EVIDENCE
[Recorded by Electronic Apparatus]
Tuesday, November 23, 1999
The Chair (Mr. Charles Caccia (Davenport, Lib.)): Good morning to you all. I apologize for the distorted pitch of my voice; I was performing at the opera last night and I went a bit too far.
I also apologize to our witnesses for the delay. We could have started half an hour ago, but we had to wait for a quorum.
I'm grateful to those present for being here so that we can start without keeping witnesses waiting longer.
I would like to give notice of a motion tomorrow whereby I will propose to the committee, in regard to the necessary quorum, to reduce the number of members of the committee required from five to three, in order that we be able to start the meeting, and also to reduce the required number of opposition members from two to one, for the same purpose.
• 0920
I very much appreciate Mr. Jaffer's presence here
today, which allows us to start even if we don't have
the perfect presence as required by our rule, and I
hope you will not object to that.
This morning we have with us, from the Canadian Water and Wastewater Association, Mr. Ellison, I believe, and Mr. Douglas; and from Health Canada, Mr. Thomas and Madame Morisset. When we are finished with this team, so to speak, then we will have another session with the Canadian Labour Congress.
It is my understanding that Mr. Ellison would like to go first. I would invite each group to keep their comments to about 10 minutes possibly, so as to allow for questions, of course.
Again, on behalf of the committee members, my apologies for keeping you waiting, and a warm welcome from the committee.
Mr. Ellison, the floor is yours.
Mr. Duncan Ellison (Executive Director, Canadian Water and Wastewater Association): Thank you, Mr. Chairman and members of the committee.
I am the executive director of the Canadian Water and Wastewater Association. With me is Mr. André Proulx, a member of the CWWA board of directors and its executive committee. He will make the bulk of our presentation. We are also accompanied by Mr. Ian Douglas, who is a process engineer in the water quality section of the Regional Municipality of Ottawa-Carleton and the chair of the CWWA water quality committee.
Mr. André Proulx (Secretary-Treasurer, Canadian Water and Wastewater Association): Monsieur le président, chair, and members of the committee, I am the director of the water division for the Regional Municipality of Ottawa-Carleton. I also represent the Ontario Waterworks Association on the CWWA board of directors and am the CWWA secretary-treasurer on the executive committee.
Mr. Duncan Ellison: Mr. Chairman, CWWA represents corporately the municipal water and waste water agencies, who are a front line in protecting public and environmental health in respect to water. CWWA represents nationally the public not-for-profit water supply and waste water services provided by more than 3,000 municipalities to more than 24 million Canadians. It is joined by the seven regional or provincial water and waste water associations whose memberships comprise the individuals who actually operate the water and waste water treatment, collection, or distribution systems.
CWWA thanks the committee for this opportunity to participate in the review of pesticide management in Canada and has been asked to brief the committee on the impacts of pesticide use on drinking water quality and the various processes used to disinfect water and waste water.
In doing so, CWWA would like to make it clear that neither chlorine nor any of the other chemical disinfectants used are considered to be pesticides under the pesticide management program. They are disinfectants, whose use is required by provincial and federal public health and environmental authorities to disinfect drinking water and waste water in order to manage the microbial hazards existing in all water sources and effluent streams carrying human and other wastes.
Mr. André Proulx: I would like to begin my remarks with pesticides. Pesticides have implications for municipal water sectors in two ways: the presence of pesticides in ground and surface water sources and the treatment challenges these represent. Later, I will address the matter of disinfection of water and waste water effluents and will describe to you the various chemicals and non-chemical processes available or required to be used to meet public health objectives.
Pesticide contamination of water sources is a serious issue. The legal, registered use of pesticides has resulted in pollution of water bodies throughout Canada and all parts of the world.
Pesticides enter water bodies through three main routes: accidental spills or discharges, leaching to groundwater, and runoff to surface water.
Provincial and federal monitoring has detected the presence of pesticides in water bodies used as drinking water sources throughout the country. Despite the fact that the levels have generally been within guidelines, public health officials and the drinking water supply sector remain concerned with the long-term protection of drinking water sources.
Predicting the health consequences of exposure to these residual levels of pesticides and drinking water and the treatment processes to remove or reduce the residual levels are both difficult, thus it is important that water sources be protected from contamination by pesticides in the first place.
• 0925
To ensure this protection, CWWA and all municipal
water services are strongly committed to the
development and implementation of sound watershed
management practices—watershed here includes both
surface water and aquifer recharge areas. All
pollution sources, whether point or non-point in
nature, should be addressed by the program. A
pesticide spill or discharge is considered a point
source, while contamination from runoff or migration to
groundwater is a non-point source. Since most
watersheds extend geographically well beyond the
jurisdiction of municipalities, watershed management
programs have to be implemented at the provincial or
federal levels.
While certain water treatment techniques and technologies can achieve fair to excellent removal of pesticides, prevention of pollution is a much preferred option. CWWA recommends that this committee support federal initiatives to keep pesticides from reaching drinking water supplies in the first place. There is an immediate need for more widely spread training and education and awareness efforts promoting the optimized use and application of pesticides by commercial and residential users.
