Federal government’s management of the impact of pesticides and toxic chemicals on the health of Canadians

Petition: 297

Issue(s): Agriculture, air quality, governance, human/environmental health, pesticides, and toxic substances

Petitioner(s): Frank Woodcock

Date Received: 2 February 2010

Status: Completed

Summary: The petitioner is concerned that Health Canada is not taking a precautionary approach to protecting the health of Canadians given the many pesticides and toxic chemicals that he alleges are found in the environment and in our food. The petitioner asks Health Canada and other federal departments for information about the amount of pesticides and toxic chemicals in the environment and their impact on the health of Canadians.

Federal Departments Responsible for Reply: Agriculture and Agri-Food Canada, Environment Canada, Health Canada

Petition

Frank Woodcock
35 Tyrell St.
Simcoe, ON
N3Y2H2
519 428 4031
f_woodcock@hotmail.com
January, 26, 2010

The Auditor General of Canada
Commissioner of the Environment and Sustainable Development
240 Sparks St.
Ottawa, ON
K1A 0G6

Attention, Petitions, please accept the following petition under the Auditor General Act.

At great cost to the country, Health Canada has failed to act in a preventative way to protect our environment. Mismanagement of policy makers at Health Canada has cost the Canadian taxpayer billions of dollars in environmental degradation, health costs, insurance claims, psychological health, legal bills and all related support costs for the above. Because Health Canada continues to prioritize the health of industry over the health of Canadians, mistakes are and will be systemic at Health Canada.

Sheila Weatherill, head of the Independent Listeriosis Investigative Review painted a realistic view of the failings of Health Canada in allowing listeriosis into the Canadian environment. Tainted meat was distributed throughout our environment killing 22 Canadians and leaving 33 others seriously ill.

In the Independent Listeriosis Review, one conclusion was that the Health Canada Listeria monocytogenes policy does not provide adequate direction on expected outcomes leaving room for interpretation by Industry. The lack of integration with CFIA policies creates gaps and overlaps. (Chap. 5, Rec. 11) In approving food additives and technologies, Health Canada has not been taking into account food safety considerations when assigning priorities of fast-tracking, for approval, these substances and processes. (Chapter 5, Rec. 12)1

Health Canada is corrupt according to Dr. Shiv Chopra in his book “CORRUPT TO THE CORE Memoirs of a Health Canada Whistleblower”. The graphic picture he provides of manager after manager trying to curie favour from upper management by interfering with those in charge of investigating new products, products that could be harmful to the health of Canadians. This corruption is not about bags of money handed over in an alley, it is the corruption of senior management concerned for their careers.

The examples put forward by Dr. Shiv Chopra are not the only ones on record. There is the case of Dr. John O’Connor who warned of a link between high levels of carcinogens and cancer in a community down river from the Alberta tarsands. Then there is Dr. Michele Brill Edwards, former senior physician at Health Canada, trained in clinical pharmacology and responsible for prescription drug approval in the 80’s and 90’s. Her account of the corruption at Health Canada mirrors that of Dr. Chopra. Different departments, same story, which you can listen to at: http://rabble.ca/podcasts/shows/boilingfrog/critical-dialogue-dr-michele-brill-edwards.

The government of Canada is responsible for protecting Canadians from harmful products. Our government does not test these products but leaves it to industry to provide proof of the product’s safety. The government’s current attitude is one of risk management as opposed to risk assessment. This means our government decides how many Canadians can die and how much money the government is willing to forego before a product is recalled. If Health Canada makes prevention the Number 1 Priority, lives and money will be saved.

Qualified personnel in health risk evaluation are being asked by Health Canada managers, usually unqualified in health risk evaluation, to approve questionable drugs. The picture that develops is of expensive well tailored suits of lawyers, PR men, industry scientists, accountants and upper managers with weight of evidence studies, parking their limos in front of Health Canada and ascending to the top floors for private meetings with the upper echelons of management. Does money change hands? No. What happens is a subtle dialogue of pressure. Whether political, financial, economic or psychological, it matters not, what matters is the pressure down the chain of command, pressure that their product is awaiting approval but is being unnecessarily held up. What isn’t told is how Industry drags its feet in the approval process making the process longer than it should and open to criticism of unnecessary delay. Subtle, very subtle.

According to Dr. Shiv Chopra, upper management at Health Canada control the drug approval process through the use of “acting positions”. Ambitious people are promoted temporarily to an acting position. The permanence of the job seems to depend on proving oneself. Tenure is illusive. The employees in the acting position know what they have to do to keep their position. Nothing needs to be said because upwardly mobile personnel are aware of the subtleties of direction from above and they know that interpreting such subtleties is the secret of promotion.

Another factor is that upper management rarely promote technically qualified people to management. Keeping qualified evaluators out of the seats of power muffles the voices of those who see the danger in certain products and are morally and ethically bound to act accordingly. In tandem, technically qualified personnel who raise objections to a product can be taken off a file to be replaced by a more pliant person and the whole process starts again.

One only has to look into the history of GM foods. "GENETIC ROULETTE – The documented health risks of genetically engineered foods” by Jeffrey M. Smith shows how GM foods passed through all the regulatory hoops without providing conclusive proof of the safety of their product. The EU wasn’t fooled like the government of Canada. Canada accepted GM foods, the EU didn’t and as a result Canada has lost lucrative trading opportunities with Europe.

Canada experienced a predictable backlash from the world with our first Bovine Spongiform Encephalopathy (BSE) case in 2003, a Health Canada mistake which cost and is costing Canadian taxpayers billions of dollars. Even after the United Kingdom’s experience, Canada still feeds animals the renderings of other animals. This is another example of Health Canada being unable to learn from prior mistakes.

Previously Health Canada approved registration of Triffid flax. Recently Canadian flax exports to the EU have been stopped because the Triffid flax (banned in the EU) containing a genetically modified gene, has been found in shipments to Europe. The EU buys 70% of Canadian flax, a market that could be closed for the next 3 years jeopardizing the $320 million industry. This is another expensive Health Canada mistake to be responded to with an “Oops” and, as usual, no government official will be held accountable.

Cell phone technology was exempted from pre-market testing. The story is detailed in my petition #235B. As a result this technology is costing the health care system millions to attend those suffering from Electromagnetic Sensitivity (EMS) and related illnesses. Soon, when electrosmog is considered an environmental pollutant and carcinogen, those at the Consumer and Clinical Radiation Protection Bureau (CCRPB) will say ,”Oops” and no one held responsible.

The government of Canada spent and has/is spending millions of dollars to disparage Dr. Chopra, to solve the world boycott on Canadian beef, to lobby the EU to accept our GM foods and the list goes on. All this money wasted due to upper management decisions. The money spent defending inept managers could solve the doctor crisis if not child poverty in Canada and go a long way to provide health care to 33,311,389 Canadians.

If every time Health Canada made a mistake, like approving Vioxx, and those involved were fired, it would not take long for a true Precautionary Principle to be utilized.

In a letter sent to me December 2, 2009, Leona Aglukkaq, Minister of Health states, “Health Canada’s mission is to help the people of Canada maintain and improve their health. Prudence and careful decision making are critical to the Department’s ability to achieve its objectives, and therefore, Health Canada has adopted a precautionary approach in its regulatory functions.” and in a letter sent to me December 3, 2009, Leona Aglukkaq, Minister of Health states, “Health Canada does its utmost to inform Canadians about any credible potential threats to human health. Where there is a conflict between the health of Canadians and the interests of industry, Health Canada will always focus on the health of Canadians.”

The Minister of Health at the time of thalidomide probably had the same sentiments and let us not forget Vioxx, Distilben, Trasyol, Climacteron, Tequin, Prexige, Permax, Zelnorm, Bextra and Nefazodone.

I accept that the Minister and her department believe in her words but their decisions prove otherwise. I am certain the vast majority of those working for Health Canada have the health of Canadians as their Number 1 Priority but for upper management I have a different assessment. If prevention and the Precautionary Principle were to become the number one priority of Health Canada, none of the above costly decisions would have been made and the health of Canadians and the environment would be improved.

Five stressors of Environmental Illnesses are a) registered pesticides used in agriculture, forestry and industry, b) permitted use of other chemicals, compounds and by-products of chemical industries c) electromagnetic radiation d) food processing and e) Health Canada.

The outcomes of these stressors are rising rates of occurrence for environmental related illnesses such as: Multiple Chemical Sensitivity (MCS), Electrical Sensitivity and Hypersensitivity (EHS), Chronic Fatigue Syndrome, Fibromyalgia, Cancer (including brain tumors, especially children’s), childhood brain and spinal cord tumors, Acoustic Neuroma, Gliomas, Ureal Melanoma, Obesity, Diabetes, Type 2 Diabetes in children, Hypoglycemia, Irritable Bowel Syndrome, Chrone’s Disease, Leaky Gut Syndrome, Allergies, Celiac Disease, Autism Spectrum Disorder (ASD) (including Pervasive Developmental Disorder), Depression, increased blood brain barrier permeability, Anxiety, Bipolar Disorder, Parkinson’s, Thyroid Disease, Attention Deficit Disorder (ADD & ADHT), early onset Alzheimer's, Arthritis, Rheumatoid Arthritis, Asthma, sleep disorders (Sleep Apnea, Insomnia), Anaphylaxis, Arrhythmia, Hypertension, Hormone Disruption, Tinnitus, Morgellons Disease, Eczema, birth defects, fertility impairment, precocious puberty, C-difficile, Vancomycin-resistant staph aureus (VRSA) and others.

