Evidence of meeting #23 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 children.

A recording is available from Parliament.

On the agenda

MPs speaking

Also speaking

Michel Gaudet  Allergy and Environmental Health Association of Quebec
Kathleen Cooper  Researcher, Canadian Environmental Law Association
Inka Milewski  Science Adviser, Conservation Council of New Brunswick Inc.
Donald Spady  Principal Investigator, Department of Pediatrics, University of Alberta
Daniel Krewski  Professor and Director, McLaughlin Centre for Population Health Risk Assessment, Institute of Population Health, University of Ottawa
Michelle Turner  Epidemiologist / Research Coordinator, McLaughlin Centre for Population Health Risk Assessment, Institute of Population Health, University of Ottawa
Michael G. Tyshenko  Risk Analyst, McLaughlin Centre for Population Health Risk Assessment, Institute of Population Health, University of Ottawa
Roger Keefe  Imperial Oil Limited
Aaron Freeman  Director, Policy, Environmental Defence Canada
Paul Glover  Director General, Safe Environments Programme, Department of Health
Cynthia Wright  Associate Assistant Deputy Minister, Environmental Stewardship Branch, Department of the Environment

3:30 p.m.


The Chair Conservative Bob Mills

I call the committee to order.

First of all, I'd like to welcome our guests, our panel today. I realize you were notified on rather short notice, so thank you so much for being here.

Again, thank you to the health and environment departments for being here. Feel free to jump in where necessary. I know our people here will involve you.

I believe we'll follow the order of witnesses as they're found on the agenda. I would ask you to try to keep your comments to ten minutes. Then we'll go through the first round, which will involve our members having a ten-minute intervention, and the second round would be a five-minute intervention. I would ask you to keep your answers as brief as possible so that the maximum number of people can ask questions.

We'll begin with Mr. Michel Gaudet.

3:30 p.m.

Michel Gaudet Allergy and Environmental Health Association of Quebec

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.

3:40 p.m.


The Chair Conservative Bob Mills

Thank you very much.

I believe the next person is Kathleen Cooper.

3:40 p.m.

Kathleen Cooper Researcher, Canadian Environmental Law Association

Good afternoon. My name is Kathleen Cooper and I'm senior researcher with the Canadian Environmental Law Association. I'm also chair of the coordinating committee and the policy committee of the Canadian Partnership for Children's Health and Environment, which is a partnership of public health, environmental, and child-focused organizations established to address the special vulnerability of children to toxic substances. You can see the member organizations of the partnership on the back of the brochure I distributed.

I'm going to run through some overheads drawn from the document called Child Health and The Environment—A Primer. I've provided some copies of it today, and if there aren't enough I can provide more. This document is intended to help the media, the public, service providers, and policy-makers such as you in your understanding of what is a very large and complex topic. It's further summarized in the brochure, which is focused on what parents can do to avoid key exposure risks.

We've prepared these materials for several reasons. First, among the groups and the partnership we needed to improve our understanding of a very large field to decide which concerns are greatest and where we should focus our attention. Second, we saw a need to raise public awareness about what can often be hidden exposures to toxic substances. Third, we saw a corresponding need for greater public awareness to enable public participation in discussions like these today about policy changes that are necessary to address these risks.

Our partnership is in year two of a multi-year campaign to raise this awareness, with 10,000 copies of the primer in print and over 200,000 brochures distributed across Canada. These bilingual resources are also available online. We expect their popularity will continue as awareness about these issues continues to increase.

I will discuss some key points about our findings and our work and conclude with some policy recommendations from the partnership, adding more detail from the perspective of further work within my own organization. I thank the technicians once again for letting me set this up on very short notice.

One of the key concepts about risks to children is their greater vulnerability, especially in the womb. This is a notion of windows of vulnerability. You'll be familiar with the old saying that the dose makes the poison. While this is often true, children's environmental health adds the element of timing. For example, an exposure to organic solvents, lead, or mercury that would not harm an adult can create very serious consequences during sensitive stages of fetal development. Throughout pregnancy, all the major systems of the body are developing. The placenta does not block the entry of most toxic substances. The fetus will share the mother's body burden of chemicals. Many of the organs and systems of the body are still immature at birth and continue to develop during infancy.

In fact, development in some systems continues for many years. The lungs and brain continue to develop until the end of adolescence. The years just before and during puberty are times of vulnerability in the reproductive system. Evidence points to chemical exposures both in the womb and during early puberty that may contribute to breast cancer later in life. As this illustration shows, it is important to remember that at all times across the human population a window of vulnerability is always open.

As I mentioned, one purpose of our research over the last six years was to write educational materials from a better understanding of this very large topic. The scale and seriousness of this topic can be alarming and we don't want to unnecessarily scare people. We ask ourselves which health impacts and which exposures matter the most, what can individuals do in response, and what are the necessary policy responses?

One way to set these priorities is to focus on health impacts where large numbers of children are affected. This overhead summarizes the health concerns and body systems or developmental processes of concern. You will already be aware of the concerns of asthma and other respiratory impacts. 12% of children in Canada have physician-diagnosed asthma. That's a fourfold increase from the early 1980s. Links to air pollution as a contributing factor are well established.

Impacts on brain development are of particular concern. We know that about 25% of Canadian children have one or more learning or behavioural problems. More research is needed to know whether or how much environmental contaminants contribute to these large numbers. We do know that children are routinely exposed to low levels of chemicals that are suspected of being toxic to the developing brain. We have to ask ourselves, what kinds of chances are we taking here?

