Scientists call for action on toxic chemicals

A letter to the Prime Minister from Scientists For A Healthy Environment, which doubles as an effective critique of the Canadian Environmental Protection Act:

Dear Prime Minister,

We are writing to encourage your Government to make significant improvements to Canada ‘s overarching pollution law, the Canadian Environmental Protection Act (CEPA).

Canada has a growing pollution problem that is a threat to both human health and the quality of our environment. In recent years, our understanding of the health impacts of pollution has become much clearer. In 2005, the Ontario Medical Association estimates that, in Ontario alone, smog-causing substances are responsible for 5,800 premature deaths, and more than 60,000 emergency room visits in a single year. A significant body of scientific evidence is drawing links between toxic chemicals and health conditions such as cancer, asthma, autism, learning disabilities, attention deficit hyperactivity disorder, birth defects and low birth weight. The risks are higher for the developing fetus and among infants and children, who are uniquely vulnerable because of their developing organs, rapid metabolisms and lifestyle exposures.

In our environment, pollution has continued to threaten aquatic ecosystems such as the Great Lakes-St. Lawrence basin, where substances of emerging concern such as brominated flame retardants, perfluorinated substances and pharmaceuticals are being detected in the waters and in wildlife species. In the Arctic , studies suggest mercury levels are leading to high blood pressure in newborn babies and causing polar bears to lose cubs at birth. Of particular concern throughout Canada are a host of persistent and bioaccumulative substances often found in consumer products.

As in any scientific field, uncertainty may remain regarding a particular chemical and whether it causes a particular health or environmental effect. However, the available information warrants a precautionary approach in our system for assessing and managing potentially harmful substances.

CEPA requires significant improvements in order to deal with the emerging challenges of harmful substances in our environment.

Vulnerable Populations and Ecosystems

CEPA explicitly “recognizes the importance of an ecosystem approach.” However, there are no provisions requiring the government to address vulnerable ecosystems such as the Great Lakes-St. Lawrence basin, the largest freshwater ecosystem in the world, where one third of Canada ‘s population lives and nearly half of the country’s toxic air pollution is generated. Significant regions such as the Great Lakes thus warrant particular attention in the Act.

In addition, it is important that the chemicals assessment process be legally required to fully account for the unique vulnerabilities of children and infants.

Especially for vulnerable populations across Canada , it is important that CEPA apply pollution prevention principles and place a priority on the phasing out of the most toxic substances.

Required Timelines

Under CEPA, while some stages of the assessment and management process have mandatory timelines, others do not. As a result, assessments and recommendations are often not acted upon, or delays result in years of inaction on substances of concern. Parliament should ensure that there are required deadlines at each stage from assessment to management of potentially harmful substances.

Burden of Proof

Under CEPA, industry must provide certain data in order to get approval to market a new substance. However, for the 23,000 existing substances (those in commerce up to 1986), data requirements are minimal. A precautionary approach suggests the onus should be on industry to show that products are safe, rather than the current system for existing substances, under which the government must generally prove that a substance is harmful before taking regulatory action. An industry burden of proof is in place under Canada ‘s new Pest Control Products Act (PCPA), which governs pesticides. It is also the principle behind the pending Registration, Evaluation and Authorization of Chemicals (REACH) system in Europe .

Consumer Products

Increasingly, products bought and sold on the market contain substances that are potentially harmful to Canadians and to our environment. CEPA’s regulatory provisions provide the authority to regulate consumer products, but the government generally does not use CEPA for this purpose. While the Hazardous Products Act is occasionally used to regulate consumer products, this law deals primarily with product-specific (rather than chemical-specific) threats, and usually only where instances of acute poisoning have taken place. There are no provisions to deal with substances that are of general or specific concern to the environment.

For example, lead, a highly toxic substance that was banned in gasoline over fifteen years ago, is often found in consumer products. Canadians are exposed directly to these products, and when the products are disposed of, lead enters our environment. The Hazardous Products Act has been used to regulate lead in children’s jewelry, but not in widely available costume jewelry, key chain fobs, lapel pins and a wide range of other products.

CEPA should cover all the major pathways that expose Canadians to potentially harmful substances. The law should regulate these substances in consumer products, which are currently not explicitly covered by the law.

The current parliamentary review of CEPA provides an excellent opportunity to better protect Canadians and our environment from the harmful effects of pollution. We urge you to modernize CEPA by making these changes, for the benefit of all Canadians.

Sincerely,

You. If you want, you can sign on to the letter at: http://scientistsforahealthyenvironment.ca/signon.php

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