The first stressor of Environmental Illnesses are registered pesticides used in agriculture, forestry and industry. Some have already been taken off the market after initial approval. If health prevention was the Number 1 Priority, no approval would have been given in the first place and the health of Canadians greatly improved. Such pesticides are: DDT, Aldrin, Dieldrin, Chlordane, Chlorpyrifos, Alachlor, Fenitrothion and 2,4,5-T. Toxic pesticides still in use are 2,4,-D, 1,3,-D, Atrazine, Glyphosate, Alachlor (banned in EU), Endothall, Lindane, Methoxychlor, Nitrates, Ziram, Captan, Methyl Bromide, Loxynil, Amitrol, Iprodion and Furadon to name a few.

The second stressor of Environmental Illnesses is the permitted use of toxic chemicals and industrial chemical by-products and compounds which means regular exposure of Canadians to between 3,750 and 7,500 carcinogens. Cancer causing additives Formaldehyde, Phenol. Benzene, Toluene and Xylene are found in most common household cleaners, cosmetics, beverages, fabrics and cigarette smoke. Flame retardants Polybrominated diphenyl ethers (PBDE), structurally akin to PCB’s, have been used in a wide array of products, including building materials, electronics, furnishings, motor vehicles, airplanes, plastics, polyurethane foams, and textiles. Then there are the environmental concerns over the fuel additive methyl tertiary-butyl ether (MTBE), lead in paints and gasoline and PCB’s, not to mention Arsenic, Beryllium, Cadmium, Hexavelent Chromium (VI) Compounds, Ethylene Oxide, Nickel, Radon, Lead, Vinyl Chloride, Bisphenol A, Perchlorate, Polychlorinated Naphtalenes (PCNs), Phtalates (DEHP), Mercury, Methylmercury (Minimata disease), Organochlorine – Parabens, Alkylphenols, and Triclosan, EDB (1,2-Dibromoethane), Hexachloro Benzene, Dioxin, Parabens, Tetrachloroehtylen and Carbofuran. Thalidomide, Vioxx, Trasyol, Climacteron, Tequin, Prexige, Permax, Zelnorm, Bextra, Nefazodone and Diethylstilbestrol (DES) have been problematic.

The third stressor of Environmental Illnesses is electromagnetic radiation. On a daily basis we are exposed to Electromagnetic Fields (EMF) or electrosmog. From WiFi to cell phone technology to cordless phones to compact florescent light bulbs to CAT scans to dimmer switches we are bombarded with accumulating radiation. These stresses are not only in our homes but in the environment. Dirty electricity or transients are by-products of technologies that lower their electrical output creating a wildly fluctuating electromagnetic field that radiates our home environment and backs up our wiring all the way to the utility, affecting everyone in between.

The forth stressor of Environmental Illnesses is our food chain; what is added to the soil, what is taken from the soil, what ends up in our soil, what drains off of our soil, what is added to our food, and the effects of these factors on our internal environment - our bodies. Our food history includes the additives Agene, colourings butter yellow-green1-green 2-orange 1-orange 2-orange B-red 1-red 2-red 4-red 32-sudan 1-violet 1-yellow 1-yellow 2-yellow 3-yellow 4, cinnamyl anthranilate, cobalt salts, coumarin, cyclamate, dulcin, ethylene glycol, monochloroacetic acid, nordihydroguaiaretic acid (NDGA), oil of calamus, polyoxyethylene-8-stearate (Myrj 45), safrole, diacetyl, potassium bromate and thiourea.

These additives confirm Health Canada’s record of favouring industry over prevention. Furthermore there are other food health concerns including, artificial colourings blue1-blue 2-green 3-red 3-yellow 6, sodium, refined sugar, high fructose corn syrup, hydrogenated vegetable oil plus trans fats, propyl gallate, sodium nitrite, genetically modified foodstuffs, monosodium glutamate, milk protein concentrates (MPC’s), organic contaminants, nanoparticles and atomically modified organisms, arsenic fed chickens, inspection criteria, processing and labeling, akrylamide, addition of supplements like asparaginase to junk food, bovine growth hormone (BGH), bovine spongiform encephalopathy (BSE), feeding corn to herbivores, pigs and chickens, feeding herbivores the remains of other cattle in the form of meat and bone meal (MBM), feeding pigs and chickens slaughterhouse waste, antibiotics in animals and vegetables, hormones in animals including (estradiol and zeranol), listeriosis, contaminants that enter the environment and accumulate in animal fats and animal-borne bacteria (Methicillin-resistant Staphylococcus aureus (MRSA), Vancomycin-resistant enterococcus (VRE), Salmonella Typhimurium, E. coli, Clostidium difficile, Campylobacter).

The fifth stressor is the policy process at Health Canada. If Health Canada could conceive of; cause and effects as opposed to cause and effect, understood that for every action there is a chain reaction, the Gaia hypothesis, the butterfly effect or any other law of Nature, then a true Precautionary Principle could be utilized leading to a preventative philosophy rather than their current business and reactive mindset. The irony is that if Health Canada were a business it would be continually operating in the red, it would be financially unsustainable. One of Health Canada’s top policy priorities, according to their history, is that of waiting for the United States to initiate policy as opposed to following the far more cautious European Union. Prevention and environmental sustainability should be Number 1 and 2 Policy Priorities of Health Canada. If this were so, Environmental Illnesses could be reduced at a great savings for the taxpayer and the environment.

Question 1 - How does the Minister reconcile the above list of concerns and mistakes with her own words?
Question 2 - Would Health Canada consider the rises in the rates of the above ailments over time to be reflective of how successful Health Canada has been at protecting the environmental health of Canadians?
Question 3 - How have the rates of the incidence of Environmental Illnesses changed since 50 years ago and to the closest billion dollars what is the yearly cost to the Canadian taxpayer of Environmental Illnesses?
Question 4 - If prevention and the Precautionary Principle is a high priority in Canada, why is the list of products, pesticides, chemicals and foodstuffs banned by the EU so much longer than those banned the Canadian government?
Question 5
- Is it correct that there were only 350 pesticides allowed in the EU and that in 2009 an additional 22 chemicals were banned and that the eliminated pesticides have studies showing a link to cancer, reproductive trouble, or genetic damage? How many pesticides are allowed by our federal government?
Question 6 - If Canadians followed a balanced organic diet and refrained from eating refined sugars, high fructose corn syrup, bleached flour and vegetable oils; a regular program of exercise; a meditative mental and emotional program; supplements based on blood analysis; and refrained from smoking, illicit drugs and alcohol, what would be the savings of such a program in health care costs to the Canadian taxpayer, to the closest billion dollars? If Canadians followed such a program, how many doctors would become available to attend Canadians who are without doctors? Would the above savings eliminate child poverty in Canada?
Question 7 - If prevention and the Precautionary Principle is a high priority in Canada, why are up to 80% of cancers influenced by environmental factors?
Question 8 – Just when Canadians thought trans fats were a thing of the past Health Canada has found a way to regenerate the industry. A cancer causing substance called akrylamide has been quietly known for several years. It does not exist in nature but is generated when making potato chips and French fries. Health Canada has plans to allow industry to add the leukemia fighter asparaginase to these foods to combat acrylamide. Is this is another example of choosing industry over the health of Canadians?
Question 9 - Obesity is the second-highest risk factor for cancer. Milk from grass fed cows is perfectly balanced in omega-3 and omega-6 fatty acids but milk from cows fed corn; soy and wheat contain practically no omega-3 fatty acids but are high in omega-6s. Omega-3s are involved in developing the nervous system, making cell membranes more flexible and reducing inflammation. Omega-6s stimulate the production of fatty cells from birth onwards. Is the change in the character of milk since 1950 responsible for infant obesity?
Question 10 - Is it correct that cancer-inducing substances accumulate in human fat?
Question 11 - Is it correct that in the past 50 years, among the cancers that have increased the most are those in tissues that contain or are surrounded by fat: the prostate, colon, breast, ovaries, and lymphatic system?
Question 12 - Is it correct that in biology and medicine it is known that many toxic substances present in the environment play roles in the appearance of the first cancer cells in an organism, and then in their transformation into a more aggressive tumour? Is it correct that the process goes on after the disease has started? Is it important to seek protection against toxins that encourage tumour growth, whether we are healthy or already affected by the disease?
Question 13 - Is it correct that compared to other crops, corn and soy use more water, fertilizers, and herbicides?
Question 14 - Is it correct that the annual production of synthetic chemicals has risen from a million tons in 1930 to two hundred millions tons today?
Question 15 - Is it correct that pollutants are bioaccumulative?
Question 16 - Is it correct that carcinogens are found in many everyday products, for example certain plastics, lubricants, resins, glues, dyes, detergents, pesticides, dry cleaning, women’s deodorants and antiperspirants, cosmetics, shampoo, lotions, gels, hair dye, nail polish, household pesticides and household cleaning products like liquid detergents, disinfectants and toilet bowl cleaners?
Question 17 - Is it correct that the most contaminated fruits and vegetables are: apples, pears, peaches, nectarines, strawberries, cherries, raspberries, grapes, peppers, celery, green beans, potatoes, spinach, lettuce, cucumbers, squash and pumpkins?
Question 18 - Has the disappearance of honey bees, songbirds and amphibians been associated with environmental factors?
Question 19 - The government’s current attitude is one of risk management as opposed to risk assessment. This means our government decides how many Canadians can die and how much money the government is willing to forego before a product is recalled. If Health Canada makes prevention the Number 1 Priority, lives and money will be saved. How correct is this statement?
Question 20 - Since Health Canada has adopted a precautionary approach in its regulatory functions and since Health Canada does its utmost to inform Canadians about any credible potential threats to human health and since whenever there is a conflict between the health of Canadians and the interests of industry, Health Canada will always focus on the health of Canadians, why is the state of health of Canadians deteriorating? Who is tracking this deterioration, who is tracking the accumulated cost of these environmental mistakes and who in government is advocating for Canadians’ health when it comes to the environment? What is their success rate?

