Thank you.
The precautionary principle is fundamental to protecting the health of children and other vulnerable populations and vulnerable ecosystems.
CEPA requires the government to make sure that 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. It is important that CEPA states the precautionary principle, but it must be made operational in a meaningful way to protect vulnerable populations and ecosystems.
Earlier this year, CIELAP released a report called “There is no 'Away' - Pharmaceuticals, Personal Care Products, and Endocrine-Disrupting Substances: Emerging Contaminants Detected in Water”. Pharmaceuticals and chemicals in personal care products are increasingly being used by both humans and animals. These contaminants find their way into water in four ways: substances used in manufacturing are discharged into waste water; unused medications, cleansers, and personal care products like shampoos are washed away with waste water; drugs are excreted into the waste water stream directly; and discarded or excreted substances are carried in runoff from private septic systems, treatment facilities, and from animal waste and sewage sludge spread on farm fields.
Testing in the U.S. has found emerging contaminants virtually everywhere--in surface water, groundwater, and stream-bed sediments. There's not been as much testing in Canada, but one study of samples near sewage treatment plants in 14 Canadian cities found a number of pharmaceutical products present.
Increased use of antibiotics by humans and as growth promoters in farm animals has led to increased concerns about antimicrobial resistance. And there's also concern that exposure to certain environmental contaminants may interfere with the human endocrine system.
Endocrine-disrupting substances, or EDSs, may increase or decrease hormonal activity that controls many of the body's functions, including growth, development, and reproduction. EDSs are found in pharmaceuticals such as birth control pills, industrial chemicals such as PCBs, metals and plasticizers, fragrances and preservatives in cleaning and personal care products, contaminants such as dioxins, and pesticides such as the insect repellant DEET.
In humans and other large mammals, the health effects of EDSs are not yet well understood, but in fish, birds, and other wildlife, effects have included reproductive impairment, reproductive failure, deformities, and feminization. The incidence of cancers linked to the presence of excess hormones--breast, testicular, and prostate cancers--has recently risen despite the fact that overall cancer rates have been declining. Many more animal studies, along with clinical research and statistical trends and patterns, are needed to establish consensus about the human health impacts of EDSs.
History has shown that the potential hazards from emerging contaminants are not always initially clear. Thalidomide was prescribed as a tranquilizer or a sleeping pill during pregnancy before it was discovered in 1962 that it caused dramatic birth defects in babies, such as missing or truncated limbs. In 1971, a link was established between the synthetic hormone DES, taken during pregnancy to prevent miscarriage, and its effects on female children that included a rare form of cancer, pregnancy complications, and infertility.
These examples teach important lessons related to endocrine disruption and the issue of emerging contaminants. Scientists realized that some effects of these exposures were delayed and would not show up until the fetus was a young adult. Also, some extremely small doses of hormones had devastating impacts. A June 2006 study conducted by Environmental Defence tested seven children and six adults and found 38 chemicals that can cause reproductive disorders and harm the development of children, 38 suspected cancer-causing chemicals, and 23 chemicals that can disrupt the hormone system.
In our submission, we make a number of recommendations. The categorization criteria in subsection 73(1) of CEPA needs to be updated to require that domestic substances list substances be considered inherently toxic and identified for further action if they are known to be carcinogenic and/or known to be capable of reproductive or neuro-developmental toxicity. Once identified, these substances should be targeted for virtual elimination.
CEPA should be amended to require consumer product warning labels notifying the public if a product contains substances that are known to be carcinogenic or toxic to human reproduction and development.
CEPA should include explicit language directing that vulnerable populations be taken into account in identifying substances for assessment and in conducting assessments.
The government should also phase out antibiotics and hormones as growth promoters for farm animals as a precautionary approach to health and ecological concerns such as antimicrobial resistance and EDSs.
This is clearly the time for the Government of Canada to move forward in regulating these emerging contaminants, as the last week has shown. Last Friday the government announced a new chemicals management plan to regulate chemicals harmful to human health and the environment. Proposed measures include establishment of the virtual elimination list under CEPA, addition of the first substances to that list, and development of solutions for the proper disposal of 9,000 chemicals such as pharmaceuticals and personal care products.
Yesterday a letter signed by approximately 700 environmental scientists was released, urging that the current parliamentary review of CEPA be used to better protect Canadians and the environment from the harmful effects of pollution, noting particularly the vulnerability of populations such as children and infants. The letter states that in any scientific field, uncertainty may remain regarding a particular chemical and whether it causes a particular health or environmental effect. However, the available information warrants a precautionary approach in our system for assessing and managing potentially harmful substances. The letter notes that CEPA's regulatory provisions provide the authority to regulate consumer products, but that the government generally does not use CEPA for this purpose. It is time to use CEPA to do this.