Homeowners should be a prime target as, surprisingly, per acre pesticide use in urban and suburban areas can outweigh that on farms. A U.S. survey of suburban Chicago homeowners found that lawn treatment with pesticides averaged 10 pounds per acre annually, which is approximately 9 kilograms per hectare, compared to approximately 2 kilograms per hectare for soybean farmers.
There is also a need to target golf course users and industrial pesticide users in areas such as power, pipe, and rail line rights-of-way, as well as usage at dams and aqueducts. Whatever is sprayed into the air or onto the ground eventually ends up in our water bodies.
Additional research is needed to gain a better understanding of the long-term health and environmental effects of pesticides from all exposure sources, particularly any synergistic effects. In addition, further research into the extent of and stability of pesticide contamination of groundwater and surface water in Canada is key to understanding the scope of the issue facing the water treatment and supply sector.
Water drawn from the environment is never pure. There will always be some natural and man-made impurities—whether they be chemical or microbial—present in the water, which may require treatment to remove or reduce them. Microbial hazards arise from all living creatures whose bodily wastes end up naturally or by intent in water bodies.
Disinfectants are required to meet public health objectives established by federal and provincial public health and environmental agencies. Drinking water and waste water effluents are disinfected to minimize the incident of waterborne disease. Health officials are unanimous in their assertion that the effectiveness of water disinfection not be compromised, even in the face of danger from disinfection by-products.
Regulators are calling for greater effectiveness in disinfection or in the physical removal of organisms to deal with the threat from protozoans. Due to recent microbial outbreaks and the increased number of people in our society with compromised immune systems, regulators are requiring a higher level of disinfection and physical removal to deal with microbial risks.
The primary methods of disinfection in use today employ chlorine in one form or another, whether it be chlorine gas, chlorine dioxide, sodium hypochlorite, or chloramines. Ozone and UV—which is ultraviolet radiation—are potential alternative disinfectants and are gaining prominence. While the intent of these disinfectants is to kill microbial and other organisms in water sources, they are neither considered to be nor regulated as pesticides, any more than they would be if used in hospitals to disinfect or sterilize surgical tools or other equipment and areas used by patients. Membrane filtration is a non-chemical treatment technology. Its use is still not common for economical reasons, but it is being used in small systems.
• 0930
The chemical and non-chemical disinfectants or
processes used in the treatment of water and waste water
are often used in combination or in sequence in the
multiple stages of the treatment and distribution or
discharge processes. Some flexibility exists for their
use in the multiple stages, but no matter what process
is used, it has been found that chlorine, either
directly or in the form of chloramines, must be used to
ensure that water in the distribution system remains
disinfected and safe to drink. UV, ozone, and
membranes, which I talked about earlier, cannot provide
this protection.
Traditionally, chlorine and related products have been and remain widely used in both the pre- and post-treatment phases of drinking water production and in the disinfection of waste water effluents just prior to discharge into the environment. Chlorine is effective in eliminating microbial hazards, is widely available, and has been the greatest positive influence in promoting public health around the world. Waterborne diseases are significant in infant and child mortality and the loss of economic production in the developing world.
While the by-products of chlorine disinfection have been recognized as public health concerns, other disinfection methods and systems also have negative effects. This is the disinfection dilemma: how to obtain the health and environmental benefits of disinfection without undue negative effects. But no matter what alternatives may be used in the pre-treatment processes for drinking water and the post-treatment processes for waste water, disinfection residuals based on chlorine or related products have to be maintained in drinking water distribution systems. There simply is no alternative.
Ozone disinfection is used in some pre-treatment drinking water disinfection processes prior to or just after coagulation, flocculation and filtration. It is a powerful oxidizing and disinfecting agent formed on site by passing dry air over high voltage electrodes.
As an example, ozone occurs naturally, usually after a lightning storm. You may smell that occasionally. After a lightning storm you'll smell the ozone.
It is more widely used in Europe than in Canada and the U.S., although Montreal, Quebec and Ste-Foy, Quebec, employ ozone disinfection, and Windsor, Ontario, has recently made the decision to do so.
However, the use of ozone for disinfection results in the formation of disinfection by-products, such as aldehydes and bromates, both known to have health risks. For example, an interim maximum acceptable concentration guideline has been set by Health Canada for bromate at a fairly low level of 0.01 milligrams per litre.
Ultraviolet or UV radiation uses high-energy light instead of oxidative chemicals to disinfect water. UV lamps emit energy at a wavelength that penetrates cell walls and destroys the genetic material of bacteria and viruses. All organisms are susceptible to germicidal UV energy, but the lethal dose varies from one organism to another. The use of UV systems requires easy access to the equipment for regular maintenance, channels for banks of lamps and a reliable source of power, including back-up power. Power costs are an important part of the total cost of operating a UV disinfection system but may, depending on the source of power, result in additional greenhouse gas generation.
As UV is generated on site, it eliminates the transport, storage and handling of chemicals, does not require expensive safety equipment and training in chemical handling or personnel evacuation. However, annual equipment replacement costs can be as high as 70% of total system costs, and operating a UV system requires management of cleaning chemicals. For example, 5% phosphoric acid may be needed to clean the lamps every three to five days.
