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Assessing mercury health risks and federal mercury management
Petition: No. 183
Issue(s): Human health/environmental health, natural resources, toxic substances, and waste management
Petitioner(s): Pollution Probe
Date Received: 15 December 2006
Status: Completed
Summary: This petitioner would like to know if the government has undertaken any recent studies on the risks of mercury to human health and the environment. The petition asks if specific decisions have been made regarding health risks in vulnerable human and/or wildlife populations to low-level mercury exposure. It also requests a copy of Canada's plan for "full life-cycle management" of mercury as described in the federal Toxic Substances Management Policy and asks how the Canadian Environmental Protection Act is used to reduce mercury in Canada.
Federal Departments Responsible for Reply: Environment Canada, Health Canada, Natural Resources Canada
Petition
Environmental Petition
Office of the Auditor General of Canada
Commissioner of the Environment and Sustainable Development
240 Sparks Street
Ottawa, Ontario
K1A 0G6
petitions@oag-bvg.gc.ca
December 12, 2006
This petition is being submitted by Pollution Probe in accordance with the Auditor General Act for response by the Departments noted below.
Yours truly,
[Original signed by Quentin Chiotti]
Dr. Quentin Chiotti, Senior Scientist
Title of petition
Assessing Mercury Health Risks and Federal Mercury Management
Background information
Mercury emissions and releases continue to pose health risks to Canadians, particularly northern residents and those reliant on aquatic species for protein. Recent determinations from the US National Academy of Sciences and the Centre for Disease Control suggest that up to 300,000 American children are at risk from early exposure to mercury. Levels of mercury in the environment and exposures may be considerably higher in parts of Canada.
Specific questions
- Has Health Canada or Environment Canada undertaken any epidemiological/risk research in the past five years using recent research findings (e.g. NAS Study, Faroe Islands research) together with deposition and exposure patterns to determine whether mercury poses "unacceptable risks to the environment or human health?"
- Has a specific determination of health risks of chronic low level exposure to mercury been made in Canada for vulnerable human and/or wildlife populations and what scientific evidence has led to this determination?
- Please provide Canada's plan for "full life-cycle management" of mercury as described in the Toxic Substances Management Policy including long term targets for mercury reduction and domestic policies to achieve those targets, with specific reference to mercury in consumer products including thermostats, electrical switches and fever thermometers.
- How is CEPA being used to advance mercury reductions in Canada?
Federal departments and agencies that need to respond
Environment Canada
Health Canada
Contact information
Dr. Quentin Chiotti
Senior Scientist
Pollution Probe
qchiotti@pollutionprobe.org
416 926-1907
Joint Response: Environment Canada, Health Canada, Natural Resources Canada
17 April 2007
Dr. Quentin Chiotti
Senior Scientist
Pollution Probe
qchiotti@pollutionprobe.org
Dear Dr. Chiotti:
Thank you for your environmental petition No. 183, to the Commissioner of the Environment and Sustainable Development, concerning the Government of Canada's actions on assessing and managing the environmental and health risks associated with mercury. Your petition was received in Environment Canada on December 21, 2006.
Due to the nature of the issues raised in the petition, I am providing a joint response, on behalf of the Honourable Tony Clement, Minister of Health and the Honourable Gary Lunn, Minister of Natural Resources. We have considered your questions and responded to them in the order in which they were presented.
I appreciate the opportunity to respond to your petition and trust that you will find this information helpful.
Sincerely,
[Original signed by John Baird, Minister of the Environment]
John Baird, P.C., M.P.
|
c.c.: |
Mr. Ron Thompson, Interim Commissioner of the Environment and |
JOINT RESPONSE FROM THE DEPARTMENTS OF ENVIRONMENT,
HEALTH, AND NATURAL RESOURCES
PETITION SUBMITTED BY
POLLUTION PROBE
CONCERNING THE ASSESSMENT OF MERCURY
HEALTH RISKS AND FEDERAL MERCURY MANAGEMENT
Introduction
This document provides detailed answers to the questions raised in the petition received from Pollution Probe.
Question 1: Has Health Canada or Environment Canada undertaken any epidemiological/risk research in the past five years using recent research findings (e.g. NAS Study, Faroe Islands research) together with deposition and exposure patterns to determine whether mercury poses "unacceptable risks to the environment or human health?"
