Thank you, Madam Chair, for the opportunity to present our views in seven minutes and to at least get on the record for students of social history.
The Canadian Health Coalition is a non-partisan advocacy organization founded in 1979, dedicated to preserving and improving Canada's public health care system. The first goal of our coalition is to create conditions for good health. We think this should be the first objective of the Minister of Health, not to balance health with economic interests.
I'll make a couple of general observations, then some specific recommendations on Bill C-6.
I read the initial presentation of officials from Health Canada to your committee on May 5, and was impressed by members' questions from all sides. However, I must say I found the departmental responses misleading and deceptive.
Bill C-6 is consistent with the Government of Canada's policy of putting economic considerations ahead of protecting health and the environment. Everything else follows from this, including the policy of managing risk that causes preventable death instead of preventing the damage in the first place with a precautionary policy.
Bill C-6 reflects a general pattern of regulatory and legislative initiatives coming out of Health Canada. Rules are drafted by the industry itself, then these rules are not applied or enforced.
Canada's health and safety regulatory agencies have been captured by the very industries they are supposed to regulate. This regulatory capture is formalized in memoranda of understanding, where the industry actually funds the regulator and the regulator enters into a client relationship with the industry. Now, I'm assuming members of Parliament understand this, and this is what fee-for-service is all about, so their client becomes the industry instead of the public.
Regulatory scientists at Health Canada, should they have old-fashioned views of serving the public, will be fired—and have been fired. If Health Canada were putting health protection ahead of economic interests of the chemical producers, why would Dow Chemicals be pointing to Health Canada to use against Canadian municipalities in the NAFTA court challenge on cosmetic use of pesticides? If Health Canada were a world leader in protecting human health from toxic chemicals, as claimed by the associate deputy minister here on May 5, then why is Health Canada, at the Codex Committee on Nutrition and Foods for Special Dietary Uses, actively working hand in hand with the food industry to block the reduction of chemical additives and contaminants in infant foods? This outrageous behaviour is well documented by the respected International Baby Food Action Network.
Health Canada has displayed negative leadership in international food and regulatory bodies by systematically blocking the introduction of the precautionary principle in international health regulations. Experience has taught me to approach any health protection legislation sponsored by Health Canada with a critical eye, based on what the department actually does, not on what it says it's doing. I encourage you to continue in this direction, as members of Parliament. Some of you have more experience than others with this departmental double-speak.
The following are specific recommendations on Bill C-6:
First of all, the legislation needs to be precaution-based, not risk-based, and the associate deputy minister acknowledged this was a risk-based piece of legislation. That's the completely wrong starting point. It means parents don't have the right to apply precaution, because the department has already taken the risk decision for you. That means that certain chemical substances should be banned outright.
The second recommendation is to end Health Canada's secrecy about unsafe products. Bill C-6, in the definition section, enshrines into law commercial confidentiality under “confidential business information” and is such that anything that affects a company's bottom line may be kept secret. This provision must be removed from the bill if any one of you believes in the right to know. This provision is completely inconsistent with that.
The third recommendation is that we support a number of our environmental organizations, some of which are here today, in calling for an outright ban on lead, mercury, phthalates, and PBDEs.
Fourth, there needs to be a legislated mandate toward labelling in the meantime, and I understand a number of witnesses will speak to that.
Finally, we have to ensure that whistle-blowers are protected. We strongly support whistle-blower protections for individuals within companies and within Health Canada who uncover wrongdoing. Whistle-blower protection will help bring to light serious safety issues hidden by unscrupulous corporate executives, and will help ensure that scientists and other professional staff at Health Canada may raise concerns about unsafe products without fear of retaliation by the Government of Canada.
Thank you.