Membrane filtration offers a physical barrier to contaminants and can achieve very high removal of particles greater than 0.5 microns in size. For those who are unaware, a micron is one-thousandth of a millimetre, and most viruses are smaller than 0.5 microns.
Membrane filtration is very promising for dealing with protozoans such as giardia and cryptosporidia, but is relatively expensive.
I have to remind you, though, that while non-chemical technologies reduce the reliance on chemicals, a residual disinfectant is still needed to protect water quality in the water distribution system, and capital costs for both ultraviolet and membrane-based systems remain high at this time.
• 0935
Now I'd like to talk about waste water and storm water
issues rather than just drinking water.
Municipal waste water, including storm water, may also be required by provincial agencies to be disinfected, depending on site-specific situations, to protect public health and the quality of the water from high loads of human parasites, bacteria and other disease-causing organisms. This recognizes the fact that many communities draw their drinking water downstream of another community's sewage outfall or will use the water for recreational purposes.
Examples of known diseases that may be spread through non-disinfected waste water discharges are typhoid, polio, cholera, dysentery and hepatitis.
As with drinking water, the disinfection processes most often used in North America still involve chlorine, although this is changing. Free and combined chlorine in municipal effluents are toxic to aquatic ecosystems, causing acute lethality in fish and changes in community structure—for example, reductions in diversity and shifts in species composition.
The impact of discharges to water bodies is affected by factors such as the nature of the mixing zone and how quickly chlorine residuals may be dissipated through dilution or reaction with organic materials in the receiving water body. The need to protect organisms in receiving waters from toxic effects of chlorine has prompted regulatory authorities in some provinces to require the de-chlorination of effluents or the use of alternative methods of disinfection.
De-chlorination is the physical or chemical removal of the traces of residual chlorine remaining after the disinfection process, and may involve the use of other chemicals, such as sulphur dioxide. Other authorities recognize that winter discharges into cold aquatic environments may not require disinfection due to the lack of viability of the organisms.
Non-chlorine processes and technologies are effective in producing high-quality effluent within acceptable guidelines for the presence of pathogenic organisms. Among these are ultraviolet radiation—
The Chair: May I ask you now to wind up your presentation, please.
Mr. André Proulx: Certainly.
The Chair: You have now had 20 minutes.
Mr. André Proulx: Okay.
Just to touch on the other options, there's ultraviolet radiation, ozone, ponds, constructed wetlands, and membrane-based processes. All these can be used as alternate methods for the waste water, or storm water type of disinfection. Of course, the challenges the municipalities have touch on the research in those areas and the direct impact on their receiving streams.
The Canadian municipal water and waste water sector, the scientific community, and regulatory authorities all have the same goals: clean, safe and high-quality water, both in our homes and in our environment.
That will be it, Mr. Chair.
The Chair: Mr. Proulx, thank you very much.
Who wants to be next? Mr. Thomas.
Mr. Barry Thomas (Senior Scientific Adviser, Bureau of Chemical Hazards, Department of Health): My name is Barry Thomas. I'm the senior scientific adviser in the bureau of chemical hazards in the environmental health directorate of Health Canada.
Véronique Morisset is here with me. She is a chemical evaluator in the drinking water section. She helped me prepare the brief and did the translation, so she's here to assist me.
I'd like to thank you for inviting me here today. I received correspondence from the chair of the committee asking me to update you on what Health Canada is doing with chlorination and chlorination by-products, and so my talk is going to focus on that one issue.
Health Canada has established a chlorinated disinfection by-products task group whose purpose is to look at the whole problem in a very broad perspective. I will also be mentioning a study that Health Canada is doing in its own laboratories on what consumers could do themselves to deal with problems of high-disinfection by-products.
Before I get into that, I think I need to emphasize, as my colleagues ahead of me have pointed out, the importance of the disinfection of water. Natural water is filled with pathogenic organisms, and if we don't carry out this critical process, we run tremendous public health risks.
A case that's often quoted is from Peru in the early 1990s, where they became so alarmed by the reports coming out of the United States Environmental Protection Agency about chlorine by-products that they ceased to chlorinate the water. They had a huge outbreak of cholera and typhoid, and many thousands of people died.
• 0940
So clearly the answer to these problems is not to stop
disinfecting water.
The concerns scientists have with chlorine are about the possible long-term effects of drinking chlorinated water on the incidence of bladder cancer and the short-term effects during pregnancy. More recent studies have shown that miscarriages and stillbirth rates seem to be increased when chlorine by-products are elevated.
The guidelines for Canadian drinking water quality clearly state that any effort to minimize these risks must not compromise the disinfection. This same advice is given by the World Health Organization.
Nevertheless, we should not underestimate the risks from chlorine by-products. That is clearly the reason Health Canada is putting considerable resources into looking into this issue.
It's important at this point to remind the committee of the jurisdictional issues with drinking water. Across Canada, the responsibility for the provision of safe drinking water lies with the provinces, not with the federal government. The system we have is that provinces adopt enforceable guidelines, objectives, or regulations, usually based on the guidelines for Canadian drinking water quality published by Health Canada. This publication is actually produced by the Federal-Provincial Subcommittee on Drinking Water, which has been working for several decades in the preparation of these guidelines. So we do have a national consensus on this issue.
