Thank you, Mr. Chair.
I will begin by sort of echoing Mr. Attaran's comments in saying that, in Canada, drinking water is generally of good quality, with the exception, of course, of the drinking water in many rural or first nations communities.
Bill C-326 does not address the issue of boil water advisories in first nations and other communities. Resolving these issues requires a political will, a significant commitment of financial resources and highly likely, in my opinion, new governance structures in some cases. Fortunately, the government is dealing with this challenge with great determination, and so far, the results have been promising.
When any changes are made to the drinking water standard development system, we must make sure not to unduly increase the burden on Health Canada or, perhaps more importantly, on public water services and their operators. To do otherwise would be counterproductive to achieving the objective of Bill C-326, which aims to reduce Canadians' exposure to harmful contaminants in drinking water. Interfering in how Health Canada and public water services are fulfilling their mandate of providing quality drinking water unintentionally compromises the quality of our drinking water.
Bill C-326 aims to be a small practical step. It's objective is to modestly increase the rigour and accountability of the process of developing Canada's guidelines for drinking water quality, hopefully resulting in Canadians being able to access the best drinking water in the world on an ongoing basis, even as new contaminants are identified over the long term.
The bill seeks to do this by requiring Health Canada to systematically scan the international environment to compare Canada's drinking water guidelines with those of other comparable nations, and report on discrepancies. Such an exercise would provide the public, NGOs, and the media with the information needed to judge whether the government is being timely and thorough in recommending maximum allowable concentrations for contaminants in drinking water.
Bill C-326 is inspired by the work of the environmental NGO Ecojustice, namely by its report entitled “Waterproof”, which is a report card on Canada's drinking water guidelines in comparison to those of the U.S., Australia, and European Union countries and guidelines recommended by the World Health Organization.
According to the report, published in 2014, there are 189 substances regulated in other countries for which Canada has no standard. This gap, however, is justifiable in 84 cases, where Canada has either banned a particular substance or the substance is otherwise not in use here. That leaves 105 substances that are regulated in at least one other country, but for which a guideline does not exist in this country. For example, Canada lacks a guideline for styrene, a possible human carcinogen, but the U.S., Australia, and the World Health Organization have set maximum allowable limits for this substance in drinking water.
Furthermore, according to the Ecojustice report, there are 27 substances for which Canada has the weakest standard of the countries that do have standards, or is tied for the weakest standard. For example, the standard for the herbicide 2,4-D is 1.5 to 3 times stronger in other countries than it is in Canada.
It is important, in my view, to note the distinction between microbial pathogens known to cause human disease through drinking water, and contaminants that, because of their low concentration, pose very little risk to human health. This doesn't mean that low-risk contaminants should not be assigned maximum allowable concentrations. This should be done on precautionary grounds, in my view. However, care must also be taken to avoid diverting plant operator attention from those pathogens that provide a clear, quick, and certain risk of harm if not properly monitored and controlled in drinking water systems.
There may be legitimate reasons why a Canadian guideline remains weaker than that of another comparable country. Guidelines are a function of risk, and risk depends on many factors. A contaminant's presence—arsenic would be an example—may pose an insignificant risk in a particular geographic area, and thus, pouring large sums into eliminating that risk could come at the expense of other important health priorities. To quote Dr. Steve Hrudey in a paper he wrote for the C.D. Howe Institute:
...there needs to be acceptance...of the reality that all risks to drinking water safety are not equal and that drinking water treatment strategies must address the important risks before limited resources are substantially diverted to dealing with the hypothetical issues.
Some believe we should move further in the direction of a cookbook or numerical approach to regulating drinking water as in, for example, the U.S. with its stricter emphasis on legally binding standards for drinking water contaminants. However, it may be better, and in line with emerging international practice, to put a strong emphasis on ensuring the highest operational standards in water utilities. To again quote Dr. Hrudey, speaking of over 70 case studies of outbreaks since 1974 from 15 different affluent nations:
Despite having the most detailed and onerous regulatory regime for drinking water in the world, the US accounted for 23 of the 70 disease outbreaks....
Owing to our constitutional division of responsibilities with respect to drinking water, where the provinces select guidelines to enforce, our system of regulating drinking water has built-in flexibility that prevents an over-reliance on a rigid numerical approach at the expense of focusing on ensuring good operational standards in drinking-water plants. While stricter guidelines can be recommended, provinces can decide on their relevance given local conditions and other factors to be considered in evaluating risk.
Canadians have the right to know how Canada's drinking-water guidelines measure up against international standards and whether there are valid reasons for any observed discrepancies. Such analysis could prove transformative for the process of updating Canada's drinking-water guidelines.
Bill C-326 thus imposes a statutory requirement on the government to conduct a comprehensive analysis of Canada's drinking-water guidelines in comparison with international standards and report on the results.
Specifically, Bill C-326 would require the health minister, within three months after the end of each calendar year, to conduct a review of the drinking water standards in OECD member countries in the previous year, and prepare a report on the review. The minister would be required to table the report before the House and Senate essentially within 15 days of the report's completion. The report would also have to be published on the department's website within 30 days from the day the report is laid before the House and Senate. If the Minister of Health is of the view that standards in an OECD country provide for a higher level of water quality than the Canadian guidelines and that it would be in the interests of Canadians that those guidelines be amended accordingly, the minister would be required to include such a recommendation in his or her report.
Bill C-326 creates a process analogous to the one by which pesticide regulations are updated in Canada. Subsection 17(2) of the Pest Control Products Act states:
...when a member country of the Organisation for Economic Co-operation and Development prohibits all uses of an active ingredient for health or environmental reasons, the Minister shall initiate a special review of registered pest control products containing that active ingredient.
Thank you, Mr. Chair.