[Original signed by Frank Woodcock]
.........................................................

Frank Woodcock

1 http://www.listeriosis-listeriose.investigation-enquete.gc.ca/lirs_rpt_e.pdf

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Minister's Response: Agriculture and Agri-Food Canada

4 May 2010

Mr. Frank Woodcock
35 Tyrell Street
Simcoe, Ontario N3Y 2H2

Dear Mr. Woodcock:

I am writing in response to Environmental Petition No. 297, which you submitted pursuant to section 22 of the Auditor General Act. On February 17, 2010, the office of the Commissioner of the Environment and Sustainable Development forwarded the petition to the Honourable Leona Aglukkaq, Minister of Health, the Honourable Jim Prentice, Minister of the Environment, and me for response. Our departments will be responding separately.

In your petition, you posed 20 questions, one of which relate to my portfolio. Enclosed, please find Agriculture and Agri-Food Canada’s response to question 13 of your petition.

Thank you for your interest in this important matter.

Sincerely,

[Original signed by Gerry Ritz, Minister of Agriculture and Agri-Food and Minister for the Canadian Wheat Board]

Gerry Ritz, PC, MP

Enclosure

c.c.: Mr. Scott Vaughan
Commissioner of the Environment and Sustainable Development

The Honourable Leona Aglukkaq, PC, MP

The Honourable Jim Prentice, PC, QC, MP


ENVIRONMENTAL PETITION 297

Question 13: Is it correct that, compared to other crops, corn and soy use more water, fertilizers, and herbicides?

Response:

Crop water use varies significantly with growing conditions so it is difficult to make meaningful comparisons. Weather conditions, together with available soil moisture, and the type of management (for example organic versus conventional) all have a large impact on water use. Under Canadian growing conditions soybeans require around 5 600 cubic meters of water per hectare through the growing season, and corn requires slightly less (generally around 5 200 cubic meters). These numbers, however, are comparable with a number of other horticultural crops (for example, squash and pumpkins) and even some agronomic crops (for example, sugar beet). Fertilizer and herbicide use varies depending on production system. As a legume, soybeans fix nitrogen providing a nitrogen ‘credit’ to the current and future crops (since corn and soybeans are often grown in rotation, the nitrogen contributed by soybeans reduces the amount of nitrogen fertilizer that would be required for a corn crop alone). Weed pressure (and the need for herbicides in conventional production) is too variable to be able to provide meaningful comparisons with other crops.

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Minister's Response: Environment Canada

10 June 2010

Mr. Frank Woodcock
35 Tyrell Street
Simcoe ON N3Y 2H2

Dear Mr. Woodcock:

I am writing in response to your Environmental Petition No. 297, pursuant to section 22 of the Auditor General Act, regarding environment-related illnesses. Your petition was received in Environment Canada on February 17, 2010.

Enclosed you will find Environment Canada’s response to your petition. I understand that the Minister of Agriculture and Agri-Food, the Honourable Gerry Ritz, and the Minister of Health, the Honourable Leona Aglukkaq, will be responding separately to questions that fall under their respective mandates.

I appreciate this opportunity to respond to your petition, and trust that you will find this information helpful.

Sincerely,

[Original signed by Jim Prentice, Minister of the Environment]

The Honourable Jim Prentice, P.C., Q.C., M.P.

Enclosure

c.c.: The Honourable Gerry Ritz, P.C., M.P.
The Honourable Leona Aglukkaq, P.C., M.P.
Mr. Scott Vaughan, Commissioner of the Environment and Sustainable Development


Environment Canada’s response to Environmental Petition No. 297, regarding environment-related illnesses

Question 4: If prevention and the Precautionary Principle is a high priority in Canada, why is the list of products, pesticides, chemicals and foodstuffs banned by the EU so much longer than those banned [by] the Canadian government?

Response: In Canada, chemicals are managed under a number of Acts, with the Canadian Environmental Protection Act, 1999 (CEPA 1999) being the primary legislation for addressing pollution. The Act is very comprehensive in identifying the sources of substances to be considered for assessment and management. These sources include substances identified through public nominations, New Substances Notifications, emerging science and monitoring, decisions of other jurisdictions, and those identified through a recent categorization process of existing substances.

At the same time, however, it is not surprising that there can be differences between the number of substances “banned” in various jurisdictions. Although Canada, the European Union and the United States, among others, have adopted equivalent evaluation criteria for chemicals—Organisation for Economic Co-operation and Development members use similar tools for testing chemicals to identify hazards, determine exposure and assess risks—not all countries have the same chemicals in commerce, and exposures to specific chemicals can differ from country to country.

Furthermore, jurisdictions generally manage risks posed by chemicals through the legislative tools they have available. CEPA 1999 allows for a wide range of measures to be taken, including those focused on preventing pollution. Therefore, risk management efforts are not limited to bans.

It should also be noted that in 2006 the Government of Canada introduced the Chemicals Management Plan. With this initiative, Canada established itself as a world leader in taking action to systematically assess and, if required, manage any risks associated with substances introduced prior to the implementation of pre-market approvals processes.

Question 14: Is it correct that the annual production of synthetic chemicals has risen from a million tons in 1930 to two hundred millions tons today?

Response: Although it is certain that the production of chemicals will have increased from 1930 to today, data identifying the exact change is not readily available.

Since 1950, Statistics Canada has conducted a monthly Survey of Industrial Chemicals and Synthetic Resins, which measures the quantities of selected industrial chemicals and virgin resins produced by Canadian manufacturers. However, this survey does not cover all chemicals and businesses (in particular, small- and medium-sized enterprises are excluded) and some data is not made public for business confidentiality purposes. For these reasons, it does not provide estimated production quantities for all industrial chemicals and virgin resins produced in Canada. For survey information visit the website at www.statcan.gc.ca/bsolc/olc-cel/olc-cel?catno=46-002-XWE&lang=eng.

The production of industrial chemicals is not generally aggregated in “tons,” because of the heterogeneous nature of the chemicals and the lack of comparability among products. Statistics Canada does track the value of yearly shipments of industrial chemicals. In 1992, the value of shipments of chemicals and chemical products was approximately C$23.6 billion. In 2008, the most recent year for which data is available, the value of shipments was approximately C$51 billion.

Question 15: Is it correct that pollutants are bioaccumulative?

Response: The Persistence and Bioaccumulation Regulations set the criteria that will be used to determine if a substance is persistent or bioaccumulative under certain sections of CEPA 1999. These criteria are those in the Toxic Substances Management Policy that was adopted by the federal government in 1995. The Regulations are posted on the CEPA Registry website at www.ec.gc.ca/ceparegistry/Regulations.

Additional information on pollutants and chemicals management can be found on the following two Environment Canada websites:
Pollutants: www.ec.gc.ca/pollution/default.asp?lang=En&n=77BC2971-1
Chemicals management: www.ec.gc.ca/toxiques-toxics/default.asp?lang=
En&n=97324D33-1

Question 18: Has the disappearance of honey bees, songbirds and amphibians been associated with environmental factors?

Response: In many instances, the disappearance of honey bees, songbirds and amphibians can be attributed to environmental factors. In general, wildlife diseases, changes to habitat (both natural and human induced), exposure to toxic substances and/or effects from a changing climate can all affect any one species or species group. Because of the wide range of species and the variety of ecological niches these species occupy, it would be very difficult to figure out a single causative factor limiting each population in decline, unless considered on a species-by-species basis.

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Minister's Response: Health Canada

16 June 2010

Mr. Frank Woodcock
35 Tyrell Street
Simcoe, Ontario N3Y 2H2

Dear Mr. Woodcock:

This is in response to your environmental petition no. 297 of January 26, 2010, addressed to the Commissioner of the Environment and Sustainable Development (CESD).

In your petition, you raise questions as to Health Canada’s policies and actions in relation to banned products, pesticides, chemicals and foodstuffs in Canada, as well as the prevalence of cancer caused by environmental factors.

I am pleased to provide you with the enclosed Health Portfolio response to your petition. I understand that the Minister of the Environment and the Minister of Agriculture and Agri-Food and Minister for the Canadian Wheat Board will be responding separately to questions that come under the purview of their respective departments.

I appreciate your interest in this important matter, and I hope that you will find this information useful.

Sincerely,

[Original document signed by Leona Aglukkaq, Minister of Health Canada]

Leona Aglukkaq

Enclosure

c.c. Mr. Scott Vaughan, CESD
The Honourable Gerry Ritz, P.C., M.P.
The Honourable Jim Prentice, P.C., Q.C., M.P.


Health Canada Response to
Environmental Petition No. 297 filed by Mr. Frank Woodcock
 under Section 22 of the Auditor General Act
Received February 17, 2010

Environmental Health of Canadians

June 17, 2010

Minister of Health

Q1:How does the Minister reconcile the above list of concerns and mistakes with her own words?

In the preamble to this question you referenced five stressors of Environmental Illnesses, each are addressed below.

Pesticides Used in Agriculture, Forestry and Industry

Health Canada is confident that the pesticides registered for use in Canada will not harm people or the environment when used according to label directions.

Health Canada conducts specific risk assessments for sensitive sub-populations including children and pregnant women, taking their unique physiological characteristics into account.

Before a pesticide is allowed to be used or sold in Canada, it must undergo a rigorous scientific assessment process which provides reasonable certainty that no harm, including chronic effects such as cancer, will occur when pesticides are used according to label directions. All pesticides registered in Canada, including for agricultural, forestry and domestic uses, undergo this level of scrutiny.

Other Chemicals, Compounds and By-products of Chemical Industries

Created in the late 1980s and renewed and strengthened in 1999, the Canadian Environmental Protection Act, 1999 (CEPA) is Canada's overarching environmental legislation. Jointly administered by Environment Canada and Health Canada, CEPA covers a range of activities that can affect human health and the environment, and addresses pollution issues not covered by other federal laws.