Cancer is another area of significant concern. Fortunately, cancer in children is very rare, but it is the leading cause of illness-related death in children over the age of one. However, in young adults in Canada--that's age 20 to 44--several cancers are rising rapidly, often at sites in the endocrine system. And of course we continue to experience an epidemic of breast cancer, also an endocrine site. The sensitivity of early life stages to chemical exposures are probably involved in the onset of these cancers in young adults.

Reproductive and developmental impacts are associated directly with some contaminants or may be mediated through impacts on the endocrine system. There are concerns about impacts on the immune system. And finally, there are contaminants of concern associated with multiple health effects, such as lead, mercury, phthalates, PBDEs, some pesticides, etc. Those are the ones of greatest concern and needing our most urgent attention. It's important to recognize that for any of these health end points or for good health in general, many factors are at work, often described as the determinants of health. Environmental factors are one of the determinants of health.

Our knowledge is strongest for respiratory impacts. For the other health effects, clear associations can be drawn for only a small number of substances. However, we know hundreds, in fact thousands, of contaminants are suspected in some or several of the health impacts of concern in children, but we don't have complete information. What we do know, and continue to find out, is deeply troubling.

So which exposures matter most? That's another question we had for ourselves. This illustration shows the many ways that the fetus and child are exposed to environmental contaminants. Another aspect of the greater vulnerability of children is that we know they are more highly exposed than adults. For the health impacts of concern for children, we concluded that exposures of most concern are in both outdoor and indoor air, in food, and in consumer products. There's a lot of overlap in consumer products, because exposures in indoor air and in food can often originate from chemicals in consumer products. Indoor dust also appears to be a significant pathway, again often originating from toxic substances that are inadequately or completely unregulated in consumer products.

To illustrate some of these points, I want to talk about an example that you may be familiar with. This graph illustrates trend lines of chemicals in breast milk in Sweden since the 1970s. There are three points I'd like to make about this graph.

Sweden has conducted national bio-monitoring of breast milk since the 1970s--we should too--along with other bio-monitoring of chemicals in blood and urine. Statistics Canada plans to start a study in a few months. It should be an ongoing biannual review, not a single-year study, to be able to look at exactly these kinds of trend lines. The second thing you can see in this illustration is the impact of regulation. The levels of PCBs and the metabolite of DDT dropped in the 1970s following the decision to discontinue and ban their use. And you can see the trend line for PBDEs, the brominated flame retardants. Once use started to increase in the early 1980s, so did the contaminant levels in breast milk. These breast milk data informed the regulatory process. When they saw how fast these levels were rising, they swiftly banned two of the most widely used commercial mixtures of PBDEs, and following that ban, the breast milk levels began to drop. You can see the drop in the late 1990s. The final thing to notice in this graph is that 30 years later, even though levels continue to drop, DDT and PCBs are still contaminating breast milk. Like PBDEs, they are persistent as well as highly toxic, and that is why they had to be banned.

In Canada now, 10 years after Sweden took this regulatory action on PBDEs, we have PBDE levels in breast milk that are five to ten times higher than we're seeing in Sweden following this regulatory action. The Canadian state of the science report on PBDEs is now two years old and it's based on out-of-date science. The risk management strategy proposed under CEPA for these chemicals, and currently the subject of consultation, will have us talk about this problem in this country for another two years at least. Then we will consult further on passing regulations to ban PBDE mixtures that were already discontinued two years ago by major U.S.-based manufacturers. Right now, Sweden and other progressive European countries are seeking to ban the rest of the problem. They want to ban the deck of PBDEs that are still in production. But in Canada, in our risk management strategy we are not going to address what is essentially the remaining lion's share of the problem.

It's frustrating to read a document like this, because it simply enshrines the status quo. It sets a minimal or ineffective target that can easily be met already, and the rest of the problem remains unaddressed. In your actions to revise CEPA, you need to do something about this recurring problem with the way we regulate chemicals in Canada, and I can point to other examples in discussion.

I should close off with the policy recommendations, so what I've summarized on these slides are the recommendations that we agreed to within the partnership.

The first one has to do with the progressive reduction and elimination of child poverty. Again, this is about large numbers of children. One in five children in Canada lives in poverty, another one of the determinants of health. It's well established that poverty can contribute to significantly greater exposure to environmental contaminants, so the elimination of child poverty will improve their exposure situation.

The second and third recommendations have to do with calls for research. First, we need more research and related policy action to promote safer, non-toxic alternatives to toxic chemicals and pesticides. And it's important that you support other calls for significant increases in Canadian research and monitoring within--a couple of examples are noted here--bio-monitoring and a Canadian longitudinal study similar to the U.S. national children's study.

The final four recommendations have to do with changes in CEPA and associated policy for its implementation. These are general statements about increasing the focus on toxic and smog-forming air pollution and addressing the gap in the regulation of toxic substances and consumer products. We are also calling for mandatory, not discretionary evaluation of all potentially hazardous substances for their impacts on the developing brain.

All of these recommendations, and particularly the final one, I hope can be a part of further discussion with you today. Most of them are elaborated upon in detail in our submission to this committee from June 2006.

To conclude, I would like to point out that in Canada we have just been through--which I'm sure you are aware--a multi-year effort to revise the Pest Control Products Act. In your deliberations about CEPA, I urge you to incorporate into CEPA at least the same level of protection for children that we have now in Pest Control Products Act. That law now includes several specific requirements for considering children's health, and it also includes an important aspect of putting the precautionary principle into practice in that it specifically incorporates the principle of reverse onus: where a company seeks to register a pesticide, they must first demonstrate that their products will not cause harm prior to obtaining a registration to use a pesticide in Canada.

