Speech by Dr. Goddard-Hill, former Medical Officer of Health of Prince Edward County and Hastings, to the local chapter of the Council of Canadians,
at the Kingston Frontenac Library (Central Branch),
January 25th, 2007
Air-quality and industrial air pollution has been a very big public health issue in Canada in the last few years.
In November , the Environmental Commissioner of Ontario, Mr.Gordon Miller held a public meeting here at Kingston City Hall, as part of a series that he held across the Province.
I think that we have to recognise the very strong contribution that Mr. Miller has made to our understanding of the regulation of industrial air pollution in Ontario.
Although his office has no power, in his last four annual reports ,which I commend to you, Mr. Miller really has done a very good job in focusing on how far behind Ontario regulators have been in the matter of air quality.
The most recent edition of the Commissioner's report is entitled Neglecting Our Obligations.
The cover page shows a number of smokestacks in the background, and the silhouette of a child in the foreground.
This image itself is a very powerful one.
On the inside cover of that report Mr Miller quotes Winston Churchill, who in the British House of Commons in 1936 said, " The era of procrastination, of half measures, of soothing and baffling expedience, of delays, is coming to its close. In its place we are entering a period of consequences."
Some the consequences of those half measures, and expedience and delays by various governments in the regulation of industrial air pollution in terms of human health effects are now better understood.
This has been apparent in the medical literature In the past few years.
If you want to understand the health effects of industrial smoke a good place to start would be with the health effects of cigarette smoke which are very well understood now, and which are many. There are said to be some 4000 chemicals in cigarette smoke. There are probably a lot more in industrial smoke. So you can draw your own conclusions.
Our provincial cancer agency Cancer Care Ontario has had a lot to say, of course, about cigarette smoking. But about two years ago, CCO published a Report on the health effects of industrial smoke, and air pollution.
In that report, CCO said that industrial smoke, like cigarette smoke causes heart disease, and lung disease, both acute and chronic, and probably causes lung cancer and as well, has effects on unborn children. So the similarity in the health effects of the two is quite a powerful connection to make as you think about this subject and I commend that report also to you. It is available on the Cancer Care Ontario website.
Another publication to be aware of is a recent paper by Grandjean and Landrigan, from the Harvard School of Public Health. The paper is entitled Developmental Neurotoxicity of Industrial Chemicals. It was published in the Lancet, coincidentally, in the same week that the MoE made their December announcement. I think this is a very important paper to consider. It describes yet another aspect of the human health effects of industrial pollution.
Another quote from Mr. Churchill is also relevant. In 1901, he said, "I have noticed within the last three years that we have been very engaged in a tendency to hush everything up, to make everything look as fair as possible, to tell what is called the official truth, to present a version of the truth which contains about 75 per cent of the actual article."
That was in 1901, and apparently some things do not change because that is what I find disturbing about the situation here in Bath because in my opinion the whole truth about what is going on here is not being told either by the company, or by the government regulator.
And why do I say that? Well, first of all what kind of waste is going to be burned there?
The company says, non hazardous waste, and the regulator, does not disagree. But the first point is that tires, for the most part, are not made from natural rubber any more. They are made from synthetic chemicals, principally styrene and butadiene. These are classified as toxic chemicals under the Federal Environment Protection Act. Therefore, at the end of their useful life tires are hazardous waste.
And the second point is that your people, at Clean Air Kingston, have discovered that apparently, other types of hazardous waste have already been imported from the United States and have already been burned at Lafarge, sometime in the last two years and this was apparently done with the full knowledge of the MoE, without any announcement to the public, and presumably with no meaningful monitoring of stack discharges whatsoever.
Personally I find that particular revelation...to be very disturbing.
Secondly, and again in the truth telling department,how will the process be monitored?
According to the MoE, monitoring will be ...Strict...and ...Stringent....and
....Rigorous...and .....Continuous. But the first problem is that the guideline which will be used to regulate this process will be the A 7 guideline, which is for the regulation of new Municipal waste incinerators, which this facility clearly is not.
And the second problem is that there will be no meaningful monitoring of the most toxic chemicals that might be expected to leave the smokestack as particulates, namely heavy metals, dioxins and furans, and carcinogens such as volatile and semi volatile compounds.For these toxics, annual sampling is to be done.
This consists of 3 hour samples taken three times on one day, once each year.
So, if you work it out — that amounts to about 1/1000 of the total time of operation of the facility that monitoring will be done for these very toxic compounds, and this is described by the company and worse by the MoE, the regulator, as "continuous" monitoring. 1/1000th of the time.
So the government has decided to do an experiment in Bath....and in Eastern
Ontario. And the rest of the many cement companies in the Great Lakes Basin
will be eagerly awaiting the results of this experiment.
But if they were to look just 120 miles due East of here, to Ticonderoga, New York, which is
on the border with Vermont, they could anticipate the result of the experiment.
Because the International Pulp and Paper Company has recently, about two months ago, shut down a pilot tire burning project after they were surprised to find high levels of toxic emissions coming out of their smokestack.
So the experiment has already been done, and it failed.
Our Ontario MoE in defending their decision to perform this experiment say that they have "no experience monitoring the environmental performance of facilities that incinerate tires." But it is not especially clear that they would be able to learn from their experience even if a proper monitoring program is put in place.