Since 1994, Canada has had in place a risk assessment and management regime under CEPA for all new manufactured or imported industrial substances. Through the New Substances Notification Program, government scientists assess over 500 chemical substances a year. Canada prohibits or puts restrictions on the use or disposal of new substances that could pose a risk to human health and/or the environment.

Approximately 23,000 chemical substances were in commerce in Canada at the time of the implementation of the New Substances Notification Program. CEPA recognizes the importance of assessing and managing these existing substances. Assessment activities have led to 85 individual and classes of substances (representing approximately 700 discrete substances) being added to Schedule 1 of CEPA (List of Toxic Substances). This has allowed Environment Canada and Health Canada to place controls on these chemical substances to manage their health and environmental risks.

CEPA required the Government of Canada, by law, to prioritize (or "categorize") the approximately 23,000 existing substances for their potential to harm human health and/or the environment. This task was completed in September 2006, making Canada the first country in the world to prioritize substances that have not been previously subject to formal assessment.

In December 2006, the Government of Canada announced the Chemicals Management Plan (CMP). An important element of this Plan is assessment and management, as appropriate, of the 4,300 substances identified as priorities by 2020. The CMP also includes other elements such as accelerated re-evaluation of older pesticides, mandatory ingredient labelling of cosmetics, regulations to address environmental risks posed by pharmaceuticals and personal care products, enhanced management of environmental contaminants in food, and increased monitoring, surveillance and research1.

Electromagnetic Radiation

Electromagnetic fields (EMFs), such as those emitted from wireless communication devices (Wi-Fi networking equipment, cell phones, cell phone towers and cordless phones) are regulated by Industry Canada. Industry Canada requires that these devices comply with safety standards, which use human exposure guidelines found in Health Canada's document Limits of Human Exposure to Radiofrequency Electromagnetic Energy in the Frequency Range from 3 kHz to 300 GHz – Safety Code 6 (2009). It should be noted that the limits recommended in Safety Code 6 for general public exposure are designed to provide protection for all age groups on a continuous basis. Health Canada has done a thorough review of scientific data in order to develop Safety Code 6 and concluded that there is no evidence of any known adverse health effects at exposure levels below the limits prescribed in the Safety Code.

With regard to compact fluorescent lamps (CFLs), Health Canada has recently measured EMFs from a representative sample of 30 CFLs and investigated whether these lamps were a source of so-called “dirty electricity”. "Dirty electricity" is the small amount of high frequency voltage that leaks back into the house wiring from the CFL. The results showed that EMFs arising from the use of these lamps are below Canadian and international exposure standards that are based on established effects. Further, “dirty electricity” fields were found to be insignificant, when compared with those produced by CFLs. Based on these findings, Health Canada does not consider the EMFs from CFLs to be a health risk and this conclusion is in agreement with current international scientific opinion. Information about Health Canada’s survey of EMFs from CFLs is available at: <http://oee.nrcan.gc.ca/residential/personal/cfl-impact-study.cfm>.

While the symptoms attributed to Electromagnetic Sensitivity (EMS) conditions are real, numerous scientific studies to date have failed to demonstrate that they are associated with EMF exposure. In studies where subjects were intentionally exposed to EMFs, the majority of individuals were unable to detect whether the fields were present or showed symptoms which did not correlate with their actual exposure condition. A recent review by the European Commission's Scientific Committee on Emerging and Newly Identified Health Risks has indicated that the expectation of harm may play a role in symptom formation2.

Food Processing

The focus and priority of Health Canada is to help the people of Canada maintain and improve their health. The Department remains committed to making prudent and careful decisions supported by sound scientific evidence. Recently, the Government of Canada announced additional investments to help ensure that Canada has the tools needed to make these decisions. Investments in the Food and Consumer Safety Action Plan and actions to improve the food safety system, are designed with prevention of health risks as a top priority. These investments will help Canada stay abreast of scientific advances and emerging new knowledge that would point to credible emerging hazards to human health and would support the best decisions possible. Health Canada continues to strive to ensure that the health of Canadians is not compromised, and that they have the information needed to enjoy safe health products and foods.

Health Canada

Health Canada’s mission is to help the people of Canada maintain and improve their health. Prudence and careful decision making are critical to the Department’s ability to achieve its objectives, and therefore, Health Canada has adopted a precautionary approach in its regulatory functions.

The Government of Canada endorses the application of a precautionary approach, which is described in A Framework for the Application of Precaution in Science-Based Decision Making About Risk, 20033. This framework provides guiding principles for the application of precaution to science-based decision making regarding federal regulatory activity designed to protect health, safety, and the environment and the conservation of natural resources.

This document acknowledges that governments can rarely act on the basis of full scientific certainty and they cannot guarantee zero risk. Therefore, governments need to address new and emerging risks and manage issues where there is significant scientific uncertainty.

The framework outlines five general principles of application.

  • The application of precaution is a legitimate and distinctive decision-making approach within risk management.
  • It is legitimate that decisions be guided by society’s chosen level of protection against risk.
  • Sound scientific information and its evaluation must be the basis for applying precaution; the scientific information base and responsibility for producing it may shift as knowledge evolves.
  • Mechanisms should exist for re-evaluating the basis for decisions and for providing a transparent process for further consideration.
  • A high degree of transparency, clear accountability and meaningful public involvement are appropriate.

This framework also contains five principles for precautionary measures:

  • Precautionary measures should be subject to reconsideration, on the basis of the evolution of science, technology and society’s chosen level of protection.
  • Precautionary measures should be proportional to the potential severity of the risk being addressed and to society’s chosen level of protection.
  • Precautionary measures should be non-discriminatory and consistent with measures taken in similar circumstances.
  • Precautionary measures should be cost-effective, with the goal of generating (i) an overall net benefit for society at least cost, and (ii) efficiency in the choice of measures.
  • Where more than one option reasonably meets the above characteristics, then the least trade-restrictive measure should be applied.

This Government of Canada document is intended to assist in achieving coherent and cohesive application of precaution to risk decision making where there is a lack of scientific certainty. Departmental and agency officials consider this framework and its guiding principles in decision making and to develop guidance for the application of precaution in their particular area. Health Canada has done this in part through the development of the Health Canada Decision-Making Framework for Identifying, Assessing, and Managing Health Risks4. This document recognizes that decisions are often made in the presence of considerable scientific uncertainty. A precautionary approach to decision making emphasizes the need to take timely and appropriately preventative action, even in the absence of a full scientific demonstration of cause and effect. A lack of full scientific certainty should not be used as a reason not to take preventive measures when reasonable evidence indicates that a situation could cause a significant adverse health effect.

A precautionary approach is incorporated in Health Canada’s more recent legislation, such as the Pest Control Products Act, which states in Section 20 that:

Where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent adverse health impact or environmental degradation5.

In the Canadian Environmental Protection Act 1999 (CEPA), the following statement in the preamble gives guidance on the use of precaution:

Whereas the Government of Canada is committed to implementing the precautionary principle that, where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation6.

In addition, Part 1 of CEPA requires that the National Advisory Committee use a precautionary approach in its advice and recommendations, as is evidenced below:

(1) For the purpose of enabling national action to be carried out and taking cooperative action in matters affecting the environment and for the purpose of avoiding duplication in regulatory activity among governments, the Minister shall establish a National Advisory Committee.

(1.1) In giving its advice and recommendations, the Committee shall use the precautionary principle.

(2) The Committee shall consist of the following members:

(a) one representative for each of the Ministers;

(b) one representative of the government of each of the provinces; and

(c) subject to subsection (3), not more than six representatives of aboriginal governments, to be selected on the following regional basis...

More importantly, in section 76.1, the Act requires that when the Ministers (Environment and Health) are conducting and interpreting the results of

a) a screening assessment;
b) a review of a decision of another jurisdiction; or
c) an assessment of a substance on the Priority Substance List

they shall apply the precautionary principle.

The proposed Canada Consumer Product Safety Act, Bill C-36, which was passed in the House of Commons before Parliament prorogued and which the Government has stated it will reintroduce in its original form, contains the following statement in the preamble:

Whereas the Parliament of Canada recognizes that a lack of full scientific certainty is not to be used as a reason for postponing measures that prevent adverse effects on human health if those effects could be serious or irreversible.

Health Canada has demonstrated that it uses a precautionary approach in risk-based decision making. For example, Canada was the first country in the world to propose a prohibition on the import and sale of polycarbonate baby bottles containing Bisphenol A (BPA). Although the scientific evidence is not yet conclusive, Health Canada applied a precautionary approach in announcing its intention to regulate some products that contain BPA to further protect the health and safety of newborns and infants who could be exposed to chemicals that could affect their early development.

The Cabinet Directive on Streamlining Regulation also includes a precautionary approach. It applies to all departments and agencies involved in the federal regulatory process, and government officials are responsible for following this directive in all stages of the regulatory lifecycle. The Directive commits the federal government to:

  • protect and advance the public interest in health, safety and security, the quality of the environment, and the social and economic well-being of Canadians, as expressed by Parliament in legislation; and
  • make decisions based on evidence and the best available knowledge and science in Canada and worldwide, while recognizing that the application of precaution may be necessary when there is an absence of full scientific certainty and a risk of serious or irreversible harm.

This Directive also elucidates a precautionary approach, as it states that:

When there is a risk of serious or irreversible harm, the government recognizes that the absence of full scientific certainty shall not be used as a reason for postponing decisions to protect the health and safety of Canadians, the environment, or the conservation of natural resources7.

Q.2: Would Health Canada consider the rises in the rates of the above ailments over time to be reflective of how successful Health Canada has been at protecting the environmental health of Canadians?

