Another point is that very often the effects we see with certain substances and that Toxic Nation was describing are subclinical. We're talking about loss of several IQ points in children who are exposed to mercury in utero. We know about this, and we think, “What's a few IQ points?” But in fact if you talk to people in the field, what you end up doing is moving the population's bell curve sufficiently that you have a fairly substantial increase in the number of people who are handicapped and a substantial reduction in people who are gifted. So there's a societal cost for some effects that are still subclinical.
I think the most important point of Toxic Nation is not to claim that the concentrations they're observing in the blood of these people across Canada are causing damage now. I think it's a call for biomonitoring, for the evaluation of the potential effects of these substances on humans and on other members of the ecosystem. It's not just humans: we are responsible for protecting—we're stewards for—everything else without voices.
It's a call for action. We're finding it in our systems. As Mr. Weinberg was saying, we didn't evolve with those in our environment. We're not accustomed to many of those chemicals being in our system. So what effect might they be having in our systems? It's a call for caution, and it's a call for research; it's a call for biomonitoring. And it's not a call for Toxic Nation to do the biomonitoring; it's a call on governments to understand what the possible outcomes or consequences of these substances being present in people across nations are. What's the consequence?
Director, Office for Science and Society, McGill University
There's always a “but” in science. No matter what you look at, there always will be a “but”.
Science doesn't progress by giant leaps. It progresses by a series of very small steps. Of course, we're always trying to correct past errors. We hope that if we substitute a substance, it will be safer than the one before it. Obviously that's what the intent is, but it's not always easy to know that. You can't predict. And truly one of the main points I try to make is that one should never suggest that they have knowledge that actually doesn't exist. There's just way too much that we don't know about what the consequences are of regulating and substituting.
I'll give you an analogy, perhaps. Right now we're talking about PFOAs. It's been in the paper for the last couple of days because of the ban on certain perfluorinated compounds, especially the telomers that are used as stain removers. I think that this is a good thing. I think that we do have accumulating evidence of problems there, but there are going to be consequences. We use these products in order to resist stain. If that's not going to work, people will have more stains. They will go to the dry cleaner more often. Then we worry about the tricholoethylene that is used by dry cleaners. That's a very legitimate worry. Tricholoethylene is one of these persistent chemicals that I think we need to do something about.
Then we talk about replacing that maybe with liquid carbon dioxide. The manufacturing of liquid carbon dioxide is not a totally benign procedure either. There are other ways to make stain-resistant compounds. There are some very new technologies, including carbon nanotubes that you've probably heard about. This is all based on the buckyball technology, which is really quite fascinating, because it's essentially a discovery of a new form of carbon. Everyone knows about graphite and diamond as a form of carbon. Well, we have another form--these so-called buckyballs, after Buckminster Fuller, who was the architect who designed geodesic domes. These substances can be incorporated into fabrics in order to ward off stains.
We've already seen a demonstration in Chicago in which the demonstrators dropped their pants that they had purchased at Eddie Bauer, because Eddie Bauer was, according to them, using Teflon to keep off the stains. They weren't even using Teflon. What they were using was the buckyball technology, so they even got that part of it wrong. But in the next demonstration they had, they at least corrected that and they were demonstrating against the use of these nanoparticles in stain-resistant materials. Why? Because the suggestion is that we don't know what is going to happen if we expose the public to these nanotubes. The public, of course, has been sensitized to this because they read Michael Crichton's book, Prey, which suggests that these nanoparticles can somehow multiply or self-assemble and turn the world into toxic goo, as he calls it.
So there is always a “but”. Yes, we try to replace things with the new, and it doesn't always work better. We have to make some educated guesses on these things. We have to look at each class of chemicals very specifically. We have to look at the molecular structures. We have to look at the amounts. I think that there are thresholds, but obviously not everyone agrees with that.
Conservative
The Chair Conservative Bob Mills
We've obviously gone over our time for this question. We're rewarding Mr. Godfrey for a good approach to asking the question.