There is one area of drinking water where the federal government does have jurisdiction, and that is in the area of materials. Materials that come into contact with drinking water, being a product, do fall into the area of federal jurisdiction. In the last session of Parliament, the proposed Drinking Water Materials Safety Act, Bill C-14, sought to regulate the quality of drinking water products, which of course would have included chlorine. We still believe this is an important issue.
The process by which chlorine is causing a problem is that it naturally is a very reactive chemical. That's the reason it kills bacteria. But unfortunately it reacts with a myriad of organic compounds that are present in natural water to form these chlorination disinfection by-products. Chemists have identified several hundred of these products, and it's a major challenge how we're going to remove them. Certainly one of the preferred methods is to remove the organic material prior to the addition of chlorine.
As my colleague mentioned, there are alternatives. I won't go into them too much. He's covered that ozone is probably a more effective disinfectant than chlorine, but it's expensive, particularly for small systems; it produces its own disinfection by-products; and unlike chlorine, it is so short-lived that it does not maintain the disinfected quality of water in the distribution system, so chlorine still has to be used. UV, on the other hand, is a non-chemical process, and again as was mentioned, is quite promising. We'll look to see further developments in that area.
As mentioned in the written brief, the task group Health Canada has established will be looking at the guidelines we currently have for a group of disinfection by-products called trihalomethanes. The current level is 100 micrograms per litre and was established in 1993. We will be reviewing this with the committee, which is a multi-stakeholder group including provinces, environment groups, and health groups. Under it, Health Canada is conducting scientific evaluation and research to try to establish the extent of the risks from chlorine by-products.
The task group is also looking at what technologies are available to improve the quality of water, both in reducing the disinfection by-products and also in reducing microbial risks. The purpose of the task group is to prepare a report, which would go to the Federal-Provincial Subcommittee on Drinking Water, to recommend if the guideline needs to be changed in order to protect public health, and if so, what technologies are available to municipalities in order to achieve a new, lower guideline. We expect this work to be completed within one to two years.
• 0945
As with anything, money is a problem. Any reduction
of the guideline will result in very large
expenditures. If we significantly reduce the
guideline, we're probably talking in the order of
several billions of dollars spread over perhaps five to
10 years as treatment systems are modified.
Against this, we should realize that Canadians currently have some of the cheapest drinking water in the world. The figure I have is something like 0.03¢ per litre is the current cost of drinking water in Canada. So it could perhaps be argued that there is room for some increase in cost if it would improve public health.
We will be looking in this exercise at the costs, the benefits, and the risks.
I've heard people be rather impatient that Health Canada isn't coming more rapidly to a conclusion on this issue. From evaluating the literature, I have to tell you it is in some cases contradictory, and there is certainly a lack of clear science on exactly how these by-products may be causing cancer and reproductive effects. The exercise is one of reading a vast amount of literature and trying to reach some clear scientific conclusions, because clearly if action is taken that costs this country billions of dollars, we'd better be sure we're right.
I'd like to close by making two brief recommendations to the committee, which are in the written brief. I urge the committee to support this initiative of Health Canada to examine this critical issue of managing the risks from chlorine by-products. I'd also urge the committee to consider the whole question of drinking water safety and the materials that come into contact with drinking water, with the goal of reducing the risks by preventing unsafe materials from affecting the quality of drinking water.
Thank you for your attention. I'll be happy to answer any questions.
The Chair: Thank you, Mr. Thomas.
[Translation]
Ms. Morisset, would you like to say a few words?
Ms. Véronique Morisset (Evaluator, Water Quality, Microbiology and Cosmetics Division): No, my comments are included in his presentation.
[English]
The Chair: Mr. Douglas, do you want to add anything?
Mr. Ian Douglas (Chair, Water Committee, Canadian Water and Wastewater Association): No, I'm fine, thank you.
The Chair: Wisdom and silence are synonymous, are they?
All right then. We'll start a good round of questions, beginning with Mr. Jaffer, please.
Mr. Rahim Jaffer (Edmonton—Strathcona, Ref.): Thank you, Mr. Chairman.
I'll just direct my questions openly to whoever feels they can answer them.
Mr. Thomas, you talked about the jurisdictional issue of water and you outlined that. I'm curious as to whether any standards are set as to the highest levels of chlorine that could be added to water. Is there some sort of standard across the board for all municipalities or provinces? If not, or if there is, are there great differences in the levels of chlorine as you go across the country from municipality to municipality? Does it depend on what's in the water, depending on whether it's runoff time? How is that established? Could you explain that?
Mr. Barry Thomas: There is no level of chlorine set for municipal systems, and you've actually touched on the reason. The amount of chlorine that has to be added to water in order to ensure it's disinfected—which, remember, is the prime reason for adding it—varies considerably with the quality of the water and even over the course of a year. We find that in, for instance, the prairie cities, where you come from, in the spring you get a very high runoff and the organic content of the water goes much higher, so you have to add a lot more chlorine.