No. According to Statistics Canada, in 2005 life expectancy was 78.0 years for males and 82.7 years for females. This marks substantial gains since 1956 when life expectancy was 67.7 years and 73.0 years for males and females, respectively. According to projections (based on a medium mortality assumption), males born in 2031 will have an average life expectancy of 81.9 years, and females, 86.0 years8.

This improvement in life expectancy is based on numerous factors, including gains in medical care and treatment, reductions in risk factors such as smoking, and improved diagnostic capabilities. Most of the illnesses mentioned by the petitioner are chronic diseases, with various etiologies, of which environment factors may be one for certain diseases.

Q.3: How have the rates of the incidence of Environmental Illnesses changed since 50 years ago and to the closest billion dollars what is the yearly cost to the Canadian taxpayer of Environmental Illnesses?

Significant advances have been made over time to reduce Canadians’ exposure to environmental chemicals.

Recent information-gathering and assessment activities for high priority substances under the Chemicals Management Plan indicate that many are no longer in commerce in Canada. For many of those that remain in commerce, exposure potential has been determined to be low or negligible9.

Recent Canadian biomonitoring data also shows considerable decreases in exposure to certain chemicals such as mercury, lead and cadmium. Preliminary results from the Canada Health Measures Survey released in November, 2008 show a large decline in population blood lead levels since the 1970s that can be attributed to, among other actions, the successful phase out of lead in gasoline, lead-based paints and lead solder in food cans. Less than 1% of Canadians have blood lead concentrations above the Health Canada guidance value of 10μg/dL, compared to about 25% in the early 1970s.

Also, due to risk management measures put in place by the Government of Canada, levels of dioxins in human serum and breast milk have declined by more than 50% in Canada since the 1980's. Canadian tissue dioxin levels are about 2-fold lower than in most European countries.

Although there has been no comprehensive economic assessment of the potential costs to the Canadian taxpayer from environmental diseases, several studies have estimated the direct and indirect costs associated with environmental diseases.

The World Health Organization (WHO) has developed a program to estimate the global burden of disease from several risk factors, including the environment. One publication, “Preventing disease through healthy environments: Towards an estimate of the environmental burden of disease,” can be found at http://www.who.int/quantifying_ehimpacts/publications/preventingdisease/en/index.html.

Additionally, the WHO has developed estimates by country, including Canada, for which it estimates that approximately 13 per cent of the disease burden is due to environmental factors. The analysis for Canada can be found at http://www.who.int/quantifying_ehimpacts/national/countryprofile/canada.pdf.

Boyd and Genuis (2008), using an outcome-based approach, assessed the costs associated with respiratory disease, cardiovascular illness, cancer, and congenital abnormalities. Environmental exposures, they estimated, resulted in $3.6 billion to $9.1 billion in annual costs in Canada in terms of these four diseases. Direct costs included those for physician care and operating hospitals. Indirect costs included lost productivity, but not costs related to pain, suffering or loss of life.

Further results of these studies have been summarized in the following publication:

Boyd, D.R., Genuis, S.J., (2008). The environmental burden of disease in Canada: Respiratory disease, cardiovascular disease, cancer, and congenital affliction. Environm. Res., 106 (2): 240-249.

Q.4: If prevention and the Precautionary Principle is a high priority in Canada, why is the list of products, pesticides, chemicals and foodstuffs banned by the EU so much longer than those banned the Canadian government?

Q.5: Is it correct that there were only 350 pesticides allowed in the EU and that in 2009 an additional 22 chemicals were banned and that the eliminated pesticides have studies showing a link to cancer, reproductive trouble, or genetic damage? How many pesticides are allowed by our federal government?

(As questions 4 and 5 are related, this response addresses both questions.)

Health Canada’s mission is to help the people of Canada maintain and improve their health. Prudence and careful decision making are critical to the Department’s ability to achieve its objectives, and therefore, Health Canada has adopted a precautionary approach in its regulatory functions.

Application of the precautionary principle and implementation of preventative measures are priorities for the Government of Canada. The Canadian Environmental Protection Act 1999 (CEPA) recognizes the importance of the precautionary principle and requires its application when conducting and interpreting the results of screening assessments, assessments of substances on the Priority Substances List and the review of particular decisions of other governments. Precaution is also an underlying principle of the Health Canada Decision-Making Framework for Identifying, Assessing, and Managing Health Risks (2000). The Framework guides work undertaken under Canada’s Chemicals Management Plan launched in December 2006.

Based on its commitment to the precautionary principle and prevention, Canada, under the Chemicals Management Plan, was the first country to take action on bisphenol A (BPA) in order to reduce exposures to newborns and infants, a vulnerable subpopulation. In 2004, the Government of Canada was the first jurisdiction in the world to take regulatory action on four fluorotelomer-based substances assessed under the New Substances provisions of CEPA 1999. As well, the Government of Canada recently took action on certain flame retardants and stain repellents; in the case of one fire retardant, Canada was the first country to do so.

There is substantial overlap between chemical substances banned in Canada and substances banned in Europe. However, depending on a number of factors such as use pattern, stage of assessment, and regulatory options, there can be differences in the approaches taken on chemicals to minimize risks. In Canada, Schedule 1 of CEPA 1999 currently contains 85 individual or classes of substances, representing approximately 700 discrete chemical substances that have been determined to be harmful to human health and/or the environment and which are subject to enforceable measures. In addition, Canada has had an assessment regime in place for all new manufactured or imported industrial substances. Under this regime, government scientists assess over 500 chemical substances a year. Substances that could pose a risk to our health and/or the environment are prohibited or restricted in their use or disposal10.

In terms of global pesticide regulation, joint reviews between Canada, the EU and the US are increasingly becoming the norm. This ensures that products are available to several jurisdictions after rigorous scientific evaluations by experts from around the world.

The EU legislation that was approved last year on January 13, 2009 aims to increase the number of pesticides available to member states, while in due course reducing the use of certain dangerous chemicals in these products. The new legislation will only gradually supersede existing EU law. There will thus be no sudden or large-scale withdrawal of products from the market. The agreement for the legislation with the EU Council was based on a scientific assessment by the Swedish Chemicals Agency that only around 22 dangerous substances are likely to be removed from the market as a result of the new criteria.

The EU regulatory landscape is very different than in Canada. At the EU level, substances must meet certain hazard based criteria. In Canada, as in other leading OECD countries (which include EU member states), a risk based approach is generally used in the regulation of pesticides.

Active substances are contained in pest control products, or pesticide products. As of March 3, 2010, there were 348 active substances classified as included as per Directive 91/414/EEC in the EU. Our understanding is that you are referring to this number, but it is important to note that these are active ingredients for plant protection only and do not include the many other types of pesticides.

In addition, the Registration, Evaluation, Authorisation and Restriction of Chemical substances (REACH) is a European Community Regulation on chemicals and their safe use (EC 1907/2006), designed to generate data on some 30,000 chemical substances in use today, some of which are biocides, which are regulated as pesticides in Canada.

Finally, a separate EU level organization is responsible for regulating veterinary medicines, of which many are pesticides used to treat animals, and regulated under the PCPA in Canada.

Furthermore, individual EU member states also have certain regulatory authorities. They are responsible for regulating pest control products, within their borders, which contain active substances registered at the EU level. Through their own regulatory organizations, each member state has registered thousands of pesticide products.

In Canada, Health Canada regulates both active ingredients and pesticide products for all uses, of which plant protection is only one of several. Under the Pest Control Products Act (PCPA), there are 551 registered active ingredients and 5,715 pesticide products for all uses, which include devices and other control products with non-toxic modes of action. Of that total, there are 1,986 pesticides registered in the Domestic Class, which are products that can be used in and around the home. The rest are Commercial Class, Restricted Class or manufacturing concentrates that the general public cannot access.

As for further restricting access to chemicals of concern, Canada has taken steps through the Toxic Substances Management Policy11 to eliminate Track 1 Substances, which must meet the following criteria:

  • CEPA-toxic or equivalent;
  • Persistent;
  • Bioaccumulative; and
  • Primarily the result of human activity.

The list of TSMP Track 1 Substances is identical to the “List of Substances Subject to Prohibitions” Part A in Annex 1 of Regulation (EC) No 850/2004 of the European Parliament and of the Council on persistent organic pollutants.

While differences may exist between jurisdictions, Canada continues to maintain a high level of safety for food, consumer products, pesticides, and chemicals substances used, manufactured in or imported into the country.

Q.6: If Canadians followed a balanced organic diet and refrained from eating refined sugars, high fructose corn syrup, bleached flour and vegetable oils; a regular program of exercise; a meditative mental and emotional program; supplements based on blood analysis; and refrained from smoking, illicit drugs and alcohol, what would be the savings of such a program in health care costs to the Canadian taxpayer, to the closest billion dollars? If Canadians followed such a program, how many doctors would become available to attend Canadians who are without doctors? Would the above savings eliminate child poverty in Canada?

The Government of Canada does not have data on the economic cost of many of these lifestyle choices; however, there are a number of publications which focus on certain elements of health care costs. The Public Health Agency of Canada produces the Economic Burden of Illness in Canada (EBIC) report. EBIC 1998 and a complementary Web-based application (EBIC On-line - http://www.phac-aspc.gc.ca/publicat/ebic-femc98/index-eng.php) offer a comprehensive overview of how the principal direct and indirect costs of illness were distributed in Canada. The methods used in this report allow a determination of the “opportunity cost” to society of illness or injury by translating illness, injury, and premature death into direct and indirect costs. With respect to the use of tobacco, illicit drugs and alcohol, a 2006 report by the Canadian Centre for Substance Abuse concluded that the annual economic burden of substance abuse in Canada is almost $40 billion, including health care and law enforcement costs, illness and accidents, early mortality and lost productivity. More information about this report can be found at http://www.ccsa.ca/2006%20CCSA%20Documents/ccsa-011332-2006.pdf.