That's probably at least 10 minutes, and I should stop there. Thank you very much for your time.

3:50 p.m.


The Chair Conservative Bob Mills

Thank you very much. Actually, you were at 13 minutes and 14 seconds.

I would ask you to try to keep it to 10 minutes so that we can stay on schedule and get the maximum number of questions.

Our next speaker is Inka Milewski from the Conservation Council of New Brunswick.

3:50 p.m.

Inka Milewski Science Adviser, Conservation Council of New Brunswick Inc.

Thank you, Mr. Chairman.

My name is Inka Milewski and I'm the science adviser for the Conservation Council of New Brunswick, one of the three oldest environmental groups in Canada. We are a membership-based organization.

With respect to the topic today, vulnerable ecosystems and vulnerable populations, the Conservation Council believes there are two blind spots in CEPA. One is the lack of regulations for nutrient discharges to coastal waters, and the other is the lack of nationally binding standards on contaminants in soil, sediment, and water for populations living in the footprint of industrial activity.

I'm going to address each of these separately. In the first instance, that of coastal ecosystems and the need for regulations of nutrient releases, the Conservation Council has been preparing briefs on this matter for standing committees on the environment for almost 10 years, so once again I'm going to bring it up in the hope that we might get some action.

Since 1990, world experts on marine pollution have declared nutrients, specifically nitrogen compounds, the most damaging class of pollutants to the marine environment. There is no scientific dispute about the harmful effects of excessive nutrient loading on coastal waters. Unchecked release of nutrients from municipal sewage plants, pulp and paper mills, fish plants, marine aquaculture operations and intensive livestock operations can trigger a series of ecological responses that ultimately result in oxygen-starved dead zones, causing massive fish kills and the transformation of complex and diverse coastal habitats into barren seascapes dominated by a few species. In 2001 a report on the state of the world's oceans by UNEP, the United Nations Environment Programme, identified 50 dead zones worldwide. In 2004 the number went up to 150 and in 2006 that number, as just reported last week, is up to 200; there are 200 dead zones in coastal waters around the world.

Our marine waters are not immune from this phenomenon. In P.E.I. episodes of oxygen starvation and subsequent fish kills due to nutrient loading from agricultural runoff are reported annually at 18 to 20 sites around the province. In New Brunswick a study in 2002 by researchers from Dalhousie University and the Conservation Council of New Brunswick found that of ten estuaries we studied in northern and eastern New Brunswick, seven exhibited moderate to severe symptoms of excessive nutrient loading. Many coastal areas in the Quoddy region on the Bay of Fundy also show symptoms of nutrient loading, especially in the vicinity of point sources such as aquaculture operations.

Currently CEPA is silent on the problem of nutrient releases to the marine environment. Based on our analysis—which we sent in 2004 and 2006, and which you should also have in May—CEPA is the appropriate vehicle to regulate nutrients. Amendments can be made to the nutrient section—part 7, division 1, sections 116 to 199—to accommodate nitrogen compounds such as ammonia, nitrates and nitrites. Ammonia is currently on CEPA's priority substance list, and its release from various point sources represents a significant portion of the nitrogen or nutrients loaded into coastal ecosystems.

The amendment to part 7 would extend the current powers of the Governor in Council to include nutrients other than phosphates. Phosphates are nutrients that are limiting in freshwater systems, but in marine systems it is the nitrogen compounds. Limits could be placed on the concentration of nitrogen and effluent in emissions, or the minister could establish total maximum daily load requirements for a water body, as is done in the United States, and the provinces could be directed to allocate them by individual user.

The Government of Canada must act quickly to control nutrient releases to coastal waters, where 75% of all commercial species live. The report released last week in the journal Science predicting the total collapse of the commercial food fishery by the year 2048 if nothing is done to control overfishing, habitat destruction and pollution—specifically nutrient loading—should be all the evidence the government needs to begin controlling nutrient releases.

On the second issue, that of protecting vulnerable populations within the footprint of industry, in our view vulnerable populations are those people living in the shadow or footprint of industrial operations, such as metal smelters, petrochemical refineries, coal-fired power plants, waste incinerators and so on. People living closest to pollution sources are known to be at higher risk of exposure than those living some distance away. Many of the pollutants released, such as metals, persist and accumulate in soil, then bioaccumulate, or bio-magnify, within plants and animals that are subsequently consumed by people living in the area.

While CEPA does set emissions standards on a range of pollutants, it does not address the ongoing accumulation of these pollutants in the environment. That aspect of environmental protection is thought to be covered by other agencies such as Health Canada and the Canadian Food Inspection Agency. Health Canada and the Canadian Food Inspection Agency have developed some guidelines, not regulations, for safe levels of some contaminants in some food products. The Canadian Council of Ministers of the Environment, the CCME, has established non-enforceable, voluntary guidelines for pollutants in soils, sediments, and water. These are applied at the discretion of the provinces.

Enforceable limits on pollutants in soil, sediment, and water are needed to protect people living in close proximity to industrial activity. They are more vulnerable than people living further away. The example of Belledune, New Brunswick, illustrates this point. I think I sent earlier a copy of this report, Dying for Development - the Legacy of Lead in Belledune, some time in August, and the French translation is now available.