Where the regulatory mechanism comes in is this trihalomethane guideline I mentioned, which is the chlorine by-product. That's what is used to try to maintain the quality of water. That is why, for instance, the scenario I just described is a very difficult one. When the organic content is high, you have to add more chlorine, and it has a multiplying effect: you get more and more of these THMs and more and more of a health risk.
That is how it is done. We can't set a maximum level for chlorine because of the varying quality of water.
Mr. Rahim Jaffer: Okay. With regard to the health effects from chlorine, are some harder data available that show the effects? I don't know how long we have been using chlorine in our systems, but given the timeframe during which it's been used, do you have some direct effects? I know you mentioned some of them that show direct links between, say, chlorine levels and the effects on people's health no matter how old they are, if they're pregnant, or just general effects.
Mr. Barry Thomas: I have to emphasize that there's no evidence that chlorine itself causes a problem. It's these chlorine by-products. And yes, we do have fairly good data. Canada has actually played a leading role in this.
• 0950
A study funded by Health Canada from the mid-1990s in
Ontario showed a very strong statistical link between
the level of chlorine by-products and bladder and colon
cancer. This is one of the stimuli for the Health
Canada initiative.
As far as the reproductive effects are concerned, a study in California in 1998 showed that miscarriage rates were increased in California communities with elevated chlorine by-products. More recently, in 1999, from Nova Scotia there is a report of increase in stillbirth rates in communities that have high levels of chlorine by-products. So there's quite a lot of human data coming out of epidemiology.
The animal data is not quite as conclusive, though we have shown that some of the chlorine by-products will cause cancers in rats, but usually at different organ sites, such as liver and kidney. And some reproductive effects have also been seen in animals.
Mr. Rahim Jaffer: I'll direct my final question to André.
You mentioned in your talk that sometimes there's a runoff of pesticides in various drinking waters. Do you find consistent levels of certain pesticides in different parts of the country? How does that play into the equation? Do you find there are certain areas in the country where pesticides are more present in water because of certain effects of runoff or so on? Or is that not really even a factor?
Mr. André Proulx: It varies very much across the country. A number of effects come into play: the size of the watershed, the flow, the dilution factor—I hate to say dilution factor—and that's why we're promoting correcting the pollution at the source.
Smaller communities with smaller streams in a large agricultural area, for example, are much more susceptible to pesticide use in that area. Again, when it gets into the groundwater, it's much more difficult. The groundwater flow is very, very slow, so it's a big issue for those on well systems and for aquifer issues.
But it is very varied across Canada.
Mr. Rahim Jaffer: One thing just struck me in that, and someone from Health Canada may have something to say about this.
When you do mix chlorine with, say, various forms of these pesticides, could the chemical reactions even have more of a negative effect than chlorine? Or does chlorine not necessarily cause the negative reactions with various forms of these pesticides you might find having a runoff? I don't know anything about the reactions, but can potential negative effects come from that?
Mr. André Proulx: I think we touched on this slightly. There are synergistic issues with pesticides or anything in the water, for that matter. Earlier we talked about organic matter with chlorine. Also, two different pesticides or other items in the water, whether they be organic or man-made, all have an issue. How chlorine reacts with pesticides is something I don't think research has really tackled. Probably Dr. Thomas could touch on it better than I could.
On the issue of pesticides, we're concerned with the health aspects of the drinking water. That's our concern. Avoiding the pesticides getting into the streams and into the aquifer is primarily our concern. If we can avoid it, then we don't have to worry about the impact downstream.
I'd like to touch briefly as well on something Dr. Thomas touched on concerning chlorine. It is critical to note that it is the issue of the by-products of the chlorine. It's not the chlorine itself. If you can remove the organic matter and treat the water, less chlorine will be needed and there will be a lot fewer by-products. That's something the industry is pushing towards. A lot of research is going into that across the world. If we can avoid that, then we reduce our trihalomethanes, as we talked about.
The Chair: Thank you, Mr. Jaffer.
Mr. Reed, followed by Madame Carroll.
Mr. Julian Reed (Halton, Lib.): Thank you very much.
This is in the nature of a general question too. There are many millions of people living around the Great Lakes right now. What is it, 30-some-odd million? Most of them get their drinking water out of the Great Lakes and discharge their sewage effluent back into it. If all of that water is chlorinated, it would stand to reason that some of that chlorine is going to form by-products, whether it's with a toilet flush or whatever.
• 0955
Has any work been done to establish what downstream
impact there has been? We see the canary in the mine
through changes in certain sea life in the St. Lawrence
River. But has there been any real work?
This technology, which started many years ago now, is still being employed by municipalities. I have to admit that in the riding I serve, a decision has been made to put yet another pipe into Lake Ontario and discharge effluents back into the lake. Do we know what that's doing downstream?
Mr. André Proulx: I guess I can touch on it from the Canadian Water and Wastewater perspective. Certainly we all know effluent goes back into the receiving streams, whether they are the Great Lakes or rivers. The quality of the effluent is a big factor and the assimilation of that receiving stream.
If you're discharging into the Ottawa River versus Lake Ontario or the Grand River in central Ontario, they all have different assimilation properties. So the impact on those various streams has to be looked at individually. That's the first point I'd like to make.
