Respected chair and members of the Standing Committee on Environment and Sustainable Development, on behalf of the Allergy and Environmental Health Association of Quebec, I thank you for the opportunity to provide public comment on CEPA.
AEHAQ is a non-profit organization created to secure the facilities and services needed to enhance the lives of people suffering from environmental sensitivities. Since the enactment of CEPA in 1999, several reports on body burden testing for chemicals in the U.S. and Canada have revealed that humans carry an assortment of chemicals in their bodies. The synthetic chemical burden has been measured in all parts of the body, and some of them can linger for decades in body fat and be released during lactation, pregnancy, weight loss, and stress. While some chemicals are known to cause some diseases, complete information is not available on most of them and the synergistic effect of carrying this load is unknown. Also unknown is the effect that this will have on future generations.
The recent coverage of this widespread pollution of the population has been published in the October 2006 issue of National Geographic. This mounting crisis is being exposed and there's a real concern that, without its knowledge or permission, the public has been part of a chemical experiment in which no records have been kept.
Many chemicals are known to initiate or trigger chemical sensitivities, and this phenomenon is known to the pesticide industry. In a preliminary study, people who suffer from ES have been shown to have genes that are less able to detoxify medication and environmental chemicals, and therefore may be genetically more susceptible to adverse effect from exposure to relatively low levels of environmental chemicals.
ES is a chronic, multi-system disorder that can lead to disability. ES can occur when people become sensitive to substances or phenomena in their everyday environment at levels well below what would be considered to be acceptable to the general population. In part, sensitivity reactions can be triggered by scented and cleaning products, solvents, volatile compounds, petrochemicals, and so on.
According to the Nova Scotia Environmental Health Centre, sensitivity reactions can result in “a range of disorders marked by debilitating symptoms affecting multiple organ systems. Frequency and/or severity of these symptoms are made worse by subsequent exposures, even at very low doses to a wider range of chemicals and irritants”.
People suffering from ES often identify acute or chronic exposures to chemicals as initiating their condition. A recent survey by AEHAQ shows that a majority of the respondents identified chemical exposure as a cause of ES.
Due to an increasingly contaminated environment, the number of people with environmental sensitivity is steadily increasing. According to a study published in the peer-reviewed journal Environmental Health Perspectives, 12.6% of the population suffers from MCS. Of these, 13.7% or 1.8% of the population are affected severely enough to lose their jobs. EHP is the journal of the National Institute of Environmental Health Sciences, part of the U.S. Department of Health and Human Services. Extrapolated to Canada, around four million Canadians would suffer from environmental sensitivities and around half a million would be unable to work.
Their report in 2000 estimated that one in eight Canadian workers was significantly impaired or absent from work due to chemicals and mould in their workplace. Lost productivity cost the Canadian economy $10 billion a year. Misdiagnosis, ineffective and inappropriate treatment, and disability payments also cost Canadians billions of dollars a year. A million Canadians were underemployed and needed to renovate their homes in order to deal with sensitivities, half a million were unemployed, and thousands were homeless. Family breakup and suicide sometimes ensued.
The effect of environmental sensitivities can be overwhelming. Productive people can become unable to tolerate offices, homes, schools, hospitals, public places. Many lose their jobs. Some become homeless. All too often retirement savings are depleted and debts are incurred in an attempt to create safe living conditions and to fund the costs of treatment. Sadly, despite skills and education, many affected individuals eventually find themselves living on social assistance. Many become socially isolated as they are forced to retreat from places and activities they love.
However, individuals with sensitivities improve significantly once they find a safe toxin-free environment in which to live and work. According to a study headed by the Canada Mortgage and Housing Corporation, 86% of people with environmental sensitivities improve significantly after access to adequate housing. Some who had a bleak prognosis almost completely recovered.
Many studies demonstrate that the most effective management strategy for ES is avoidance of further chemical exposures. This means breathing clean air, drinking clean water, eating organic food, and using only non-toxic products for all aspects of living. Members of AEHAQ inform us that this is close to impossible to achieve in this chemical world. There is literally no place to hide.
Therefore, AEHAQ urges the committee to develop a strong and responsible CEPA, since it is pivotal in managing and avoiding the development of environmental sensitivities. AEHAQ does not have the resources to match its recommendations with each point in CEPA. A detailed list of recommendations is provided in the AEHAQ submission.
This is a summary of the recommendations:
To recognize and include ES sufferers as a vulnerable segment of the population.
The precautionary principle must be enshrined in every part of the act so that Canadians are protected from toxic exposures in the home, workplace, and community.
Only chemicals and pesticides proven to be safe for the most vulnerable segments of the population should be approved and allowed for use in Canada. All Canadians should have the health benefit of using only non-toxic products for everyday living. Industry must be given a maximum of one year to produce only non-toxic products.
Legislation coupled with education is necessary to inform the public regarding non-toxic products.
CEPA must set standards for ecological products, just as standards are set for organic farming and ecological pest control.
Industry must label all chemicals present in all products and the negative health effects in clear layman's terms that can be easily understood by the public, just as they are required to do when advertising medications. Labelling of products must be mandatory, and it must include the mention of sensitizers, carcinogens, mutagens, hormone disruptors and so on.
CEPA must include the ability to require random testing of products on the shelf. Mislabelling must result in heavy fines and immediate removal of the product from the shelves.
Proof of safety for chemicals must be carried out in a very short timeframe. The present timeframes for each stage in the process to establish safety of a chemical are far too long.
In terms of reversal of onus, the obligation to prove that manufactured products are completely safe for human health and the environment must rest squarely with the industry.
Testing must encompass all aspects of toxicity, and it must include the synergistic effect of mixtures in products.
The public must be informed when less toxic alternatives become available, and the toxic materials must be removed from the shelves immediately.
There must be immediate removal of toxic chemicals from the shelves as soon as a risk has been established. The public must immediately be informed so that products in the household or workplace may be disposed of appropriately.
Revenue generated from fines should be used to care for people who suffer from ES. This will include safe, chemical-free, adequate, low-cost housing; rehabilitation; financing for groups who care for ES sufferers; promotion of programs for health protection through avoidance of toxins; and subsidizing safe alternatives to toxic products.
There should be adequate air advisories: listing of the chemicals present inside buildings and commercial establishments.
The national advisory committee established by CEPA must have ENGOs as participants, especially those that represent vulnerable groups. Proceedings of this committee must be available to the public.
In terms of transparency, all data and records on chemical production, distribution, body burden, adverse health effects, and environmental degradation reporting must be made easily available to the public. Canadians have the right to know what is being used in their homes, workplaces, communities, and their environment. This will allow people to make a connection between exposure and ill health, and to report such effects to the Government.
Complaints about a product or chemical should result in immediate action towards removal and testing, in that order. Human health and the environment should always take precedence over corporate interests.
Canadians are becoming more acutely aware of the hazards of chemicals in their environment. They look forward to a strong CEPA geared only towards health protection.
AEHAQ urges the Standing Committee On Environment and Sustainable Development to mention in its CEPA report to Parliament that environmental sensitivities or multiple chemical sensitivities are an issue that is being raised by the public as a significantly increasing concern, that it affects and disables numerous Canadians through toxic chemical and environmental injury from unwanted and often hidden exposures, and that ES/MCS is one of many adverse effects on Canadians resulting from chemical exposures and resultant injury.
Thank you. Merci.