In 2003, after almost 40 years of living in the shadow of a lead smelter, residents had their properties tested for the first time. They found their yards and their gardens had lead, cadmium, zinc, thallium, and arsenic levels that were above agricultural and residential soil quality guidelines set by CCME. In 2005, after the province released the result of the health study that was done in Belledune, residents learned that they had the highest disease, cancer, and mortality rates of any area in the province. They also found out that some of the berries, garden produce, and seafood they had been consuming for years had high levels of lead and cadmium.

Instead of ordering a community-wide cleanup of the contaminated properties, the province ordered a risk assessment, which really amounted to a risk assessment on a risk assessment. Despite the fact that the CCME guidelines have been established on a health risk basis, the province asked the consultants to do another risk assessment. The study concluded that the soil and garden produce were not significant pathways of exposure, although the seafood was. At the same time, in a separate study, children living in two neighbourhoods closest to the smelter were found to have blood lead levels two and a half times higher than children living further away. Incidentally, the soil where those children lived had two to four times higher levels of lead than the soil of children living further away.

As for the high metal levels in some of the garden produce, the province said that Health Canada, and I'm quoting, does not have “maximum residue guidelines for lead in food products”. Some berries and produce tested in the Belledune area had lead levels up to four times higher than Health Canada's maximum residue guideline for whole canned tomatoes, but the province said, you can't use this value to make any comparisons or say anything about the lead levels in those berries.

As the example of Belledune demonstrates, the emission and discharge limits placed on pollutants from industrial sources under CEPA are not sufficient to prevent pollutants from accumulating in the environment and having an impact on vulnerable populations. People living close to a pollution source need more protection than simple end-of-pipe or end-of-stack emission limits and voluntary CCME soil quality guidelines. The Government of Canada needs to step in and set nationally binding standards under CEPA for contaminants that accumulate and persist in soil, sediment, and water as a result of industrial activity.

Thank you.

4 p.m.


The Chair Conservative Bob Mills

Thank you very much.

Our next presenter will be from the University of Alberta, Donald Spady, please.

4 p.m.

Donald Spady Principal Investigator, Department of Pediatrics, University of Alberta

Mr. Chairman and the committee, I'm Donald Spady, I'm a pediatrician from the University of Alberta. I want to thank the committee for the opportunity to present some information with respect to children's health legislation and the environment.

I am here because in September 2004 I was given the mandate by Health Canada to do a survey of governance instruments, or laws, regulations, and guidelines that related to children's environmental health legislation in OECD countries, but not including Canada.

Children are often considered only peripherally in the development of legislation; however, for the creation of new legislation in Canada, Health Canada decided to explore what legislation exists in OECD countries relating to environmental health in children. Today I want to address some issues that have arisen out of our research and hope that they will be helpful in the development of the final product.

Now, apart from the fact that children are Canada's future and that events in environment and childhood affect future health and productivity, you might wonder why children are so special in the creation of environmental health legislation. Kathy Cooper eloquently described the vulnerabilities of children, and I'm going to save the committee three minutes and 13 seconds by not saying the same thing.

I will not go into detail of how we did our survey, nor will I present much in the way of specific findings. Details of what we did and what we found are in the submission to this committee that was provided earlier this year. Suffice it to say we found very few governance instruments that specifically considered children in their genesis or implementation.

I want to spend the remaining time on several more general findings and actions that we think should take place. One problem with environmental legislation is that there are a tremendous number of chemicals in the environment, over 100,000, that can potentially affect any of us. I say “potentially” because for the most part these chemicals have not been assessed for safety to any significant degree. Many of these compounds are in our bodies in minuscule amounts, but for the most part we do not know what particular blood level of a compound is dangerous to humans, nor do we know how combinations of these compounds can affect our health--we are in the dark. Yet, the attitude toward society of the manufacturers of these compounds is that they are safe until proven dangerous.

In an ideal world, these compounds should all have been assessed for safety prior to their use in industry or wherever. Practically speaking, this is not the case. Very few of these compounds have been assessed for safety to any suitable degree. This attitude in part is due to the very high cost of assessing the safety of many compounds and in part to the lax regulation regarding their introduction and use.

One of our recommendations is that there should be a change in regulatory philosophy such that any new compounds must be shown to be safe before they are allowed on the market. This is the proposed approach being taken in Europe under the new REACH proposal, which reflects the registration, evaluation, and authorization of chemicals and requires that all compounds must be shown to be safe before they are licensed for use. There is some leeway in this in that initially compounds to be tested are those produced above a certain volume; however, some other compounds sold at even very small volumes that are felt to be particularly at risk of being dangerous must have their safety demonstrated before release.

This proposal is due to come online in 2007 and will apply not only to Europe but to any manufacturers who want to sell their products in Europe. Since this will ultimately include Canadian and American manufacturers, it might be a reasonable proposal that Canadian legislation also take the general attitude of guilty until proven innocent rather than the current attitude of innocent until proven guilty. Such an approach may act to help industry assess the safety of various compounds by spreading the task of assessment over a larger field of partners, thus cutting the costs. This, however, might require an unrealistic level of cooperation between various industry players.

The second general finding is that as a general rule proposed legislation should incorporate the precautionary principle in its regulation. The precautionary principle states that when an activity raises threats of harm to human health or the environment, precautionary measures should be taken, even if some cause-and-effect relationships are not fully established scientifically. This principle is often viewed by industry as a way of preventing the introduction of new substances. This is not the case. It is only advocating a cautious approach when dealing with a potentially dangerous situation. In fact, the precautionary principle should promote research into the safety of new compounds rather than being considered a mechanism to unnecessarily slow down the introduction of these compounds.

Very little of the legislation we found specifically incorporated the precautionary principle, and what legislation we found was largely from the European Union.