There's no doubt about it, the issue of chlorine being discharged into an environmental aquatic environment has been looked at. There is an impact on the aquatic environment because the water is taken directly into the bloodstream and there is a toxic effect. The level, of course, depends on the receiving stream, the type of water they're treating, and the quality of the water they're treating. The various municipalities have various levels of treatment for the waste water streams, from primary to secondary to tertiary, and the disinfection method can vary as well.
We have examples of chlorine being discharged into some of the Great Lakes that have very low temperatures. Lake Superior, for example, has very low-temperature water, and the question is whether we actually have to chlorinate that water. What can the microbes do in that cold water? It's understood there's a different impact—the assimilation of the microbes. Maybe we don't have to disinfect.
Duluth, Minnesota, allows no disinfection. The State of Minnesota has allowed Duluth to not have to disinfect their waste water because it's discharged into Lake Superior.
Mr. Julian Reed: Vicky Keith, who swam across Lake Ontario, reported swimming through an effluent discharge from Metropolitan Toronto. It made her sick, as a matter of fact. It was obviously effluent of dubious quality.
I register this concern because we're still harvesting seafood out of the mouth of the St. Lawrence River. We expect it to be acceptable on our dining room tables, yet we don't seem to be coming to terms with this technology that was acceptable, dilution-wise, even 60 years ago. But the population around the Great Lakes is increasing remarkably, and this pipe that's coming to Halton will not be the last, unless some other technologies are put into use.
Am I waving an unnecessarily red flag here?
Mr. Barry Thomas: No, I think it's an important issue, and there are new technologies. Sewage is not an area Health Canada actually has a lot of responsibilities for, but I've certainly been impressed, where disinfection is needed, how effective ultraviolet can be. It doesn't contaminate the water with chlorinated compounds.
As my friends will confirm, there's a big trend in many parts of the world to change to UV disinfection. I think it's something we should encourage, because we have one of the world's leading manufacturers of this sort of equipment in Ontario, and they tell me their best business is outside Canada. They don't get too many clients here.
I think we should be encouraging the use of UV rather than chlorine for disinfection, because, as you say, it may have worked years ago, but the populations around the Great Lakes and many of our water bodies are growing, so we need a higher level of safety.
On the health effects, I don't think they need to be overblown. Health Canada has done studies, and we have our Great Lakes program. We're not seeing a lot of evidence of health effects attributable to the Great Lakes.
• 1000
We've looked at cancer effects, with Great Lakes water
as a source of drinking water. We haven't found that
it was the Great Lakes per se that were causing the
cancer. The chlorination of the drinking water was
causing increasing rates of cancer of the bladder, not
the water itself.
There are other health effects, and I'm sure you've heard of many of the hormone effects and that sort of thing in this committee. So I think there are a lot of concerns, and they're legitimate. We need to be moving to more stringent and newer technologies.
The Chair: Thank you, Mr. Thomas.
Madame Carroll, Mr. Pratt, Madame Torsney, and the chair.
Ms. Aileen Carroll (Barrie—Simcoe—Bradford, Lib.): Thank you, Mr. Chair.
This partly comes from Mr. Reed's questioning, but we cottage on Georgian Bay and have seen a reduction in the water level this year of at least four feet. We keep a record of water levels, as most cottagers do. Of course, Georgian Bay reflects Lake Huron and generally all of the Great Lakes, as you gentlemen know. The result of that is an increase in water temperature, which is already impacting fish that require a cold-water environment for successful reproduction, and so on. It's also impacting the ecology generally.
Scientists seem to be somewhat in disagreement about this reduction in water level, but many are saying it will be a very long time before the water levels come back to where they once were. The level is now lower than it was in the 1960s.
How does this reduction in water levels impact—or does it—on what we're discussing this morning, which is the ability of our lakes to handle disinfectants that are safely handled predicated on a volume ratio? Does it have an impact? Does it make it more difficult to safely disperse chlorine or treat the effluent, as Mr. Reed was saying?
Mr. Ian Douglas: Your question is a good one. If the water level goes down in a certain water course, it will impact the assimilation of contaminants and pollutants that go back into the water course. Probably the most pronounced effect would be shoreline effects, where normally you'd have three or four feet of water and it might be down to one foot. That would tremendously change that localized area.
Large bodies of water, like Lake Huron or Georgian Bay, will essentially remain the same size, even if the water level adjusts very slightly. As far as assimilation goes, you usually have pipes going way out into the lake. So there is an impact. It's mostly localized in the shoreline-type areas, but it will affect assimilation.
Ms. Aileen Carroll: Thank you. That's all, Mr. Chair.
The Chair: Thank you, Madam Carroll.
Mr. Pratt.
Mr. David Pratt (Nepean—Carleton, Lib.): Thank you, Mr. Chair.
André, as you well know, the City of Nepean was one of the pioneers in terms of the use of UV to treat storm water. I'd be very interested in knowing if there are any municipalities in Canada right now that use UV to disinfect drinking water. Are there any at this point, in Canada or the U.S., that use UV technology?
Mr. André Proulx: I don't know any specifically, off the top of my head, but there certainly are some. Smaller systems, certainly not large urban systems, with populations in the neighbourhood of 5,000 may use UV.