Response:
Any new data that is available and properly vetted is evaluated to determine if this new information can be used to amend the provisional Tolerable Daily Intake (pTDI) for methyl mercury. A provisional Tolerable Daily Intake (pTDI) of 0.47 microgram per kilogram of body weight per day for methyl mercury was established in 1972 by the Food and Agriculture Organization/World Health Organization Joint Expert Committee on Food Additives (JECFA). This level of dietary exposure was adopted by Health Canada, and was reaffirmed in 1989 for the general population. However, through further studies, JECFA cautioned that pregnant women and nursing mothers were likely to represent a greater risk from the adverse effects of methyl mercury (WHO, 1989). This concern was shared by the bureau of Chemical Safety in the Foods Directorate of Health Canada and, in 1998, the Foods Directorate of Health Canada reviewed the new studies and lowered the maximum pTDI for methyl mercury to 0.2 microgram per kilogram of body weight per day for pregnant women, women of childbearing age and young children. A recent evaluation by JECFA (WHO, 2003) derived a similar value (pTWI of 1.6 microgram per kilogram of body weight per week or 0.23 microgram per kilogram of body weight per day) to the Health Canada pTDI.
In addition, Health Canada is involved in the assessment of the health effects research in the Seychelles and Faroe Islands, and co-funds human health research in arctic Canada on the possible effects of environmental levels of contaminants such as PCBs, mercury and other contaminants with the Department of Indian Affairs and Northern Development under the federal Northern Contaminants Program (NCP). An Inuit infant cohort study in arctic Quebec is led by Dr. Eric Dewailly and colleagues at Laval University and is co-funded by the NCP, the province of Quebec and the United States National Institute of Environmental Health Sciences. The initial research results have confirmed higher exposures to PCBs, mercury and other environmental contaminants among Inuit and their children. Health effects research among the Inuit children is ongoing. These results from Arctic Canada / Quebec when integrated with the health effects research from other infant / child cohort studies in the Seychelles / Faroes Islands will allow for the best assessment of the impact of environmental exposures to contaminants such as mercury.
From a human health perspective, the main route of exposure to methyl mercury is in the diet, and more specifically from the consumption of certain species of fish and marine mammals. The Food Directorate of Health Canada has established a guideline level of 0.5 parts per million (ppm) for total mercury in domestically produced and imported fish considered to be the major source of dietary exposure. This guideline is enforced by the Canadian Food Inspection Agency (CFIA).
Health Canada gives the following advice concerning fish consumption:
- Based on the health benefits of fish consumption, Canada's Food Guide recommends that Canadians eat at least two Food Guide Servings of fish each week. Choose fish such as char, herring, mackerel, salmon, sardines or trout.
- Health Canada also provides the following advice for limiting exposure to mercury from certain types of fish:
- Consumers are advised to limit consumption of shark, swordfish and fresh or frozen tuna to a maximum of no more than one meal per week for children, pregnant women and women of childbearing age, consumption of these fish should be limited to no more than one meal per month.
- Women who are or who may become pregnant, or who are breastfeeding can eat up to four Food Guide Servings of canned albacore tuna each week. Children between one and four years old can eat up to one Food Guide Serving of albacore tuna each week. Children between five and eleven years old can eat up to two Food Guide Servings of albacore tuna each week. One Food Guide Serving is 75g, 2 ½ oz, 125 mL, or ½ cup.
- All shipments of canned tuna (both albacore/white and light) are regularly tested and usually found to be well below the Health Canada guideline of 0.5 ppm. However, since canned albacore tuna (which is the same as canned white tuna) in particular contains on average more mercury than canned light tuna, and since canned tuna as a convenient source of protein may be consumed more often than other types of fish, consumption advice is provided.
- For sport fish caught in local waters, consumers should be aware of any fish advisory from provincial and territorial authorities, and in some cases, the federal Department of Fisheries and Oceans, and Parks Canada.
- Additional information on these levels may be obtained at:
Canada's Food Guide - fish consumption:
http://hc-sc.gc.ca/fn-an/food-guide-aliment/choose-choix/meat-viande/index_e.html
Advice on canned albacore tuna:
http://hc-sc.gc.ca/ahc-asc/media/advisories-avis/2007/2007_14_e.html
These levels of exposure to methyl mercury are considered to be an acceptable risk to the Canadian public based on current scientific knowledge.