The third message, and perhaps the most important one I want to make, is basically one of placing the needs of children first. They are the most vulnerable Canadians, and they are our future. We recommend that a mandate be created that all governance initiatives consider the potential impacts on children's environmental health, for all legislative, development, and planning activities where children might be affected.

This could be implemented, in part, by the creation of a national level advisory board to monitor these governance instruments. This is similar to executive order 13045 from 1997 that was signed by President Clinton. It was one of the very few governance instruments we found that specifically addressed the unique characteristics of the child.

As part of this, we recommend that there be an annual or biannual report of the most important environmental indicators of the well-being of Canada's children, with each report highlighting a specific issue. Such a report would give children a higher profile within government and within society. It would act as an impetus to improve children's health.

As well, we recommend the creation of an advisory body at the national level that is modelled after the American President's Task Force on Environmental Health Risks and Safety Risks to Children, created by executive order 13045, which would demonstrate the high priority the Government of Canada places on children's well-being. Such a body would also serve as a vehicle for assessing legislative and other governmental impacts on children's environmental health, and it could extend to public education initiatives.

There are several advantages to these recommendations. I think perhaps the most important one is that since children, including the fetus, are often the most vulnerable humans, legislation designed to minimize exposure to potential and actual noxious environmental agents in childhood, for the most part, will meet the safety needs of adults. Another reason is that there would be a need to investigate what various safe levels are for children. There would be a fair bit of research stimulated to address this issue. Also, legislators would become more aware of the importance of children and the factors that can influence their health when creating legislation.

I'll stop now. I have reviewed three important aspects of our research: the need to revise how we assess both old and new compounds for safety, the advocacy of the precautionary principle as a guideline for legislation, and the concept of placing children first when considering legislation.

I want to thank the committee for allowing me to present some of our findings. Thank you.

4:10 p.m.


The Chair Conservative Bob Mills

Thank you very much.

Now, from the University of Ottawa, Daniel Krewski.

I understand you have a couple of colleagues who will also be coming. You might introduce them as they enter in on this.

4:10 p.m.

Prof. Daniel Krewski Professor and Director, McLaughlin Centre for Population Health Risk Assessment, Institute of Population Health, University of Ottawa

Thank you, Mr. Chairman.

My name is Dan Krewski. I'm the scientific director of the McLaughlin Centre for Population Health Risk Assessment at the University of Ottawa, which is also a World Health Organization collaborating centre in population health risk assessment.

I want to thank the committee for the opportunity to participate in today's meeting.

We'd like to describe some work we've done in the area of health policy approaches to children's environmental health that was sponsored by the federal government, Health Canada in particular. Under this project, we were asked to look at international evidence on how children's environmental health issues are addressed elsewhere and how learnings from that research could possibly inform the updating of the Canadian Environmental Protection Act.

Our research approach was to identify specific governance instruments and evaluate how effective they were in other jurisdictions, looking at barriers and facilitators involved in their implementation. We used two approaches: expert interviews, case studies, as well as a detailed review of the available evidence. We focused on a series of topics that ran through the entire analysis: lead, mercury, pesticides, endocrine disruption, and both indoor and outdoor air pollutants.

The work we did was conducted within the framework we developed for population health risk assessment, which focuses on the broad determinants of health that Kathleen Cooper talked about earlier. We were interested in genetic, environmental, social behaviour, and lifestyle determinants of health. Having identified risks to health, we looked at a variety of regulatory, economic, advisory, community-based, technological, and other options for risk management.

I'll ask Michelle Turner to talk a bit about some of the substantive issues in our report and then Mike Tyshenko to follow up with some work on risk perception and bibliometry.

4:10 p.m.

Michelle Turner Epidemiologist / Research Coordinator, McLaughlin Centre for Population Health Risk Assessment, Institute of Population Health, University of Ottawa

Children's environmental health issues can range from those for which the weight of the evidence is substantive to many more for which the scientific basis for an association is incomplete. For example, much evidence points to a relationship between second-hand tobacco smoke and pre-term birth, asthma incidents and severity, sudden infant death syndrome, and lung and middle ear infections. Cognitive deficits have also been associated with high-level prenatal maternal methyl mercury, PCBs, ionizing radiation exposure, and childhood lead exposure. There are numerous examples of diseases where environmental links are suspected. There are also many emerging children's environmental health issues, including endocrine disruptors, pesticides, chlorination disinfection by product solvents, etc.

Researchers are only beginning to describe the nature of the association between many environmental hazards and health outcomes, as well as their interactions with other health determinants.

We also know the potential social and economic costs can be very high. One study in the U.S. found the annual costs associated with the environmental component of childhood lead poisoning, asthma, cancer, and neuro-behavioural disorders were estimated at $55 billion a year in the U.S.

A high climate of concern also exists over children's environmental health disorders, and I'll touch on this a little later.

If we think about children's health issues from a risk perspective, we want to think about the probability of the occurrence and the nature of the consequences. The probability of the occurrence is influenced by such factors as the nature, level, and timing of exposure, as well as factors influencing susceptibility. Consequences due to early life exposure, along with the development of body systems, may lead to serious, permanent, and long-lasting effects and even death.

The nature of children's environmental exposure is very broad. A number of exposures must be considered.

An exposure that was talked about earlier was breast milk and in utero exposures that are specific to the developing child. We know breast milk is a particularly unique exposure for children and has been found to contain pesticides and plasticizers, among other chemicals.