The big issue with UV is that we believe it's a good disinfectant, but there is not a lot of research in that area; there isn't a really good comfort level on what it actually disinfects as far as the microbial pathogens go. There are the basic ones we're comfortable with, but with the giardia and cryptosporidia there is a concern over contact time. UV is an ultraviolet light that impacts a membrane, so different organisms need different quantities of contact time, so there is a concern there. It's only used at the pre-treatment end of it; it can never be used on the distribution side of it. We have to keep making that point.
Water distribution systems need a residual disinfectant in the system to avoid regrowth of bacteria. All these other options, such as ozone, UV, membranes are used for the upfront disinfection of water coming out of the source. That's where your options are. Right now we have no other options. There are no technologies out there right now on the distribution side.
Mr. Ian Douglas: There's a lot of renewed interest in the application of UV for drinking water. I just came back from a water quality conference in the U.S., and just in the last year there's been a really strong surge of interest in UV. They've found it is very effective for cryptosporidia and giardia, which are two of the key pathogens of concern in drinking water.
• 1005
Some in Canada are using UV—I think in the
Collingwood area. I could find out who's using it. I
know they're generally smaller plants. Economy of
scale is a problem with UV. The largest demonstration
plant right now is in the U.K., and all eyes are on this
plant to see how it performs.
So there's a lot of renewed interest in UV, but as Andre mentioned, we still require some chemical disinfectant to protect it throughout the distribution, such as chloramines, for example.
Mr. David Pratt: How similar are the water quality standards on both sides of the border? You mentioned Minnesota earlier and the situation they have there. Is there anything to scientifically back up their position that they can discharge without using chlorine?
Mr. Andre Proulx: This is from the waste water side, of course, but Ottawa-Carleton has allowed non-disinfection in the winter because of the water temperature. So during winter periods, Ottawa-Carleton has the provincial authority to not have to disinfect discharge into the Ottawa River from the R.O. Pickard Environmental Centre, because of the cold temperature. In the summer, because of the activity in the receiving stream, we are forced to disinfect.
I think the scientific evidence is not all in yet on that part of it, but there is some. That's why the non-disinfecting is allowed to go on. It does two things, obviously. It reduces the amount of chlorine used, which means less chlorine produced, which is always better for the environment. If the receiving stream can assimilate that microbiological activity at the cold temperature, it's done naturally.
If you think of receiving streams in Canada, there is a lot of wildlife and no treatment of the streams. Think of it as spring thaws in Canada—everything is going into the rivers. There is natural assimilation possible in those streams; it's been going on for thousands of years, so the streams can assimilate. To what level is the issue.
Mr. David Pratt: What is the order of magnitude in terms of the use of chlorine in the disinfection of drinking water versus the use of chlorine for the disinfection of effluent? Typically, what's the ratio in terms of the use? Obviously, when water is used, the chlorine content continues to be in the water as it flushes through the waste water system.
Mr. Andre Proulx: When the drinking water is used in the home, there is no chlorine left—going through a shower or a bath. There is very little residual in the drinking water systems across Canada. As soon as you get an organic material in the water, the chlorine attaches to it immediately and it is no longer a disinfectant. As soon as it starts going down the sanitary sewer, there is no more chlorine in the sewer system.
The issue is the waste water plants removing as much as they can before they disinfect. The only reason they disinfect—we have to keep saying this—is because of the authorities telling the municipalities to disinfect before they discharge.
As Dr. Thomas stated, the technology is changing rapidly on the waste water side. More and more provinces.... We were just talking about Quebec. I think Quebec does not allow chlorine discharges. I think there is an exception for Montreal, but no municipality can discharge chlorinated effluent. They have to either de-chlorinate or find an alternate source of disinfection.
That's happening in Ontario as well and right across Canada. It's moving more and more toward stopping chlorination discharge. It's a big issue for GVRD, Greater Vancouver, because of their receiving streams and their salmon and trout. I don't think they allow it either right now.
Mr. Ian Douglas: De-chlorination is a fairly simple and effective means of rendering waste water that is low in microbial content and has no chlorine toxicity for aquatic life. So you can use chlorine or UV. If you want to get rid of the chlorine, it's very simple to add a very small amount of a very safe chemical to the system. It immediately de-chlorinates. I think there should be a greater push for the use of de-chlorination to render the streams safe.
Mr. David Pratt: How's my time, Mr. Chair?
The Chair: Second round.
Mr. David Pratt: Okay.
The Chair: I appreciate the interest in water quality, but I invite members to concentrate a little more on the pesticide issue.
Mr. David Pratt: That was going to be my next question.
The Chair: Madame Torsney, please.
Ms. Paddy Torsney (Burlington, Lib.): It was good to hear your discussion on trying to encourage the various users of pesticides to reduce the loads on the water streams. What are you doing to go about encouraging that? Is the Canadian Water and Wastewater Association on a national campaign? Do you think it's up to the government to be doing that? How do we get the message out?
Mr. André Proulx: We are members of a fraternity of water for North America, the American Water Works Association, which almost all Canadian municipalities are part of. The big push is on watershed management, and watershed management touches on a number of issues, including pesticides. So for the Ottawa capital region, we all draw off the Ottawa River, and if there was a big issue on the receiving stream from the watershed management, it would be addressed in that fashion.