Positive lifestyle changes would improve the health of Canadians and have positive effects on health care costs. However, as diet, substance abuse, and other lifestyle choices are interconnected, it would be difficult to estimate the total economic impact.

Health Canada is committed to helping Canadians to maintain and protect their health. The Department has a number of programs designed to help people make healthy food choices, to participate in regular physical activity, or to reduce use of tobacco, drugs or alcohol.

For example, Eating Well with Canada’s Food Guide, which can be found at http://www.hc-sc.gc.ca/fn-an/food-guide-aliment/index-eng.php, defines and promotes healthy eating for Canadians. It translates the science of nutrition and health into a healthy eating pattern and emphasizes the importance of combining healthy eating and physical activity.

Eating Well with Canada’s Food Guide describes the amount and type of food that Canadians, two years and over, need every day. The Food Guide recommends choosing foods from the four food groups – Vegetables and Fruit, Grain Products, Milk and Alternatives, and Meat and Alternatives – plus a certain amount of added oils and fats. Following Canada’s Food guide also means limiting foods and beverages high in calories, sugar, salt (sodium) and fat (while include a small amount of unsaturated fat).

Health Canada works with other federal partners under the National Anti-Drug Strategy in order to prevent illicit drug use, treat those with illicit drug dependencies, as well as combat the production and distribution of illicit drugs. More information about the Strategy can be found at http://www.nationalantidrugstrategy.gc.ca/nads-sna.html. The Department also produces a number of publications aimed at helping Canadians to prevent alcohol and drug abuse, which are available at: http://www.hc-sc.gc.ca/hc-ps/pubs/adp-apd/index-eng.php.

Finally, Health Canada is the lead for the Federal Tobacco Control Strategy (FTCS), which aims to reduce tobacco-related death and disease among Canadians. Built on the tenets of prevention, protection, cessation (quitting smoking) and product regulation, the FTCS represents the most ambitious effort Canada has ever undertaken to fight the tobacco epidemic. The goal of the Federal Tobacco Control Strategy is to reduce overall smoking prevalence from 19% (2006) to 12% (by 2011). As part of this program, the Department produces resources to assist Canadians in quitting smoking, which can be found at http://www.hc-sc.gc.ca/hc-ps/tobac-tabac/quit-cesser/index-eng.php.

Q.7: If prevention and the Precautionary Principle is a high priority in Canada, why are up to 80% of cancers influenced by environmental factors?

Environmental factors can play a role in the etiology of cancer. Chronic diseases such as cancer are believed to reflect the interplay between genetics and environmental factors. However, “environmental factors”, in the context of what causes cancer, includes not only exposure to cancer-causing chemicals that may be in the water, air and soil, but also ‘environmental exposures’ resulting from behaviours such as smoking, poor diet and lack of exercise. According to the World Health Report 2002, the major risk factors for cancer include tobacco, alcohol, blood pressure, physical inactivity, cholesterol, obesity, and an unhealthy diet. Cancer-causing chemical contaminants are believed to be responsible for only a very small proportion of cancers.

Nevertheless, it is a priority for the Government of Canada to assess and manage risks posed by possible environmental exposure to carcinogenic chemicals. Under the Canadian Environmental Protection Act 1999 (CEPA), the Government was required to categorize some 23,000 chemicals already in use in Canada for their potential harm to human health and the environment. Criteria used for categorization included identifying those substances that are known or suspected carcinogens. Approximately 300 such substances were identified.

In December 2006, the Government of Canada introduced the Chemicals Management Plan (CMP) to address the results of categorization. As part of the first phase of the CMP, the Government issued a “Challenge” to industry and stakeholders to provide new information about the management of approximately 200 highest priority chemical substances, which included 51 carcinogenic substances. Based on information received, and the application of the precautionary principle, risk management action has to date been proposed for 25 of these.

Q.8: Just when Canadians thought trans fats were a big thing of the past Health Canada has found a way to regenerate the industry. A cancer causing substance called akrlamide has been quietly known for several years. It does not exist in nature but is generated when making potato chips and French fries. Health Canada has plans to allow the industry to add the leukemia fighter asparaginase to these foods to combat acrylamide. Is this is another example of choosing industry over the health of Canadians?

Health Canada is committed to maintaining transparency and does this primarily by posting information on its website, releasing information through news releases, by direct responses to citizen inquiries, and through publication of its research in scientific publications. Since the discovery of acrylamide in certain foods by Swedish scientists in 2002, Health Canada has been making information on the natural formation, during cooking at high temperature, of acrylamide in food, including its research and evaluation activities, readily available on its website12. Furthermore, Health Canada's discovery of the major mechanism of formation of acrylamide in food was published in the Journal of Agricultural and Food Chemistry in 2003.

Health Canada considers that acrylamide in food is an issue that can be managed in a multi-faceted way. The main way to reduce dietary exposure to acrylamide is by eating a balanced, healthy diet. Indeed, Health Canada promotes healthy eating and recommends limiting foods and beverages high in calories, fat, sugar or salt (sodium), such as French fries and potato chips, through its guidance "Eating Well with Canada's Food Guide". Health Canada has also urged the food industry to find ways to reduce the formation of acrylamide in the foods that they sell. One way that this can be achieved is through the use of the enzyme asparaginase during food processing.

Enzymes are proteins that are naturally synthesized in the cells of plants, animals and microorganisms and are therefore natural minor components of many foods. Enzymes have been used in food processing for centuries. For example, rennet was discovered for its ability to coagulate milk to make cheese and the enzymes in yeast ferment grape juice to make wine. Most of the enzymes that are used today by the food industry are isolated from microorganisms.

The enzyme asparaginase was recently assessed by Health Canada for its safety in use in reducing the formation of acrylamide in certain foods. Health Canada follows an established procedure, which is available on its website13, when considering any proposed food additive use. At the end of the assessment, Health Canada concluded that the proposed use was acceptable on the basis of safety and efficacy. It is important to note that the proposed use of asparaginase in food is very different from the therapeutic (drug) use of asparaginase. In order for asparaginase to have a therapeutic effect on the body, it must be injected into the muscle or veins of the patient and not given orally. When asparaginase enzyme is added to food, it has an effect on the food by reducing the amount of acrylamide that can form, but the enzyme is destroyed (inactivated) during cooking and any small amount of the inactive enzyme that humans could ingest in food would be broken down in the acidic environment of the stomach and passed through the digestive system.

Q.9: Obesity is the second-highest risk factor for cancer. Milk from grass fed cows is perfectly balanced with omega-3 and omega-6 fatty acids but milk from cows fed corn; soy and wheat contain practically no omega-3 fatty acids but are high in omega-6s. Omega-3s are involved in developing the nervous system, making cell membranes more flexible and reducing inflammation. Omega-6s stimulate the production of fatty cells from birth onwards. Is the change in the character of milk since 1950 responsible of infant obesity?

Although there may be differences in the fatty acid profile of milk from grass-fed cows versus those fed other feeds such as corn, soy or wheat, there are no data to support the contention that the former is "perfectly balanced in omega-3 and omega-6 fatty acids". Moreover, the concern would be that milk containing a higher proportion of omega-3s would also contain a higher level of trans fat.

Health Canada scientists are unaware of evidence that indicates that omega-6s specifically stimulate the formation of fatty cells. The same applies to the absence of evidence that would support a link between higher intakes of omega-6s in infancy and infant obesity. It is worthwhile noting that Health Canada recommends that infants be exclusively breast-fed for the first 6 months of life. The Canadian Paediatric Society, the Dietitians of Canada and Health Canada recommend that if an infant is not breast-fed or is partially breast-fed, commercial infant formulas are the most acceptable alternative to breastmilk until 9 to 12 months of age and that cow's milk should not be introduced until after 9 months of age14. Infant formulas contain omega-3 and omega-6 fatty acids at levels found in breastmilk.

Q.10: It is correct that cancer-inducing substances accumulate in human fat?

The ability for any chemical substance to induce or cause cancer is largely determined by the chemical's relevant physical, chemical and toxic properties. While certain classes of carcinogens are lipophilic (fat soluble) and, depending on the exposure, could be expected to accumulate in human fat, others are highly reactive and do not extensively bioaccumulate.

Q.11: Is it correct that in the past 50 years, among the cancers that have increased the most are those in tissues that contain or are surrounded by fat: the prostate, colon, breast, ovaries, and lymphatic system?

Canadian Cancer Statistics, 200915 reports the incidence of various cancers year-by-year from 1980 (Tables 4.1 for men and 4.3 for women). The 2002 volume covers the period from 1973 (Tables 7.1 for men and 8.1 for women). Together, these two reports cover slightly more than 35 years. In combination, these reports show that, for women, the incidence of breast cancer has increased from 82.2 to 101.9 per 100,000 people and decreased from 46.2 to 41.2 for colorectal cancer. For men, the incidence of both prostate (60.4 to 129.5) and colorectal cancer (52.6 to 62.2) has increased.

Obesity is a risk factor for many cancers, such as post-menopausal breast cancer and colon cancer. However, it is unclear how the physical proximity of these organs to fat is connected to the cancer. Post-menopausal breast cancer, for example, is believed to be more common in obese women because of changes in their hormonal levels. Cancers of fat cells themselves (liposarcomas) are quite rare. The increased incidence of both breast and prostate cancer is partially due to improvements in the ability to detect these diseases (mammography, prostate-specific antigen (PSA) testing) and partly due to the aging of the population over this same period.