We must also consider workplace exposures, as parents often bring home these exposures to the child at home. Children have greater contact with their physical environment through crawling and hand-to-mouth contact. These unique differences greatly increase the amount of environmental exposure received.

The increased susceptibility of children due to immature systems is also great. We must consider the critical periods of development for various structures. For example, the lung and reproductive systems are two systems that have been highlighted in the literature. For the reproductive system, as an example, there are many critical exposure time windows during the fetal period, as well as after birth and into adolescence. The child may experience much greater levels of environmental exposure. For example, the respiratory ventilation rate of an infant is approximately 133 millilitres per kilogram per body weight, while that of an adult is only two.

Another example is drinking water. Infants consume nearly double the amount of drinking water per kilogram per day compared to an adult. Similar examples can be found for fruit consumption and soil ingestion.

Another important consideration is the possibility that some groups of children may be more highly susceptible to environmental exposures than average. One example we can think of is possibly the aboriginal population. The aboriginals in the Canadian Arctic have undergone much study through the northern contaminants program. They represent a population in which much greater levels of environmental exposures are found. For example, levels of maternal blood mercury in the Inuit population are much greater compared to other aboriginal groups in the north or Caucasians living in the north, as well as people living further south in Canada.

Last, if we think about the consequences, there are many examples we can think of. One example is lead exposure. In the U.S. the economic losses associated with a decrease in lifetime earnings due to blood level exposure has been estimated at over $27.8 billion for boys and over $15.6 billion for girls annually.

The last point I'm going to make is risk perception. Risk perception is an important component of risk management decision-making.

Through a national survey we conducted, we know that Canadians have a high level of environmental concern. We also know that risk issues associated with certain populations, including children, tend to be perceived as higher. Many of the children's environmental health issues have delayed effects, are newer to science, and have received much mass media attention. All these factors, including many others, tend to increase the levels of risk perceived by the public.

4:15 p.m.

Michael G. Tyshenko Risk Analyst, McLaughlin Centre for Population Health Risk Assessment, Institute of Population Health, University of Ottawa

In our study of children's environmental health, we were interested in the public perception of different risk issues pertaining to children. We looked at 17 different news dailies from all across Canada from 1985 until present. We actually did a bibliography searching for over 80 different risk issues and combined them with the key words: “children”, “environment”, and “health”. We were able to rank these 80 different risk issues from the highest number of articles and the highest frequency of these words appearing in the news media. These were newspaper articles that would raise awareness among the general public or point to issues the public may be worried about.

Of course, following on the heels of the Walkerton water tragedy, contamination of drinking water, bacteria and chemicals in water, was number one. Interestingly, numbers two through eight were all the various facets of chemical contamination: lead and lead poising, pesticides in food, and pollution as a general concept. But mostly they were chemicals, pesticides, and mercury in fish. Numbers nine and ten were smoking and tobacco smoke, which have strong chemical components.

We were also interested to see whether there was a linkage in the public's mind between the risk issues we had ranked and legislation or regulation. We added those words onto our search. Interestingly, we saw almost a complete drop-off. There are very few articles that mentioned children's environmental health, a risk issue, and legislation. This leads us to believe that in the public's mind, the news media provides them with a lot of information, but there's not this linkage between the need to do something with regulation and children's environmental health.

In our study, we also conducted a series of expert interviews. We looked at three jurisdictions: Canada, the United States, and member countries of the European Union. We conducted these open-ended interviews, which lasted up to an hour, where we asked them a series of questions to identify barriers, facilitators, and other approaches they use in their jurisdictions to protect children's environmental health.

Regardless of jurisdiction, the experts had common opinions. I'm going to read the top three to you. All of the experts agreed that there were huge areas of uncertainty, and there was simply no information for many chemicals and many chemical environment hazards in relation to children's environmental health.

Secondly, the experts pointed to a lack of research funding, a lack of political will to invest moneys into research, bio-monitoring , database management, and program building. In all the jurisdictions we looked at, experts believed that in order to quantify the scope of the problem and to better understand environmental health outcomes linked to the exposure levels of different chemicals, bio-monitoring is needed. There needs to be a mechanism for sharing this information among different jurisdictions in the country.

The one closed question we did ask in our survey was, does legislation adequately protect children in your jurisdiction? Regardless of whether they were in Canada, the United States, or the EU, about 50% of the respondents indicated that, no, legislation does not protect children's environmental health, and a better job could be done.

4:20 p.m.


The Chair Conservative Bob Mills

Thank you very much.

We'll now go to our final speaker, or did you want to finish? You're at 12 minutes and 17 seconds.

4:20 p.m.

Professor and Director, McLaughlin Centre for Population Health Risk Assessment, Institute of Population Health, University of Ottawa

Prof. Daniel Krewski

May I have 42 seconds, Mr. Chairman, just to read our four bottom-line recommendations?

4:25 p.m.


The Chair Conservative Bob Mills

Okay, go for it.

4:25 p.m.

Professor and Director, McLaughlin Centre for Population Health Risk Assessment, Institute of Population Health, University of Ottawa

Prof. Daniel Krewski

We have a large report with a lot of detail, but the four most important points, which we're suggesting action be taken on, are as follows.

Number one is an amendment to the preamble to CEPA that includes provision for consideration of children's environmental health. We've suggested a specific wording: “...including the distinctive risks faced by children and other vulnerable populations”.

Numbers two and three focus on maintaining and enhancing the capacity of Health Canada and other government departments to address children's environmental health issues.