I say this because as we speak an experiment in burning hazardous waste is under way 60 miles to the West of here in neighbouring Trenton, Ontario.
And the performance of the MoE in that case speaks volumes about the ability of the regulator to monitor this type of facility.
Norampac in Trenton, which is doing very good work in recycling cardboard fibre, built a facility called a Steam Reformer in 2002 in order to burn pulp waste which contains low levels of dioxins as a contaminant. This, the Steam Reformer process. was an untested experimental technology. In December 2001 the Minister of Environment , who at the time was the Hon Mr. Stockwell, in a letter to me ,wrote that, "The Certificate of Approval (C of A) for Norampac's steam reformer imposes very stringent operating and monitoring conditions There is to be Continuous monitoring of the operation of the Steam Reformer"
That was in December 2001.
However, the reality has proved to be very different. It was just 2 weeks ago that the MoE revealed that 3 months ago, sometime in mid October stack emissions testing was done at the Steam Reformer, apparently for the first time, and that data is currently "under review" by the MoE.
So in other words, since December 2001 and as of today, 5 years after the Minister's letter, and after perhaps 2 or 3 or 4 years of operation (we really don't know) despite repeated requests absolutely no data whatsoever about emissions from that facility has been produced by the regulator for public review.
So this is not a reassuring testimonial to the ability of the MoE to deliver on the grand promises of intensive monitoring that they made in that particular project.
Finally, more than two years ago now, as Acting Medical Officer of Health of Hastings and Prince Edward Counties I submitted a 28 point Document to the MoE in which I raised questions about potential public health problems with the Lafarge proposal.
Under the Ontario Health Protection Act Section 12, the MOH is obliged to investigate environmental issues of potential public health significance,and the MoE in turn is obliged to provide information on those issues, as requested to the MOH.
And that point was emphasised At the Walkerton Commission by Judge O'Connor who noted the importance of co-operation between the Ministry of Environment and Ministry of Health whenever a potential public health threat arises, as it seems to have done in Bath.
However, the MoE never answered my request for information, and certainly never denied, the 28 points that were made.
That document is as valid now as it was then. These 28 public health points need to be addressed by the regulator before this project goes any further.
The recent decision by the Ontario MoE to allow the Lafarge Cement Company in Bath to burn tires and other hazardous waste Is not appropriate. In my opinion the decision suggests that the wrong government department Is regulating industrial air emissions in Ontario.
This is a human health issue and it is the Ontario Public Health officials who are the experts in human health, not the MoE.
On Nov 23, of this past year the KFLA Board of Health passed a motion which requested that the MoE conduct an Env Review Tribunal Hearing on the Lafarge proposal. This was one year after the government had announced that they would not do a full EA on the proposal.
On Dec 20, the KFLA Board received acknowledgement of this request from the MoE. Then, the next day, on Dec 21, the MoE announced that no such Hearing would be held, and that the project would proceed when the Company was ready to do so.
Now through all of this exercise we have heard about a number of lawyers who have been very busy filing Appeals to the December, Christmas Eve, decision by the MoE, but we have heard very little from Doctors. And this is rather odd, because again at bottom, this is a human health issue.
However, we are very fortunate here in Eastern Ontario. First of all we have right here in Kingston the very best medical school in the whole country, and at that school there are many outstanding specialists in heart disease, and lung disease. and cancer, and reproductive medicine, and public health. So perhaps some of these doctors will have something to say about the proposal.
Secondly, at the two Health Units in the region which are the Kingston, and the HPE Public Health Units we happen to have, again, two of the best public health experts in the country — two very experienced and very capable Medical Officers of Health.
And I would think that now that the MoE has repudiated the motion from the Kingston Board of Health and therefore, for a second time in this case, has apparently ignored the statutary requirements of the Ontario Health Protection Act, that now is the obvious time for these Medical Officers of Health to take up this question publicly and to act as Advocates for this community.
It is the Department of Health and the Chief MOH of Ontario who have the power to stop this project, not the MoE.
As Mr. Miller, the ECO, has recently pointed out, of every dollar of the Ontario Provincial budget the Ministry of Health gets 40 cents, or more of every provincial dollar. The MoE, on the other hand, gets 1/3 of one cent. That is how much we are investing in environmental protection In this province. — 1/3 of one cent.
So the MoE is not going to help us. It is to the Medical Community and the Department of Health and the Chief MOH of Ontario I think, that we should appeal until we get some answers.
And the questions that need to be answered are around the 5 points that I have made this evening:
- The Lafarge kiln will apparently be burning hazardous waste.
- "Continuous monitoring" actually means no monitoring at all for the most dangerous emissions.
- Trenton, needs explanation.
- Ticonderoga, needs to be taken into account.
- The 28 public health points, need to be addressed.
And I can tell you. that Medical Officers of Health love to get personal phone calls from individual citizens on public health issues. So my advice to each and every one of you here tonight, is to pick up the phone tomorrow and call one, or both, of these doctors to voice your opinion. They are waiting for your call.
In conclusion, I compliment the Council of Canadians, Clean Air Kingston, the Loyalist Environmental Coalition, and Clean Air Bath on your work. You are doing very good work, very worthwhile. Do not be discouraged. Do not give up. You have a very strong case here.
Alban Goddard-Hill
Eastern Lake Ontario Environmental Research Group
Waupoos Institute of Public Health and Environment
http://eloerg.tripod.com /waupoos
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