Also, I would suggest, Mr. Glover and Ms. Taylor, if you have comments at the end, after we have heard this cross-examination, if you would like, we'll give you the opportunity to make comments.
Paul Glover Director General, Safe Environments Programme, Department of Health
We would very much welcome that opportunity.
Conservative
The Chair Conservative Bob Mills
We've had the clerk's office here doing some research and we do have some precedents that we will mention later, but I think in the rules of the House the overturning of a ruling is not necessarily considered a matter of confidence in the chair. That probably summarizes that fairly clearly for members. We'll see that everybody gets a copy of that along with a number of examples of where that's happened.
Mr. Lussier.
Bloc
Marcel Lussier Bloc Brossard—La Prairie, QC
Mr. Chair, I am no doubt tempted, like Mr. Godfrey, to let the witnesses have my full 10 minutes and even to also invite Mr. Glover and Ms. Taylor to take part in the discussion.
I was also tempted, after reading Mr. Schwarcz's biography, to ask him to talk to us about the chemistry of love. His biography says that he is a specialist in the science of aging.
I think that we could let the three partners speak or exchange ideas, but, first, I want to ask Ms. Krantzberg a question.
When you work in consultation with the United States, pursuant to the Boundary Waters Treaty signed in 1909 between Canada and the United States, how do you agree on the list of dangerous chemicals included in the Great Lakes sampling programs? Is this list established in consultation with Environment Canada and the Environmental Protection Agency? Does this list also apply to the Canada-Ontario Agreement Respecting the Great Lakes Basin Ecosystem?
Professor and Director, Dofasco Centre for Engineering an Public Policy, McMaster University
Just as a small correction, I'm now a professor at McMaster University. I've just moved away from the IJC. But I can talk to you about the IJC and the list of chemicals.
The Boundary Waters Treaty of 1909 stated that no activity on one side of the border will cause injury to health or property on the other side of the border. It set the stage for the Great Lakes Water Quality Agreement, which the IJC recommended happen and which the two governments, of Canada and of the United States, through the Department of Foreign Affairs and the Department of State, agreed to.
There is an annex, called Annex 1, that has all of the specific chemical objectives for organics, persistent toxic substances, nutrients, microbiology radiation, and so on. That list was first compiled with advice from the Science Advisory Board, which is a binational board that reports to the IJC, composed of scientists from academia, industry, and to some extent government on both sides of the border, equally populated by Canadians and Americans. Their recommendations went up to the IJC, and the IJC recommended to governments that they implement this list.
The list is now, in some cases, 34 years out of date. A lot of the discussion in development of those lists was based on the inputs of EPA and Environment Canada scientists.
The Canada-Ontario Agreement adopted the top 12 substances the IJC identified as the “dirty dozen”, the ones for virtual elimination. They included those substances in the Canada-Ontario Agreement to work towards their elimination in the environment.
That agreement was in 2002. It's also related to the commitments Canada has made with the United States on something called the Great Lakes Binational Toxics Strategy, which is also a strategy to use voluntary practices to move towards the elimination of those same 12 substances.
So it's a very popular 12-substance list. It doesn't include many of the compounds Dr. Schwarcz was just talking about and we've been talking about; those weren't known at the time. There are many substances that are on the DSL list right now that don't appear on any of these lists.
Professor and Director, Dofasco Centre for Engineering an Public Policy, McMaster University
The agreement is being reviewed right now, and an approach to specific objectives in this annex is being discussed. A lot of interest is focused, instead of on creating a list with numbers that will be out of date as science advances, on trying to build upon, for example, a process like CEPA, so that the governments will be able to explore these new substances through a regularly reviewed process binationally, and on trying to coordinate the binational review of these substances between the EPA and Environment Canada using a mechanism like CEPA.
Marcel Lussier Bloc Brossard—La Prairie, QC
Once again I am addressing my comments to Dr. Schwarcz.
Sir, your comments are extremely interesting, particularly when you talk about the connection and interaction among all these cancer-causing products.
Let's talk about products that attack the ozone layer, which leads to cancer. Given how these products interact, what should we be doing in order to try to find a solution to this international problem?