Our fourth recommendation is to ensure ongoing stable funding for research to characterize children's environmental health issues as fully as possible. A national bio-monitoring program, as has been mentioned by all of the previous speakers, and a broad-based research program would, we think, be critical to ensuring the future of children's environmental health.

Thank you.

4:25 p.m.


The Chair Conservative Bob Mills

Thank you very much.

We'll go now to Imperial Oil, and Mr. Roger Keefe.

4:25 p.m.

Dr. Roger Keefe Imperial Oil Limited

Good afternoon. I'm Dr. Roger Keefe of Imperial Oil. I was asked to speak to you on today's topic by the Canadian Chemical Producers Association. I also work closely with the industry coordinating group for CEPA; they have also previously appeared before you.

My views are technical in nature. They're based on about 30 years of experience since I completed my PhD and somewhat less since I got board certification in toxicology. Most of those years were in industry, dealing with safety testing and risk assessment. My career has focused on mammalian toxicology and human health risk assessment, and that's going to be the focus of most of what I say.

My remarks are really in support of just two basic propositions. One is that the susceptible subpopulations in ecosystems are already considered in risk management decisions made under CEPA when there is scientific evidence. Number two is that while consideration of susceptible subpopulations in ecosystems is implicit, there may be good reason for not making it more explicit in CEPA. I'll elaborate on those two.

On the first, that consideration is already given to susceptible subpopulations, it is clearly demonstrated in the existing CEPA risk assessments. For example, under the priority substances list program, human exposures during different life stages are estimated, and risk assessment conclusions were based on the most-exposed life stage, whether it was infants, children, adults, or the elderly.

Although less common, if there was a known difference in susceptibility owing to gender or race or any other factor, the guidance value or exposure limit that comes out of the risk assessment would be based on the most vulnerable group. This is standard procedure in toxicology when there is documented sensitivity for a substance.

There are other procedures at Environment Canada and Health Canada that should give us assurance that sensitive subpopulations in ecosystems are being considered. I just have four bullets here. First is their participation in international assessments and tool developments such as the World Health Organization, mentioned earlier, or the Organisation for Economic Co-operation and Development. Most substances, after all, are not unique to Canada in today's global market.

The second is the use of outside academic experts for advice and peer review of assessments. I think that keeps the departments at the cutting edge of science in doing a good job and in being aware of any evidence on susceptibility.

Third is the use of staff with skills and experience to conduct risk assessments--people who in academia are referred to as high-quality personnel.

Fourth is the maintenance of the capacity to conduct and publish peer-reviewed research.

It should not surprise you, given my background, that these four points are in recognition and support of a high-quality scientific risk assessment process in general. When that process is well informed and well executed, the current risk assessment process takes into account sensitive subpopulations in ecosystems.

My second proposition--that it may be better to leave consideration of susceptible subpopulations in ecosystems implicit in CEPA--stems from the need for professional judgment to deal with a lack of the necessary scientific information. Absent data on vulnerability, it would be better to use professional judgment on a substance-by-substance basis to choose between precaution and more research.

If vulnerable subgroups are explicitly considered in the act, it will likely lead to greater precaution, because data are often lacking. I would prefer to fill data gaps to reduce the uncertainty in the decision-making process rather than build into the act an allowance for greater uncertainty with unknown risk benefits. We need decisions that are based on better knowledge.

A concern I have about a broad increase in the use of precaution is that decisions may not be reviewed, at least for a long time, in light of new data. A principle in the Government of Canada's paper on the use of precaution in decision-making is a reconsideration of precautionary measures. If more decisions are going to be precautionary in nature, then we will need to reinforce this principle and ensure that substance risk assessments are reopened as new data become available.

Professional judgment by the government side will continue to be aided by the ongoing research on susceptible subpopulations in ecosystems. Currently there are a wide variety of genetically modified knock-out mice, for instance, that could be used as models of the heterogeneity in the human population. Gene arrays containing dozens or even hundreds of genes are also being used to study how genes are up-regulated or down-regulated in response to substances. Developing research on epigenetics and the use of bio-monitoring in risk assessment will also affect the way we assess susceptible subpopulations. These are very active areas of research now, and we need to have the flexibility to incorporate new results or tests into our risk-based approach.

Finally, what tests and how much testing there ought to be should depend on how a substance will be used and who may be exposed. So it should be decided on a substance-by-substance basis; it's impractical to test all species or potentially exposed subgroups. Increased testing, or costs, could be a barrier to use of a substance in Canada or may limit its uses here since Canada is such a small market. Those potential economic losses, or the loss of other benefits of the substance, need to be balanced against the unknown reductions in risk. Other likely costs to consider are larger government departments to conduct or interpret test results, and a possible burden on industry as well.

In summary, if scientific information is available, I believe it is being used and will continue to be used to account for susceptible subpopulations in ecosystems. Where such information may not be available, I believe the exercise of professional judgment implicit in CEPA, given the range of powers already in the act, is adequate to account for susceptible subpopulations in ecosystems.

Thanks for inviting me to appear.

4:30 p.m.


The Chair Conservative Bob Mills

Thank you, Mr. Keefe.

Aaron Freeman, I understand you have a very brief intervention. If you could keep it to that, please, we could get to our members' questions.

4:30 p.m.

Aaron Freeman Director, Policy, Environmental Defence Canada

My name is Aaron Freeman. I'm the policy director with Environmental Defence Canada. I'd like to talk about the Great Lakes St. Lawrence Basin as one of Canada's most vulnerable ecosystems.

The basin is home to more than 30% of the Canadian population, and it generates about one-quarter of our GNP. It's the largest freshwater ecosystem in the world, and it's hard to overstate the seriousness of this basin as a toxic hot spot. Fifty-eight per cent of the industries that report to the National Pollutant Release Inventory are located within the Great Lakes/St. Lawrence Basin. Air, water, and land-based pollution releases are disproportionately high, with nearly half of all toxic air pollution being emitted within the basin. Canada is falling behind the United States in terms of cleaning up the basin. On a per facility basis, National Pollution Release Inventory facilities emitted on average 93% more air pollution than their U.S. counterparts. According to the Commission on Environmental Cooperation, between 1995 and 2002, Canadian facilities reported a decrease of just 2% in air pollution, versus U.S. facilities reporting a decrease of 45%.

For the first time, we're now seeing the United States moving forward in Great Lakes protection generally without Canadian participation. While Canada allocated $125 million over five years for Great Lakes protection in the 2005 budget, U.S. legislative commitments to restoration efforts leave Canada lagging far behind. These include the 2002 Great Lakes Legacy Act, which earmarked $270 million to cleaning up contaminated sediments; and the Great Lakes Regional Collaboration, which was established by a presidential executive order in 2004. It identified the Great Lakes as a national treasure and it brought together stakeholders from various levels to complete a comprehensive, integrated plan for improving the Great Lakes, and the plan was released in December 2005. The collaboration formed the backbone for two federal bills, each of which have garnered widespread congressional support. These bills would earmark between $10 billion and $20 billion for Great Lakes cleanup work, boosting research and monitoring, cleaning up contaminated sediment, and remediating the effects of invasive species.

There are serious effects of the United States, moving forward, with legislative commitments without Canada, and I can go into some of those impacts in the Q and A. The Great Lakes Water Quality Agreement is currently being reviewed. This agreement has been a model for international cooperation, but we need to bring the agreement up to date. One of the things we're proposing is for CEPA to be the implementing mechanism for this agreement.

Finally, it's worth noting that all four major political parties pledged in their last election platforms to implement restoration efforts in the basin.

What we propose is a new section of CEPA to protect significant geographic areas that are vulnerable to pollution. My submission goes into greater detail as to how this would work within CEPA, but first it would grant the Minister of the Environment the power to designate a geographic area “significant” if that area is especially vulnerable to pollution, or if high levels of toxic substances are used or generated in that area. Second, we would propose designating the Great Lakes/St. Lawrence Basin as the first such area, establishing pollution prevention goals, including overall five-year and ten-year pollution prevention targets, elimination goals for carcinogens, for smog precursors, and CEPA-toxic substances.

4:35 p.m.


The Chair Conservative Bob Mills

Mr. Freeman, if I could interrupt, the IJC has reported, and actually really we should be sharing time; we already did go over with Ms. Cooper. Perhaps you could bring it to a close, so we can get on to our members, please.

4:35 p.m.

Director, Policy, Environmental Defence Canada

Aaron Freeman


My submission goes into greater detail about the legislative and the non-legislative requirements of how to implement this recommendation. We think that this would provide protection for the Great Lakes/St. Lawrence Basin. It would provide a mechanism to implement international agreements such as the Great Lakes Water Quality Agreement and to fulfill a campaign promise for each of the four major political parties.

I'd be happy to deal with your questions.

4:35 p.m.


The Chair Conservative Bob Mills

Good. Thank you.

Perhaps we could begin with Mr. Godfrey and Mr. Rodriguez, sharing 10 minutes.

4:35 p.m.


John Godfrey Liberal Don Valley West, ON

I'll try to be fairly brief.

It seems to me we're trying to do two things today. One is to figure out whether we can strengthen CEPA legislation by specific reference to vulnerable populations. And the second is whether we can strengthen CEPA by specific references to ecosystems not currently contained in the legislation.

Perhaps I will tackle the first question. It's interesting that the University of Ottawa folks, after their presentation, when it came down to what would actually be their recommendation for CEPA, really only wanted to amend the preamble to CEPA, and all the others were useful activities but not about our review of CEPA.

When I look at the child health environment, Ms. Cooper's presentation, it's only the last point that specifically deals with vulnerable populations, because it's about mandatory child health protective measures. Everything else is good, but it's not in the realm of our review of CEPA. To put more resources into child health or environmental issues is not part of the CEPA review.

Soon the first point, which has to do with these vulnerable populations, does the language that has been used in the new Canadian Pest Control Products Act, which only came into being in June 2006, meet the criteria that people are advocating in terms of strengthening language? Or is there some danger that it actually weakens the legislation because it tries to do too much, because it tries to single out individual populations. If you go with Dr. Keefe's view of the world, if you just say we'll go with the most vulnerable population and all the others will benefit from it, might that actually be a cleaner way of doing it?

So what I'm asking is this, and maybe we'll start with Ms. Cooper. Would you be happy if we simply took over the pest control language, which hasn't really been tested in any length since we've only just brought in the act?

4:40 p.m.

Researcher, Canadian Environmental Law Association

Kathleen Cooper

And I'm keeping a close on eye it.

I would point out that the last four of the recommendations, not only the final one, have to do specifically with amendments to CEPA and its implementation.

I had to be really brief and provide a lot of points in a short number of words. In the submission we made to this committee back in June, jointly with Environmental Defence, through PollutionWatch, there were many more detailed recommendations with respect to speeding up the process, the timelines, and so on, that would benefit vulnerable populations.

So yes, in response to your question, in the Pest Control Products Act, much beyond just a change to the preamble would be good. I think children deserve the same level of protection from the federal government for toxic substances as you've put in place for pesticides.