It is important to note that between 1956 and 2005, life expectancy increased from 67.7 to 78.0 years for men and from 73.0 to 82.7 years for women.16

Q.12: Is it correct that in biology and medicine it is known that many toxic substances present in the environment play roles in the appearance of the first cancer cells in an organism, and then in their transformation into a more aggressive tumour? Is it correct that the process goes on after the disease has started? Is it important to seek protection against toxins that encourage tumour growth, whether we are healthy or already affected by the disease?

Health Canada does not itself directly carry out or fund cancer research. Rather, Health Canada encourages Canadians to take care of their health through diet, exercise, and lifestyle. Health Canada provides information on health risks, so that Canadians can make informed decisions for themselves. As noted in the response to Question 1, Health Canada takes appropriate action to reduce, mitigate and manage identified health risks. The Health Canada website cancer page17 provides links to a great deal of information, including to other organizations.

The Canadian Partnership Against Cancer18 is an independent organization established in 2006 to accelerate action on cancer control for Canadians. Funded by the federal government through Health Canada, this partnership is made up of cancer experts, charitable organizations, policy makers, patients and survivors working to reduce the number of expected cancer cases, enhance the quality of life of those affected by cancer and lessen the likelihood of Canadians dying from cancer. Two projects supported by the Partnership may be of particular interest to you:

  • The CAREX Canada project is identifying and mapping the presence and prevalence of workplace and environmental carcinogens across the country. A shortlist of carcinogens is already being studied, with one database being established to record exposure in the workplace, and a second to focus on exposure through the environment, food and beverages, and consumer products.
  • Canadian Partnership for Tomorrow Project – The goal of this Project is to understand the genetic, behavioural and environmental factors which are the main triggers for cancer. The project will study a random selection of Canadians over the next several decades. It will record what they do. For example, it will track how much they exercise, if they smoke, and how much. Researchers will also collect samples of blood and urine as well as physical information such as weight and height. This Canadian database will provide policy-makers with information on how to target disease prevention efforts and will provide a legacy for future research worldwide. The high quality data gathered will also be available for the study of other health problems such as diabetes, and heart and lung disease. In the long term, this project will enhance Canada’s ability to do population research into all chronic diseases, will reduce cancer cases, and will lessen the likelihood of dying from cancer.

The federal government also funds the Canadian Institutes of Health Research,19 which supports the majority of biological and medical research in Canada. Annual reports of the Institute of Public and Population Health20 and the Institute for Cancer Research21 may provide information of the type you are seeking. Annual reports of these organizations may summarize research findings and most funded research is published in science and medical journals.

Q.13: Is it correct that compared to other crops, corn and soy use more water, fertilizers, and herbicides?

(Response to be provided by Agriculture and Agri-Food Canada)

Q.14: Is it correct that the annual production of synthetic chemicals has risen from a million tons in 1930 to two hundred million tons today?

(Response to be provided by Environment Canada)

Q.15: Is it correct that pollutants are bioaccumulative?

(Response to be provided by Environment Canada)

Q.16: Is it correct that carcinogens are found in many everyday products, for example certain plastics, lubricants, resins, glues, dyes, detergents, pesticides, dry cleaning, women’s deodorants and antiperspirants, cosmetics, shampoo, lotions, gels, hair dye, nail polish, household pesticides and household cleaning products like liquid detergents, disinfectants and toilet bowl cleaners?

Chemical substances are everywhere around us. Most of these chemical substances are not harmful to human health. However, some have the potential to cause harm, in certain doses, and should only be used when the risks are appropriately managed.

In Canada, all cosmetic products are subject to requirements of the Food and Drugs Act (FDA) and its associated Cosmetic Regulations. Household chemical products, such as detergents and cleaners, are regulated by the Consumer Chemicals and Containers Regulations, 2001 (CCCR, 2001), established under the authority of the Hazardous Products Act (HPA). Both FDA and HPA set out prohibitions and regulations on the sale, advertisement and importation of products that are, or are likely to be, a danger to the health or safety of the user.

Cosmetics
To determine whether a substance is appropriate for use in cosmetics, Health Canada reviews the scientific literature and makes determinations based on the weight of evidence, including route and duration of exposure, validation of key scientific studies and applicability to human toxicological endpoints.

Ingredients that are known to cause adverse health effects, including carcinogenicity, or that are otherwise known to be of concern in a cosmetic product are listed on the Cosmetic Ingredient Hotlist. The Hotlist, a list of over 500 substances, is indeed shorter than the European Union (EU)’s list of restricted and banned ingredients for cosmetics. However, the EU takes a different approach, and lists many substances that are unlikely to ever be used in cosmetics (e.g. cracked petroleum distillates). The Hotlist is reviewed and updated as new information becomes available. It can be found on Health Canada's website at: www.healthcanada.gc.ca/hotlist.

Additionally, the Cosmetic Regulations stipulate that manufacturers must disclose ingredients in a cosmetic product to Health Canada within the first 10 days that the product is available for sale. The information gathered through the notification process enables Health Canada to take quick enforcement action if a health and safety problem does occur after a cosmetic product is on the market. Among the United States, Europe, Japan and Australia, Health Canada is the only regulatory authority that requires this mandatory notification.

If consumers are concerned about a specific ingredient in cosmetics, they are advised to read the list of ingredients to make an informed choice prior to purchasing the product.

Consumer Chemicals
The CCCR, 2001 use a criteria-based system by which consumer chemical products are regulated on the basis of the scientifically assessed acute hazards that they pose to users (including flammability and corrosivity). Scientific data is used to identify the types of inherent hazards and the possible routes of exposure to the product in order to appropriately classify the product and its container. These regulations address acute (short-term) exposure situations resulting from reasonably foreseeable use of the product. After classification, the regulated products must display hazard symbols, warning statements, instructions, and first-aid treatment(s), in both official languages. The label must also disclose all hazardous ingredients present at a concentration of one percent or greater.

The Government of Canada is working towards implementation of the Globally Harmonised System of Classification and Labelling of Chemicals (GHS), a systematic approach for identifying and classifying hazards for chemicals, and communicating health and safety information to users. Recent developments include the formation of a multi-stakeholder group to address chronic hazards (i.e. carcinogenicity). This group will help determine an approach for labelling consumer chemical products to communicate information about chronic hazards. To follow the progress please visit the following website: http://www.hc-sc.gc.ca/ahc-asc/intactiv/ghs-sgh/index-eng.php 

Chemical Substances
It is a priority for the Government of Canada to assess and manage risks posed by possible environmental exposure to carcinogenic chemicals. Under the Canadian Environmental Protection Act 1999 (CEPA), the Government was required to categorize some 23,000 chemicals in use in Canada for their potential harm to human health and the environment. Criteria used for categorization included identifying those substances that are known or suspected carcinogens. Approximately 300 such substances were identified.

In December 2006, the Government of Canada introduced the Chemicals Management Plan (CMP) to address the results of categorization. As part of the first phase of the CMP, the Government issued a “Challenge” to industry and stakeholders to provide new information about the management of approximately 200 highest priority chemical substances, which included 51 carcinogenic substances. Based on information received, and the application of the precautionary principle, risk management action has to date been proposed for 25 of these.

Pesticides
With respect to pesticides, a product will only be registered in Canada after it has undergone a rigorous scientific assessment process which provides reasonable certainty that no harm, including chronic effects such as cancer, will occur when pesticides are used according to label directions.

Q.17: Is it correct that the most contaminated fruits and vegetables are: apples, pears, peaches, nectarines, strawberries, cherries, raspberries, grapes, peppers, celery, green beans, potatoes, spinach, lettuce, cucumbers, squash and pumpkins?

As part of the health risk assessment process, prior to the registration of a pesticide, Health Canada determines whether the consumption of residues that are likely to remain on food at the time of harvest when a pesticide is used according to label directions, is acceptable, or unlikely to cause a health concern to any segment of the population.

The maximum amount of expected residue is legally established under the Pest Control Products Act as a Maximum Residue Limit (MRL), following national and international public consultation. Each MRL is set for a specific pesticide and a specific food type. Food types include fruits, vegetables, meat, dairy products, grains and some processed foods. MRLs set by Health Canada are the result of Canadian regulatory decisions, assessed using modern scientific methodology, and applied to all food commodities sold in Canada. Canadian MRLs are set at levels far below the amount of pesticide residue that could pose a health concern.

Pesticide residues may remain in or on food at harvest, however, the pesticide breaks down over time, potentially resulting in even lower residues at the point of consumption. This rate of breakdown depends on the type of pesticide that was applied for disease or pest control, the application conditions, and the type of food treated. All pesticides can leave residues, however, the amount and nature of the residue can vary from one pesticide to another.

Food safety in Canada is a shared responsibility. Health Canada is responsible for determining whether a pest control product meets the statutory standard of acceptability for use and use conditions, and for setting appropriate MRLs. The Canadian Food Inspection Agency (CFIA) is responsible for monitoring and enforcing MRLs in the Canadian food supply. The CFIA reports that residue data compiled over the last 10 years indicates that the compliance rate is consistently very high for fresh fruit and vegetables. For example, in 2006/07 more than 99% of Canadian fruits and vegetables and 99% of imports tested well below Canada’s MRLs. In fact, no residues were detected in 90% of Canadian fruits and vegetables and in 89% of imports, at CFIA’s detection limit. However, if tested food products contain residues exceeding MRLs, appropriate follow-up and enforcement action is taken, which may include directed or compliance sampling and testing, follow-up inspections, and/or removal of the product from stores.

Q.18: Has the disappearance of honey bees, songbirds and amphibians been associated with environmental factors?