Question 2: Has a specific determination of health risks of chronic low level exposure to mercury been made in Canada for vulnerable human and/or wildlife populations and what scientific evidence has lead to this determination?
For human populations, as stated in the previous question, the pTDI for methyl mercury are considered protective of human health based on current scientific knowledge. Levels of exposure to sensitive (vulnerable) sub-populations is based on dietary exposure to methyl mercury. In the majority of vulnerable sub-populations in Canada, dietary intake for methyl mercury is well within the Health Canada guideline for protection of pregnant women, women of childbearing age and young children (vulnerable populations) at 0.2 microgram per kilogram of body weight per day. As indicated previously, Health Canada's evaluation of this guideline was supported by the evaluation undertaken by the Joint Expert Committee on Food Additives (JECFA) World Health Organization (WHO) in 2003. Both of these evaluations included the most recent exposure and effects data from the Faroe Islands and other studies.
A comprehensive nation-wide biomonitoring program which will include a large suite of contaminants (including mercury) will be launched in 2007, with the desired goal to provide up to date information on current exposures of these substances to the Canadian public.
With respect to wildlife populations, Environment Canada has been and continues to conduct research on assessing the levels and risks of exposure of fish and other wildlife populations to methylmercury. This includes:
- Measuring and estimating mercury concentrations in fish and their food webs (for example, in arctic char, marine mammals (seals), loons, etc.);
- Assessing the exposure to, and adverse effects of, methylmercury on the behaviour, reproduction and survival of some wildlife populations (for example, reproduction of loons in Nova Scotia); and
- Producing datasets and reviews on methylmercury levels and adverse effects in fish and wildlife for use by international colleagues in wildlife risk assessments.
In addition, Environment Canada researchers have been working with others to show how modeling can be used to demonstrate that mercury emissions reductions may have real benefits to certain wildlife populations that are currently exposed to higher levels of methylmercury.
Some references from recent years which include further detail on this work include:
An assessment of the toxicological significance of anthropogenic contaminants in Canadian arctic wildlife, Aaron T. Fisk, Cynthia A. de Wit, Mark Wayland, Zou Zou Kuzyk, Neil Burgess, et al., Science of the Total Environment 351–352 (2005) 57–93
Bioaccumulation of mercury in yellow perch (Perca flavescens) and common loons (Gavia immer) in relation to lake chemistry in Atlantic Canada, Neil M. Burgess & Keith A. Hobson, Hydrobiologia 567 (2006) 275–282
Biological mercury hotspots in the Northeastern United States and Southeastern Canada, David C. Evers, Young-Ji Han, Charles T. Driscoll, Neil C. Kamman, M. Wing Goodale, et al., BioScience, 57(1) (2007) 29-43
Contaminant Levels, Trends and Effects in the Biological Environment. Fisk, A.T., Hobbs, K and Muir, D.C.G. (Eds). 2003. In: Canadian Arctic Contaminants Assessment Report II, Indian and Northern Affairs Canada, Ottawa.
Effects of environmental methylmercury on the health of wild birds, mammals, and fish, Anton M. Scheuhammer, Michael W. Meyer, Mark B. Sandheinrich and Michael W. Murray, Ambio, in press
Elevated mercury levels in a declining population of ivory gulls in the Canadian Arctic, Birgit M. Braune, Mark L. Mallory, H. Grant Gilchrist, Baseline / Marine Pollution Bulletin 52 (2006) 969–987
Mercury and other Contaminants in Common Loons Breeding in Atlantic Canada, Neil M. Burgess, David C. Evers, Joseph D. Kaplan, Ecotoxicology 14 (2005) 241–252
Mercury in biota and its effects, Neil Burgess, Mercury: Sources, Measurements, Cycles and Effects Mineral Assoc. Canada, Short Course 34 (2005) 235-258
Mercury in Freshwater Fish of Northeast North America – A Geographic Perspective Based on Fish Tissue Monitoring Databases, Neil C Kamman, Neil M. Burgess, Charles T. Driscoll, Howard A. Simonin, Wing Goodale, et al., Ecotoxicology 14 (2005) 163–180
Mercury in brook trout, white perch, and yellow perch in Kejimkujik National Park, Clifford Drysdale, Neil M Burgess, Andre D'entremont, Jennifer Carter, Guy Brun, Mercury Cycling in a Wetland Dominated Ecosystem: A Multidisciplinary Study, Society of Environ Toxicol Chem (SETAC) (2005) 323-348
Patterns and Interpretation of Mercury Exposure in Freshwater Avian Communities in Northeastern North America, David C. Evers, Neil M. Burgess, Louise Champoux, Bart Hoskins, Andrew Major, et al., Ecotoxicology, 14, 193–221, 2005
2. a) Please provide Canada's plan for "full life-cycle management" of mercury as described in the Toxic Substances Management Policy including long term targets for mercury reduction and domestic policies to achieve those targets, with specific reference to mercury in consumer products including thermostats, electrical switches and fever thermometers.
