Thanks, Mr. Chair and honourable committee members.
Good afternoon, everyone.
There will be copies of my notes circulated to you within the next day or two in both English and French. I apologize that they aren't available at the moment.
I am Dr. Isra Levy. I'm a public health physician and the chief medical officer and director of the office for public health at the Canadian Medical Association. I'm delighted to be participating in your round table today and I am grateful for the invitation. With me is Mr. John Wellner, director of health policy at our sister organization, the Ontario Medical Association.
Of course, CEPA is a key piece of federal environmental legislation. For us at the CMA and for our common members at the OMA, it is really primarily about health. Canada's doctors see the topic of hearings on measuring CEPA's success in terms of the impact on our medical practices, and more particularly on our patients, so to us the measurement of success that matters is actually simply good health in our patients.
Unfortunately, I must tell you that we still see the negative impacts of environmental degradation on many of our patients every day. We are pleased, therefore, to participate in this review of CEPA, because, as I've said, for us the measure of health benefits and health outcomes is what matters. Those health benefits and health outcomes obviously can occur over the short or long term, but those that stem from reduced exposure to environmental contaminants is, to us, an important measure of our health as a nation.
As you know, health outcomes are directly linked to the physical environment in many ways. We know from the crises in Walkerton, Collingwood, North Battleford, and many first nations communities the devastating effect that contaminated water can have on individuals and families.
We know from the smog health studies undertaken by my colleague at the OMA, by Health Canada, and by others about the public health crisis of polluted air that is now evident in many parts of Canada. It is a crisis; these are not empty words.
We're at the point now that science allows us to more clearly show the long-term lifetime burden of morbidity caused by some of these pollutants. We now know that there are thousands more premature deaths caused by air pollution in Canada every year than has previously been appreciated. Dr. Khatter has mentioned some of those statistics.
We are learning that central Canada is not the only place that has a smog problem. The OMA has shown, through its model on Iilness costs of air pollution, which I believe some of you are familiar with, that it is plausible to think in terms of substantial costs to the health and pocketbooks of Canadians because of environmental risks across the entire country, not just in central Canada.
The CMA has developed many environmental policies pertinent to these discussions today; they are outlined in the text. I'm sorry you don't have that in front of you today, but they will be there; we can certainly take questions on that material, either today or at some later stage.
I do want to say, though, that doctors understand the concept that success from an intervention can be nuanced. In the case of disease, physicians know and accept that the benefit of treatment is not always a cure for a patient--sometimes we just reduce symptoms or slow the rate of decline--but in treating the physical environment that is so critical to human health, we suggest humbly that we cannot accept a palliative solution: we must aim collectively for cure.
We urge you to commit to measures of success in terms of real improvement, rather than merely accepting slight curtailments in what is sometimes thought of as inevitable increases of environmental contamination.
The issue of greenhouse gas reduction is one that illustrates this point. Just as slowing the progression of disease can never be considered a cure, referring to an inevitable increase in emissions and attempting only to limit the growth of those emissions cannot result in true success by any serious measure.
We have seen good-news press releases on environmental initiatives from various federal and provincial governments, but from our point of view, regrettably, the news isn't always worthy of praise.
There's no question, there have been some wonderful environmental successes that we should be proud of as Canadians. But the measure of overall success on all contaminants of concern, we can only say, has been incremental at best.
For example, when policy-makers speak about industrial emission reductions of any kind, we sometimes hear wordings such as “emissions intensity”; that is, the emissions per unit of production, rather than total overall emissions. To be health-relevant, the only meaningful way to report emissions reductions is to present them as net values, not the all-too-common gross valuations. The reason is that an emission reduction from a particular source is only health-relevant if we can guarantee that there is not a corresponding emission increase at another source nearby, because it is the absolute exposure an individual experiences that affects the risk of an adverse health effect in that individual.
This kind of issue becomes especially tricky with regional pollutants, things such as smog precursors, because you have to take the whole airshed into account. For this reason, cross-jurisdictional pollution control initiatives are critically important. In Canada, that means federal oversight.
To our understanding, that's what CEPA does. It gives the federal government jurisdictional authority and, dare I say, a moral obligation to act to protect the health of Canadians. As I've said, to the CMA and we believe to most Canadians, the real measure of success is going to be a reduction in the illnesses associated with pollution. That said, it's important not just how we measure this ultimate success but also how we measure our progress towards it.
Environmentally related illness is essentially the combined result of exposure and vulnerability. We are vulnerable because as human beings each of us has different physical strengths and weaknesses. Some vulnerabilities to environmental influences are genetic and some are the results of pre-existing disease. There is not much we can expect you policy-makers, or government in general, to do about this part of the equation.
Our exposure to contaminants, on the other hand, is related to the air we breathe, the water we drink, and the food we eat. This is where CEPA comes in, and this is where your role is critical and where measures of success will be most important.
Proxy measures for the health outcomes that matter must be relevant from a health perspective, as I've said. Health-based success can only be measured by quantifiable reductions in the exposure levels of contaminants in our air, water, and food.
In this context, Canada has historically relied on only guidelines for contaminants of concern: memoranda of understanding with polluters, voluntary goals and targets. Our American neighbours prefer the legally binding approach: standards, strict emissions monitoring, and pollution attainment designations.
While there may well be some benefit to the Canadian approach, we are clearly behind in some respects in this area. For example, in many parts of the United States, counties at the local level try desperately to avoid attaining a non-attainment designation. Such a designation would be based on, for example, ambient air pollution target levels that haven't been reached. If they are designated to be a non-attainment zone, these counties risk loss of federal infrastructure transfer payments. So the consequences are very real.
In Canada, we have Canada-wide smog standards, for example, for 2010. But of course these are non-binding, they have no penalties for non-attainment attached to them, they provide loopholes for any jurisdictions claiming cross-border pollution influences, and they allow provinces to opt out with only three months' notice.
We think we must be more forceful. And for the many more chemicals of concern besides those listed as CEPA-toxic, where such forceful action is certainly justified, we also realize that where the evidence isn't in, a precautionary approach is called for. We think there are many chemicals of concern where such a precautionary approach can be brought to bear and more forcefully implemented.
Although the presentation of environmental information such as the ambient pollution levels in the state of the environment report or health-based air-quality-index kinds of work is beneficial, provides information that is useful, and helps Canadians enable themselves to reduce their exposures, ultimately it isn't enough.
The CMA believes that true success would entail going beyond reporting the danger, to actually reducing it. We believe that's the purpose of CEPA, and that's why we look forward to working with you to improve CEPA, and to ensure that the measures of CEPA's success will be to the benefit of the health of our patients across Canada.