The greater the uncertainty, the more you need to take precautionary measures to address that uncertainty, which seems quite common-sensical to the average person. When you don't know what the problem is, you have to be careful. If you're not certain that there's no problem, you have to address it. It's only prudent to do so. In terms of public health policy, it's a necessity if one is to fulfill a mandate that the public expects to be filled.
I want to address two other things very rapidly, which obviously will be in the background during the whole debate on how one applies this form of risk management, and they are cost-benefit studies and the whole notion of sound or unsound science.
First of all, in terms of cost-benefit, you'll notice, if you do a review of precautionary principles, that sometimes “cost effective measures” is inserted into the definition, and other times it is not there. There have been all sorts of debates, some important, some not so important, as to whether those things should be inserted. Obviously, any government is going to look at that issue. However, it has to look at it within a certain context. And again, to quote from the European Union,
Examination of pros and cons cannot be reduced to an economic cost-benefit analysis. It is wider in scope and includes non-economic considerations. The Commission affirms, in accordance with the case law of the Court that requirements linked to the protection of public health should undoubtedly be given greater weight than economic considerations.
It went on to assert--and this is something the Canadian Strategy for Cancer Control, and in particular our primary-prevention committee, has endorsed and would like to see applied in all jurisdictions in Canada--that all class 1 and class 2 carcinogens, genotoxics, and substances potentially harmful to reproduction, including endocrine-disrupting chemicals, are of high concern, are not acceptable for daily intake thresholds, and require strict authorization before use.
That's the EU's position, and they have legislation or directives that have put that into place. There are a number of states in the United States that have also done that and have moved in that direction. Canada is probably lagging behind all those jurisdictions in taking proactive action for those particular classes of compounds.
The issue of science, and whether it is sound or unequivocal, is the last thing I want to address. Our committee is basically a tripartite committee. We have representatives from industry, from labour, from academia, and from government-linked institutions, such as WSIB. We're supported through Health Canada and the Public Health Agency of Canada. The Canadian Cancer Society and a number of its affiliates are a big part of the committee.
When we went to the strategy's governing council with a 100-page document and maybe two dozen key recommendations, the one thing they wanted to talk about was the precautionary principle. Even in that governing council, which primarily is health-scientist-based, there was uncertainty as to what that meant. We had to have a discussion, similar to the one we're having today, to talk about what it means. We're not talking about running around saying that we need no evidence before we act. We're saying that when there is potential for significant harm, you have to act, even if the evidence is not unequivocal. And you are always going to have a counter-argument--it doesn't matter what the issue is--for almost any substance of concern. The question is, when is it appropriate to act?
If we're to have a direction in this country as to how we're going to act, regulate with mandatory pollution-prevention planning. We have to look at certain classes of compounds that are out there that have been identified. We're talking about human carcinogens, for example, reproductive toxins, for example, as two clear classes of compounds that need to be addressed.
So when you see, day after day, a series in the Globe and Mail about toxic shock and what not, which I'm sure many people noticed during the last week, in fact those series were, if you looked at them carefully, focusing on those classes of compounds. That's where the Canadian public has the greatest concern. That's where precaution is most warranted, because they do have and may have significant long-term chronic effects that have not been fully documented yet. It's when you have that great degree of uncertainty and those very significant health endpoints that you need to act and not sit there and wait until all the evidence is in.
An example of the application of the precautionary principle in this country, which the whole country and all governments are now in support of, is restriction on environmental tobacco smoke. There's a placard in the back of this room about the workplace smoking law. I was looking at it during the break. That's an example of the application of the precautionary principle in the face of uncertainty and equivocal evidence. We all know there's a lot of evidence on smoking and cancer and other diseases, but if you were to ask any health scientist if is it unequivocal with respect to second-hand smoke, they'd say no, it's not.
A lot of people say I know my risk of dying of cancer if occasionally I walk in a room and some guy is smoking a cigarette may not be so significant, but on the other hand it is there, and people have died from that. So we've taken a precautionary measure, both in terms of policy and legislation, with that substance.
It makes no sense when we look at the fact that the very same substances that are in cigarette smoke are in a number of other applications with huge emissions in Canadian communities, as is documented under CEPA. The aldehydes, the formaldehydes, the polycyclic aromatics--not to address those and regulate them and require the same kind of pollution prevention planning that we do for second-hand smoke makes no sense at all.
Thanks. I'll end there.