Thank you.
It's a pleasure to have a chance to offer just a few comments as you contemplate the renewal of a very important federal statute, the Canadian Environmental Protection Act.
I have five areas that I want to make very brief comments on. There is one you might think a little peripheral, but I think it's quite central, and that's the exploitation of new science in environmental health risk assessment. I'll focus about a third of my comments on that topic.
Among the other topics, as Lynda has mentioned, is air pollution, and I'm going to expand it to a global environmental health challenge which is important that we consider. There is the possibility of strengthened provisions for drinking water safety within CEPA, and a brief discussion of the principles by which we should make important risk decisions. Finally, I will have some comments about linkages with other international environmental risk assessment programs.
On the science side, the science of toxicity testing and assessment of environmental agents is undergoing a transformation. I chaired a committee of the U.S. National Research Council which reported in 2007. The title of the report is “Toxicity Testing in the 21st Century”. We were asked to chart how we should be using new scientific tools and technologies to better assess the risks associated with agents in our environment.
We wrote a detailed report which was transformational. It talked about using new technologies, high throughput in vitro screens and computational toxicology being two of about a dozen different approaches. These tools offer the potential to greatly accelerate the rate at which we can test the tens of thousands of agents that are present in the environment at reduced cost. There are now robotic laboratories that can run through 100,000 chemicals in the space of six weeks for 50, 100, 200 different biological end points. The world is truly changing in the field of toxicological risk assessment.
This report, to my surprise and to my satisfaction, has received widespread acceptance around the world. It has been adopted by four major regulatory agencies in the United States. The Council of Canadian Academies wrote a report in 2012, which said that this is a good way to go. There has been a grassroots consortium to develop the science needed to implement these procedures. The Chinese Society of Toxicology translated our whole report into Mandarin, and it's very popular now in Asia as well, so we've had lots of widespread international acceptance for these ideas.
As a follow-on, I worked for three years on a project initiated by the U.S. Environmental Protection Agency to talk about how we should translate these new ideas into practice. What should the next generation of risk assessment look like? We published a major report under the auspices of the U.S. EPA. I have references to most of the points that I'm making here in the handout that I've left with the committee. We've laid out a template, a paradigm, and a framework for the next generation of risk science, which shows how we could be doing toxicological risk assessment better, cheaper, faster. The key cornerstones are the new toxicological approaches, advanced risk assessment methodologies, and some ideas from population health, looking at multiple determinants of health simultaneously, gene environment interactions and social environment interactions included.
Another theme—and I'm coming to the end of my scientific remarks—is we now have very well-thought-through frameworks for evidence integration, pooling together evidence from multiple sources to come up with the best scientific statement of levels of risk. The U.S. Environmental Protection Agency's integrated risk information system was reviewed in 2014, and there's a template that is being adopted by the U.S. EPA for integrating evidence in a thoughtful, balanced manner.
Some of the lessons from all of this are we can use the new science to look at data-poor compounds. There are 23,000 substances on the domestic substances list that Health Canada and Environment Canada have prepared. These new high throughput techniques can run through those efficiently, and give us answers to potential hazards and risks in a cost-effective manner. At the other end of the spectrum, when we go to PSL, priority substances types of compounds, which are typically data-rich and warrant in-depth evaluations, some of the new evidence integration techniques would be very valuable there.
My take-home message from the first of my five points is the science by which we conduct environmental health risk assessment is undergoing a revolution and there are plenty of opportunities to exploit these new techniques.
I don't know that CEPA itself wants to be prescriptive on how it should be done in practice, but I think CEPA should acknowledge that there are tools at our disposal that we did not have in the past.
Just as a footnote, one of the questions that came up early on during this transformation was by the legal community in the U.S. They asked how all of these new scientific ideas would work with respect to existing federal statutes. We had a session sponsored by the Environmental Law Institute in Washington. The conclusion was that the statutes typically say you should do your best assessment with the best available science. All of these new ideas were seen to be compatible with the existing legislation in the U.S. and presumably in Canada as well.
Getting on to the remainder of my points, I want to highlight the importance of air pollution at the global level. I'm looking here at a very nice map of the world drawn based on satellite images. It can predict ground level pollution concentrations at any latitude and longitude on the planet. I see some hot spots in Asia and Africa due to the Sahara dust. I have another map corrected for natural dust.
The point is there is a global public health issue related to air pollution. We have a paper on environmental research, which I've cited in my submission, suggesting that globally, approximately 10% of all deaths worldwide may be attributable to air pollution. So it is something we need to pay attention to from a public health point of view, and it's a problem we cannot solve totally in Canada because a lot of our pollution migrates across national borders.
Turning to drinking water, which is another important area of environmental concern, there was a drinking water materials safety act in 1997 that made it to first reading in the House of Commons. The House was prorogued, and that act never was reintroduced.
I have a cartoon in front of me that looks at the three main components of that, which are treatment of drinking water at the filtration plants, distribution of water throughout the water system through copper pipes and other materials, and point of use devices like charcoal filters on your kitchen tap, all of which could be used to enhance drinking water safety.
My suggestion is, if the committee is so inclined, to take a look at some of the elements of the previous drinking water materials safety act, and since that act did not materialize, to see if any of those might be useful to consider for inclusion in CEPA.
My second-last point is about how we make decisions about environmental risk issues. I just finished my class earlier this afternoon. The session was on principles of decision-making. There are about 10 major principles we discuss. Different principles are applicable in different contexts.
One that I stress to my class is the precautionary principle, of which there are over 20 different definitions, which are embodied in a lot of statutes and guidelines worldwide. It's a very useful principle. It says that if you're uncertain, if the science is not clear at this point, and if the stakes are high, you may want to take action rather than wait until it's too late.
When you get a message in Fukushima that it might be good to evacuate because there might be a tsunami coming, that's a good example of the precautionary principle.
Another one we focus on is risk-based decision-making, which says that when you have limited risk management resources, you want to try and do the most good for the most people, so you should try to allocate your resources to risks you know can be modified and risks you know are real, and modify them in a cost-effective manner.
We define the right principles to underlying environmental decision-making. Again, I'm not sure that CEPA wants to promote principles, but some consideration of how decisions should be made might be useful as you're crafting the new legislation.
My final point is about international collaboration and risk management. Canada is not the only country that has environmental legislation. In the European Union, the REACH program under the European Chemicals Agency has required that every chemical in existence have a detailed toxicological dossier submitted for evaluation. The U.S. Environmental Protection Agency has generated a huge database on environmental agents and potential risks. They have offered me no fewer than three million datasets to play with for our research at the University of Ottawa, so there's a lot going on internationally.
If we could work somehow at the international level, we could perhaps more effectively address international risk issues such as transboundary air pollution. We might be able to harmonize risk assessment practices, leading to the avoidance of non-tariff trade barriers, which is quite important in this era of globalization. We might even achieve cost savings through data sharing agreements and mutual recognition agreements. Some international perspective would be quite valuable.
I do have a handful of references in my handout that support most of the comments that I've offered the committee today.
Thank you.