In the past, there are documented cases where destruction of habitat, over harvesting or chemicals in the environment have caused local or regional declines of some species such as declines in cod stocks or birds due to DDT poisoning. However, understanding the dynamics of populations of most organisms is a complex task. There are natural variations in populations which can occur for a variety of reasons as well as variations which can be caused by human activity. Because of the myriad of factors which can be involved, coupled with the natural variation in population levels, it is often challenging to discern the actual causes of declines in animal populations, even for well studied species. Recently, there has been focus in the media on the role that chemicals, such as pesticides, may play in declines in bees and amphibians. The Government of Canada takes such potential associations seriously and examines the data to see if there is credible scientific information and, if merited, takes regulatory action.

The introduction of modern and science-based environmental risk assessment in the early 1980s has resulted in a more rigorous approach to the regulation of chemicals, especially pesticides. As the science of environmental risk assessment has matured over the last 30 years, we are better able to identify those chemicals with potential to harm the environment. We continue to improve our assessments to ensure that pest control products cannot be registered in Canada if they pose any unacceptable risk to human health or the environment. Additionally, our re-evaluation program is in place to ensure that pest control products presently on the market meet current standards. Over the past few years, this program has resulted in the removal of a number of pest control products, or uses of certain pest control products, due to possible environmental concerns. It is also important to note that Health Canada has recently implemented a system for collecting information on incidents related to pesticides. Health Canada considers the reported information to determine if there are potential health or environmental risks associated with a pesticide and, if necessary, take corrective action.

Q.19: The government’s current attitude is one of risk management as opposed to risk assessment. This means our government decides how many Canadians can die and how much money the government is willing to forego before a product is recalled. If Health Canada makes prevention the Number 1 Priority, lives and money will be saved. How correct is this statement?

Only once a risk has been identified and characterized can it be managed. Risk assessment is an integral part of the risk management process and is fundamental to the carrying out of Health Canada’s mandate to protect the health of Canadians. This is reflected by Health Canada’s Decision Making Framework for Identifying, Assessing and Managing Health Risks.22 The importance of risk assessment in the risk management process is clearly identified on p. 1:

Traditional risk assessments typically focus on the results of biological, chemical, and physical studies involving the health effects resulting from exposure to a single agent. In recent years, there has been a growing recognition that a number of factors or determinants can affect health, and these determinants together with their interactions, can influence the level of risk for specific populations. There has also been a growing recognition that risks need to be viewed in their public health context to ensure that the most important risks are addressed and that key risks are not ignored because an issue has been defined too narrowly. Taking both of these things into account can lead to more complete and meaningful risk assessments, and to the development of risk management strategies that are more effective and that have fewer unintended adverse impacts.

The Framework also describes Health Canada’s role and activities in relation to prevention of harms to health (at p. i).

Health Canada helps protect the health of Canadians with programs and regulatory measures concerning: the quality, safety and effectiveness of drugs, medical devices and pesticides; the safety of consumer products and workplace substances; the safety and nutritional quality of food; exposure to toxic substances in the environment; and the quality of air and water [Health Canada, 1998]. The Department also helps Canadians to prevent, and reduce the incidence and severity of disease, injury and disability, through for example, prevention and control programs for specific diseases (such as HIV, cancer or cardiovascular disease) and for groups or individuals at higher risk [Health Canada, 1998]. The assessment of health risks, and the selection and implementation of effective risk management strategies, form the basis for many of Health Canada’s activities.

Q.20: Since Health Canada has adopted a precautionary approach in its regulatory functions and since Health Canada does its utmost to inform Canadians about any credible potential threats to human health and since whenever there is a conflict between the health of Canadians and the interests of the industry, Health Canada will always focus on the health of Canadians, why is the state of health of Canadians deteriorating? Who is tracking this deterioration, who is tracking the accumulated cost of these environmental mistakes and who in government is advocating for Canadians’ health when it comes to the environment? What is their success rate?

According to Healthy People, Healthy Places1 Canadians are generally healthy and health status has remained stable from 2003 to 2008 (the latest date covered in the report). As life expectancy increases, more Canadians live long enough to develop chronic diseases or conditions associated with the aging process.

Life expectancy reflects mortality, and therefore, levels of health and disease in the population. As in other developed countries, life expectancy has increased in Canada and is projected to continue to rise. In 2005, life expectancy was 78.0 years for males and 82.7 years for females. This marks substantial gains since 1956 when life expectancy was 67.7 years and 73.0 years for males and females, respectively. And according to projections (based on a medium mortality assumption), males born in 2031 will have an average life expectancy of 81.9 years, and females, 86.0 years.

The composition of Canada’s population also reflects the demographic shift to an older population with seniors accounting for an ever-increasing proportion of the population. In 2006, 13.7% of Canadians were 65 or older, up from 7.7% in 1956. It is projected that by 2056 seniors will comprise between 25% and 30% of the Canadian population.

Because Canadians are generally living longer than they did a century ago, they are more likely to experience chronic degenerative conditions such as arthritis and diabetes that develop over time and are more common at older ages.

Canadian Cancer Statistics 20092, says that 43% of new cancer cases and 60% of cancer-related deaths occur among those who are 70 years of age and older.

In collaboration with the Canadian Institute of Health Information, Statistics Canada has developed a series of indicators which are used to monitor the health of Canadians as well as the underlying determinants that impact health. The reports may be found at http://secure.cihi.ca/cihiweb/dispPage.jsp?cw_page=indicators_e.


1 Cat. No. 82-229-XWE, Statistics Canada, 2010

2 Canadian Cancer Statistics, 2009 (Toronto: Canadian Cancer Society), also available at http://www.cancer.ca/canada-wide/about%20cancer/cancer%20statistics/canadian%20cancer%20statistics.aspx.


References for section:

1. “Canada's approach on chemical substances” http://www.chemicalsubstanceschimiques.gc.ca/about-apropos/canada-eng.php
2. “Chemicals Management Plan” http://www.chemicalsubstanceschimiques.gc.ca/plan/index-eng.php
3. “Overview of The Existing Substances Program April 2007. "http://www.ec.gc.ca/CEPARegistry/subs_list/ExSubOverview/overviewofesp_p3.cfm

2 http://ec.europa.eu/health/ph_risk/committees/04_scenihr/docs/scenihr_o_022.pdf)

3 http://www.pco-bcp.gc.ca/docs/information/publications/precaution/Precaution-eng.pdf

4 http://www.hc-sc.gc.ca/ahc-asc/alt_formats/hpfb-dgpsa/pdf/pubs/risk-risques-eng.pdf

5 Pest Control Products Act, 2002, c.28, s.20.

6 Canadian Environmental Protection Act 1999, c.33.

7 http://www.tbs-sct.gc.ca/ri-qr/directive/directivepr-eng.asp?format=print

8 Cat. No. 82-229-XWE, Statistics Canada, 2010

9 http://www.chemicalsubstanceschimiques.gc.ca/challenge-defi/index-eng.php

10 References for section:

1. “Categorization Q&A” http://www.chemicalsubstanceschimiques.gc.ca/fact-fait/categor_qa-qr-eng.php#a
2. “Section 75 Of The Canadian Environmental Protection Act, 1999: Review of Decisions of Other Jurisdictions to Ban or Prohibit Substances for Environmental or Health Reasons”
http://www.hc-sc.gc.ca/ewh-semt/contaminants/existsub/article75/index-eng.php
3. “Health Canada Decision-Making Framework for Identifying, Assessing, and Managing Health Risks August 1, 2000" http://www.hc-sc.gc.ca/ahc-asc/pubs/hpfb-dgpsa/risk-risques_cp-pc-eng.php
4. CANADA National Reporting to CSD-18/19: Thematic Profile on Chemicals, 2009 http://www.un.org/esa/dsd/dsd_aofw_ni/ni_natiinfo_canada.shtml
5. Toxic Substances List - Updated Schedule 1 as of December 27, 2006 http://www.ec.gc.ca/CEPARegistry/subs_list/Toxicupdate.cfm
6. Published Control Orders - Chemicals and Polymers - New Substances Division http://www.ec.gc.ca/substances/nsb/eng/cp_published_e.shtml

11 http://www.hc-sc.gc.ca/cps-spc/pubs/pest/_pol-guide/dir99-03/index-eng.php

12 http://www.hc-sc.gc.ca/fn-an/securit/chem-chim/food-aliment/acrylamide/index-eng.php

13 http://www.hc-sc.gc.ca/fn-an/pubs/guide-eng.php

14 Nutrition for Healthy Term Infants, Statement of the Joint Working Group, Health Canada, 1998

15 Canadian Cancer Statistics, 2009 (Toronto: Canadian Cancer Society), also available at http://www.cancer.ca/canada-wide/about%20cancer/cancer%20statistics/canadian%20cancer%20statistics.aspx.

16 Healthy People, Healthy Places (Ottawa: Statistics Canada, 2010), also available at http://www.statcan.gc.ca/bsolc/olc-cel/olc-cel?catno=82-229-X&lang=eng.

17 http://www.hc-sc.gc.ca/hc-ps/dc-ma/cancer-eng.php

18 Canadian Partnership Against Cancer, 1 University Ave., Suite 300, Toronto ON M5J 2P1. Information is also available online at http://www.partnershipagainstcancer.ca/. CPAC is the organization created to oversee the implementation of the Canadian Strategy for Cancer. The most recent annual report (2008-09), as well as a wealth of other information can be found at the Resources page http://www.partnershipagainstcancer.ca/resources.

19 Canadian Institutes of Health Research, 160 Elgin Street, 9th Floor, Address Locator 4809A, Ottawa, ON, K1A 0W9; information also available at http://www.cihr-irsc.gc.ca/e/9466.html.

20 http://www.cihr-irsc.gc.ca/e/13777.html.

21 http://www.cihr-irsc.gc.ca/e/12506.html.

22 Health Canada’s Decision Making Framework for Identifying, Assessing and Managing Health Risks (Health Canada, 2000).