If not, maybe we can finish it up when you get back.
Thanks very much for inviting me to present on behalf of the Canadian Strategy for Cancer Control. I'm the chair of the National Committee on Environmental and Occupational Exposures, which works under the Canadian Strategy for Cancer Control.
Approximately a year ago, in the fall of 2005, we made a submission on CEPA 1999 and made a number of recommendations that I believe the committee has had circulated. When I was asked to come today to address more specifically the precautionary principle, I understood why, in that it is really a principle that underpins any action--or inaction, depending on your point of view--on precaution with respect to environmental or occupational health concerns.
In fact, the application of the precautionary principle underpins all the recommendations we have made through the Canadian Strategy for Cancer Control with respect to CEPA and with respect to control or elimination of known human carcinogens in our environment. We include in that environment, of course, workplace exposures, because we address both.
We targeted two areas with respect to a series of recommendations we've made to government, industry, other levels of government and labour, and other NGOs. Those two are pollution prevention programming, particularly with respect to identified and classified human cancer-causing agents; and disclosure of the presence, use, or release of those classified carcinogens in Canadian communities and in the Canadian environment.
We made the point that until you and the public have a clear understanding of what those exposures may be--the nature of them, and the nature of the risk--obviously policy decisions that need to be taken won't be understood or won't be supported. We have found that the more information the public receives in this area, the more they ask for public policy in health protection with respect to environmental carcinogens or, for that matter, carcinogens you find in consumer products and so on.
There has continued to be, obviously, a debate over how serious or significant this risk is with respect to environmental exposures, and there is always going to be a debate in terms of quantifying exactly what percentage of cancers in Canada can be attributed to environmental or occupational exposures. In fact, in a very useful and insightful document published a year ago on environmental carcinogens, Cancer Care Ontario noted that it's almost impossible to find unequivocal evidence of harm or cancer causation, particularly when you're looking at environmental exposures. That doesn't mean you're not going to find them; there is always evidence, but you're not going to find unequivocal evidence.
It went on to say that in spite of that--in fact, because of that--it was necessary to apply things like the precautionary principle to begin to control and eliminate a number of very significant and serious threats to our environment and our health with respect to environmental exposures. In particular they addressed things like drinking water chlorination byproducts, radon exposures, diesel air pollutants, certain pesticides, and heavy metals.
In other words, the point they made and the point we make is that it is possible to prioritize. We're not talking about 40,000 compounds that we must immediately address using the precautionary principle. No government is going to be able to do that, we're not resourced to do that, and people are going to ask how to prioritize.
One of the things we prioritized or classified was known human cancer-causing products. They are classified through the World Health Organization, and they are referenced in our legislation, both federally and provincially, in terms of not only the environment but in all the occupational health regulations as known human carcinogens to which there should be, if at all possible, no exposure at all. When you apply that to the environment, you're applying the precautionary principle in a certain way and in a focused way.
Again, many argue that there isn't sufficient evidence to do that. The way we put it is the opposite--public policy and primary prevention is driven by limited data and a necessity for precautionary measures. We cited as one articulation of that the European Union, the European commission's adoption of a definition of the precautionary principle.
You've heard it over and over again. Essentially it says that where reliable scientific evidence is available that there may be adverse impacts on health or environment but there is still scientific uncertainty about the precise nature or the magnitude of that damage, decision-making must be based on precaution in order to prevent that damage.
There are a number of other very serious scientists in the country who have addressed this as well. In Canada, for example, the CEO of Cancer Care Ontario, Dr. Terry Sullivan, in that Insight on Cancer review stated: “Governments may choose to go beyond existing evidence and be guided by a range of principles...”. He then went on to talk about the precautionary principle, citing that “the tradition of public health, a tradition which in Canada, through the Supreme Court, has given municipalities the authority to ban pesticides” is in fact a tradition of application of the precautionary principle.
Dr. Tony Miller, professor emeritus of U. of T. and a colleague of mine on our committee, put it in terms very much to the point. He said: “The potential penalties from not following this principle are that cancers that could be prevented are not”. That's pretty basic, and it is a fact.
Dr. Donald Wigle, formerly of Health Canada and now with the R. Samuel McLaughlin Centre for Population Health Risk Assessment, cited Horace Krever and the Canadian blood supply commission, who restated again that the precautionary principle means that:
Where there is reasonable evidence of an impending threat...it is inappropriate to require proof of causation beyond a reasonable doubt before taking steps to avert the threat.
In Canada there's not only a great amount of discussion on this principle, but I think there are two citations from the European Commission as well that are particularly informing to us. One is their statement that the application of this principle is in fact the “central plank of Community policy”. These are quotes from the EU documentation. One that I think is particularly germane is this one. It is “...in situations in which the adverse effects do not emerge until long after exposure”—