First of all, engage the people who live in the area. They know how they use the dock and what the exposure pathways are. That is what I referred to. If the consultants or the government had notified the community and engaged it, the risk assessment would have looked fundamentally different.
Health Canada publishes the guidance for how we do health risk assessments in Canada. That guidance specifically states that you have to engage indigenous communities because their land use is different from that of the general Canadian public. They have different ways of life that could expose them to higher concentrations of contamination. It recognizes that they often live in different and lower socio-economic conditions than the general public of Canada and have a different health status. All of that is in the guidance. There's also a supplemental guidance for human health risk assessment for country foods, which is what we call traditional foods and medicine. The guidance was all there.
In the oil sands area in northern Alberta and a bit across Canada—but in Alberta specifically—there are a lot of consultancies with risk assessors who practise with and work for developments and proponents. We don't have a governing body for risk practitioners. We all practise under different professional organizations. I'm a professional biologist. There's APEGA, which would be for engineers. You don't go to school to become a risk assessor. It's based on who you trained under and how you learned.
If you have a system that is, as I'll refer to it, risking away liability to try to save money so you don't have to clean up contamination and this becomes the industry best practice or standard, that's how we get risk assessments like this. Designating a community use area with a lot of human contact as a commercial site wouldn't have happened if you had talked to anyone in this room or engaged anyone. It would have looked fundamentally different.
I'm not saying a different consultant needed to do it, but if direction had been provided and people had been engaged, the consultant wouldn't have been able to go out on their own. I don't have any indication of what Transport Canada guidance was given to the consultant, but again, it's shocking to me that a federal department wouldn't have understood the use of big dock in Fort Chipewyan.