The Government of Canada is involved in the development and implementation of several initiatives to help reduce mercury releases and manage risks associated with exposure to mercury throughout its life-cycle. The Government also continues to track and report on mercury reductions. Canada, through use of a number of legislative authorities by all levels of government, has achieved emissions reductions of about 80 percent since 1990 which is on a par with other Organisation for Economic Co-operation and Development (OECD) countries. It is important to note that mercury is regulated at the federal level by the Canadian Environmental Protection Act, 1999 (CEPA 1999), the Hazardous Products Act, the Pest Control Products Act, the Food and Drug Act, and the Fisheries Act.
Some recent examples of initiatives to reduce releases of mercury to the environment, which include targets and objectives, are the Canada-wide Standard (CWS) for Mercury Emissions from Coal-fired Electric Power Generation Plants, the Proposed Pollution Prevention Planning Notice Requiring the Preparation and Implementation of Pollution Prevention Plans in Respect of Mercury Releases from Mercury Switches in End-of-life Vehicles Processed by Steel Mills, and the Risk Management Strategy for Mercury-containing Products. These initiatives are described in more detail below.
Environment Canada has worked with the provinces and territories through the Canadian Council of Ministers of the Environment (CCME) to establish a Canada-wide Standard (CWS) for Mercury Emissions from Coal-fired Electric Power Generation Plants. Agreed to on October 11, 2006, the CWS is set to achieve by 2010 a 45 percent reduction of mercury emissions from existing plants, relative to 2003 emissions.
On December 9, 2006, Environment Canada published a Proposed Notice Requiring the Preparation and Implementation of Pollution Prevention Plans in Respect of Mercury Releases from Mercury Switches in End-of-life Vehicles Processed by Steel Mills in Part I of the Canada Gazette for a 60-day comment period. Comments received are being considered and a Final Notice is expected to be published in 2007. It is proposed that this action will require vehicle manufacturers and steel mills that process end-of-life vehicles to develop and implement pollution prevention plans to address mercury releases from switches found in cars. This measure will prevent the release of up to 10 tonnes of mercury into the environment over the next 10 years.
In addition, on December 20, 2006, Environment Canada published a Risk Management Strategy for Mercury-containing Products (RMS). The RMS proposes the development of a mix of risk management instruments to reduce mercury releases to the environment from products to the lowest possible levels. Although the RMS applies to mercury-containing products in general, it specifically addresses the use of mercury in dental amalgam, thermostats, switches/relays, lamps, batteries, measuring devices, thermometers and tire balancing products.
This RMS considers prohibition or limits for existing products and new products, labelling requirements, waste management and extended producer responsibility. Development of the proposed instrument(s) is scheduled to begin in fall 2007, following public consultations and a formal cost-benefit analysis of the proposed initiatives. The RMS is attached and is also available for comment until March 31st, 2007 on the web at: http://www.ec.gc.ca/ceparegistry/documents/part/Merc_RMS/index.cfm
Although domestic measures will continue to reduce the risk of mercury in Canada, efforts must also be made on a regional and global scale because a portion of the mercury in our lakes and soil originates from other countries via long-range atmospheric transport. Therefore, Canada continues to play a leadership role in the development and implementation of international mercury management initiatives including the Aarhus (Heavy Metals) Protocol under the United Nations Economic Commission for Europe Convention on Long-range Transboundary Air Pollution, the Arctic Council, the Great Lakes Binational Toxics Strategy, the North American Regional Action Plan on Mercury and various national and bilateral monitoring programs.
2. b) How is CEPA being used to advance mercury reductions in Canada?
Under CEPA 1999, the Government of Canada has carried out a number of risk management activities that target priority industrial and natural resource sectors and other sources of mercury. Risk management activities put in place for mercury under CEPA 1999 and through the CCME include:
