REPORT ON CHEMICALS MANAGEMENT PLAN
Meetings of the Stakeholder Advisory Council and Multi-Stakeholder Meeting
May 21 – 24, 2019 Ottawa, Ontario
Report by Sheila Cole Environment and Health Expert and CHNNE (Representative for the NSEN)
These three and a half days of meetings involved presentations on several topics. I have concentrated on the topics of highest interest to me in relation to my areas of work and expertise.
Knowledge regarding the National Pollutant Release Inventory (NPRI) needs to be increased across Canada. At the moment, this consists mostly of dissemination of information out, and reliance on people finding their way inside a very complex and technical website.
In general, it would be best for Canadians to have NPRI data interpreted for them and circulated through common media. It is important for Canadians to know the rich knowledge available on the site such as which pollutants are decreasing, where they are increasing, what the most common sources are, etc. These are the kinds of important information that may not be readily grasped and interpreted by the public as they navigate the site, trying to make sense of graphs and charts. The media would be more inclined to print stories related to the CMP and the NPRI if this information is provided in interesting and accessible news releases.
There has been some outreach to spread knowledge of the NPRI and help people to learn how to use the site, but that outreach is very NCR concentrated. After that, the outreach has been mostly within Ontario and Quebec. In the meantime, knowledge about the program is badly needed in the regions. NPRI program and outreach developers are missing the target by focussing on the general public and youth. They should, instead be working with municipalities, groups and communities, especially in hotspot areas.
Communities need a mechanism to get direct help with such things as information and
analysis. They need a number to call for help… a Help Line. The program could train people as technicians who would work at the provincial or regional level. These technicians could then be the help on the ground for groups, communities and individuals who need help addressing sources of pollutants, mitigation of pollutants and overall reduction of pollutants in their own neighbourhoods.
How are individual Canadians supposed to navigate the NPRI website and make some sense of it, when even technically experienced people in industry, academia and the NGO community struggle with it. I have noticed that within the whole multi-stakeholder community it is those with a background in engineering, mathematics etc. who have the greatest ease with accessing and interpreting the NPRI data.
In order to raise its profile, the NPRI needs a public relations injection. It is a very rich but unfortunately highly underutilized resource because it is a very complicated index and simply not easily accessed or understood.
Bisphenol A (BPA)was discussed as a success story in terms of its having been removed, most notably, from the plastics in infant baby bottles. Perhaps this success would be merited if the substitute chemical were not also toxic. In this regard, the public has been misled. They think that anything which is marketed as being BPA free is therefore not toxic. It is important to remember that Canadians expect the government of Canada to protect them from toxins. In this instance, Canadians are being misinformed, while the program celebrates success. The public is now buying products like BPA free, reusable drinking containers to carry their water, thinking that the container is safe. Stores that market these products also feel confident that they are offering a healthy product to their customers.
Nanomaterials are being developed at a very fast pace with the intention of broad usage in products. While this field is developing rapidly, there are a few current checks and balances to ensure that these materials are safe for human health and the environment. The development of the materials and usages is swift, yet the government’s response is, typically, slow and measured. This raises obvious concern that if there are problems arising, how do these materials get removed from the market place before extreme damage occurs. It’s already too late to address these issues in the products that are already utilizing nanomaterials and already circulating in the marketplace. One example of this is the current usage in cosmetics and personal care products. Who, if anyone, is tracking the range of their usage and the impact on individuals using these products and also their environmental impacts?
As Barbara McKinnon aptly commented, “There are unknown unknowns“! While the broad range of work being done internationally on nanomaterials is encouraging, the field is left wide open for data gaps that could have serious implications for both human health and the environment.
VULNERABLE POPULATIONS – MCS
It is encouraging that the Chemicals Management Plan (CMP) has undertaken to focus on Vulnerable Populations (VPs). One such population is those with Multiple Chemical Sensitivities ( MCS). It is critically important that this group be included, in writing, in the list of VPs, along with infants, expectant mothers, the elderly, etc.
In terms of chemical exposure, this group has long been referred to as “Canaries”, for very obvious reasons. Yet, to date, few people and institutions have followed their warning. This is the group that the CMP should be paying closer attention to, as a means of data collection, and importantly to understand, address and to deal with the reality of the ugly cumulative impact that chemicals are having on humans, in particular, those suffering from MCS.
The medical speciality known as Environmental Medicine has been established for several decades now, and hundreds of physicians have been trained in the speciality. It would be an excellent and most appropriate idea to have an Environmental Medicine Specialist sitting as a member of the Stakeholder Advisory Committee (SAC). They could speak with first-hand knowledge on the rising impact of chemicals on human health and the way chemically related diseases are affecting the human body. There is one such specialist in Ottawa, namely Dr. Jennifer Armstrong. Dr. John Molot is nearby in Toronto. Either of these physicians would be a huge asset to the program.
Many books have been published on this subject by well-known physicians, such as: Dr. Sherry Rogers, and Dr. Claudia Miller (together with her research partner, Nicholas Ashford, Phd.). Dr. Samuel Epstein’s book The Politics of Cancer is also a compelling reference on the impact of chemicals on health. Many more books can be found on this subject. The scientific literature is well established, rich, plentiful, authoritative, and continually being updated. Children with multiple chemical sensitivities often have behaviour problems and learning disabilities. All people with MCS have issues of accessibility-related to public buildings, workplaces, hospitals, schools, recreation facilities, etc. Common exposures include strong cleaning substances, people wearing scented products, and off-gassing from building materials, flooring, furnishings, etc. Adults with MCS have difficulty holding down jobs to support their families and caring for their children due to this extremely disabling condition. With respect to disability, it must be noted that MCS is recognized by the Canadian Human Rights Commission. It is time that the CMP boldly steps forth to recognize and embrace this very real and disabling disease that is undeniably connected squarely to chemical exposure.
INTERNATIONAL CHEMICALS MANAGEMENT – SOUNDING THE ALARM
Canada is very well respected internationally for the work it has done on chemicals through our highly respected Chemicals Management Plan. Our country works closely harmonizing our chemicals management with the United States, Mexico, the European Union, Japan, China and other countries around the globe. Also, Canada is engaged in helping many countries who do not have such a plan to establish their own chemicals management plans, using the CMP as a model.
But there is an aspect to international chemical management discussions that is not being fully embraced. That is the GLOBAL REDUCTION of CHEMICALS PRODUCTION. None of the larger bodies such as the OECD or the WHO, for example, has advanced this topic as an area needing immediate attention. There are some 130 million chemicals now in the global registry. The value of the global chemical industry exceeded 5 trillion dollars in 2017. The international production of chemicals is slated to double by 2030. China alone is expected to contribute half of the volume to that estimate. There is much talk of various means of minimizing adverse impacts of these chemicals and wastes and reducing the risks of some chemicals and wastes. Also, much work is being advanced in the field of green chemistry. Yet, no coordinating body is calling for an overall reduction in the production of chemicals.
In the meantime, diseases of the central nervous system, many different cancers, childhood asthma, autism, and other diseases are continuing to spike in countries around the world. Air, soil and water in countries the world over are heavily contaminated with chemicals. Entire ecosystems are damaged and unable to deliver their vital and critically important services. These are known facts. In the face of this knowledge, how can we continue to allow more and more and more chemicals to be developed and to enter into commerce? This makes no sense. Something must be done to curb the overall global production of chemicals.
Canada is very well-placed to advocate for such an initiative. I highly recommend that action is undertaken immediately to do so. Canada has the proven knowledge and capability to lead discussions and action on this growing threat to the environment and to the very survival of humans and other living things.
PLASTIC USE and DISPOSAL
Canada’s new initiative to promote zero plastic waste is an excellent one.
There are many very good ideas already in discussion to increase recycling of plastics: eliminating single use plastics, and reducing excess packaging in the food industry and in consumer products in general. It was noted in one of the presentations that the hierarchy of prevention begins with elimination, banning and informed substitution. In terms of elimination, one of the obvious places that plastics can be reduced is by banning the use of plastic bags in stores.
In Halifax, Nova Scotia the Atlantic Superstore on Quinpool Road has already completed a 10-year pilot study on diversion of plastic bags from landfills. This was done by banning the use of plastic shopping bags in that store. It has been a successful experiment and worth attention as a model study in Canada.
Usually, the store would use 36 cases of bags annually. Each case contains 1000 bags, at a cost of $1200.00 per month. Over the ten year period, this would have added up to 4320 cases of bags. That translates to 4,320,000 bags having been diverted from landfills. In addition to the diversion of plastics, this represented cost savings to the store of $156,000.
This Superstore continues to permanently ban the use of plastic shopping bags. The store manager also noted that the store is anxiously awaiting the reduction of plastics use through reducing excess packaging in food products supplied to the store. In addition to the reduction of excess packaging in food products, there should also be a reduction in the use of plastic vats and jugs of various designs that hold larger quantities of food for restaurants, cafeterias, hospitals and other institutions. This would help to reduce the level of microplastics currently consumed by humans.