For groundwater storage, aquifers for example, there is a big push by all associations to say, protect your source. And looking at the source touches on pesticides, and touches on farming—just farming in general, from cattle, which would be the fertilizer end of it, to pesticides. So there is a big push and it is being taken very seriously. I know that in the southern Ontario area, for the Grand River, which is very much a high agricultural load receiving stream, they are focusing directly one on one with farmers on the use of pesticides and how discharges go into their receiving streams.
So there is a big push on it, but I don't know about the research end of it. I don't know if Dr. Thomas could talk to it.
Duncan.
Mr. Duncan Ellison: I would like to add that some municipalities have almost 100% control over the watersheds through which they draw. A good example of that is Nanaimo, British Columbia, and Moncton has a good chance of doing that. But for others like Ottawa-Carleton, the watershed is thousands of square kilometres upstream. The city of Edmonton is receiving water from a major area with very high cattle production.
So the degree to which a municipality can control use of the watershed varies. This is why we have to go up from the municipal level to water basin management that may be multiple. A municipality like the Grand River is a very good example in Ontario.
But when you get into bi-provincial water systems like the Ottawa or the North and South Saskatchewan Rivers, you have to go up to federal-provincial mechanisms for control of the watersheds. And unfortunately we don't really have integrated river basin management in Canada yet. We have management of river basins from the point of view of flow, flood reduction, electrical energy generation, fish habitat protection, and recreational use, but we don't have—with few exceptions like the Grand River—control of industrial development or resource exploitation as part of the water resource management.
Ms. Paddy Torsney: But where Mr. Reed and I are from, there seems to be a new golf course every week. It's not farmers any more who are owning that land, it's golf courses. We also have a very high standard of very nice lawns. I'd have to think we'd be fairly similar to the suburban Chicago situation. If people had more information, I'm sure they might think about the decisions they're making. I think it's a lot of inadvertent decision-making.
Whose responsibility is it to target, as you say, the training, education and awareness efforts? Is that the governments? Is it municipalities? Is it your association?
Mr. André Proulx: Right now it's the municipalities taking that role, because when we look at the drinking water side, they are responsible to provide the drinking water to their constituents. If they have a drinking water issue, they're usually the ones who take the lead role, and they will go upstream and say, we have an issue, you have a discharge, how can we work together in correcting it?
Ms. Paddy Torsney: Lastly, I was glad to see you talking about the membrane technology, which is manufactured in my riding with Zenon technologies. Certainly part of the challenge is that there are already established systems all over the country, and people tend to use what they know, and so the cost issue becomes really one of what's familiar, what's in general practice, instead of moving to the newer systems.
• 1015
What kind of targets do we have for finding solutions
on eliminating more chlorine, whether it's the
chlorinated effluent or figuring out a way to do things
differently? Are there targets? That seems to
be somehow a greater motivator to people to establish a
10-year target for reducing. Or is there a demand or
an opportunity as newer systems are established?
I think Collingwood has membrane technology,
because they had a horrible problem with....
A voice: Filtration.
Ms. Paddy Torsney: Thank you. I know they had an emergency at the hospital, and they put in a portable unit and then moved into a municipal unit.
Emergencies tend to create an opportunity. But is there any kind of move to get up some more pilot projects within Canada? They're exporting lots of technology, and people come to the plant and then have to be taken elsewhere, to another country, to actually see it in operation.
Mr. Duncan Ellison: One of the issues in the acceptance and installation of new technology is of course always the concern for the management of risk. Will it work? Will it not work? One of the criteria that we as an association have been working on with the Federation of Canadian Municipalities in the proposals for the infrastructure program that is being advanced is that the investments made should be towards using new technologies that will solve some of these problems.
It's one of the criteria. There are probably seven or eight criteria that have been developed. But this should be one of them. We must use this opportunity to leapfrog in the application of technology to meet these health and environment goals.
Mr. Ian Douglas: I would comment that there's a tremendous amount of interest and research in getting away from chlorine. When you go to these conferences they're talking UV, they're talking membranes and other techniques, because the regulations have been tightened and tightened.
As Dr. Thomas alluded, the 1993 was actually quite a significant lowering of the guideline on THM, from previously 350 parts per billion down to 100 parts per billion. Suddenly municipalities say there's no way I'm going to meet this 100 unless I look for alternative technologies. So certainly regulations based on sound health risk drive that move. That's underway right now with the task force in Health Canada.
Mr. Barry Thomas: That's what I described. We're going to establish not just the health risks, but what are the choices. Obviously these new technologies are amongst the choices. There's no question that the guidelines, which in many provinces are like regulations, are big driving forces.
If you reduce the trihalomethane guideline, for instance, from 100 down to 50, it would have a huge economic impact in this country, but it would also force people to look at new technologies, because chlorine becomes more and more problematic in how you can use it. I think what we're doing right now is part of that, and we are working with the Canadian Water and Wastewater Association and other people to see what technologies are available and what the costs are of using these new technologies.
So I think we are working very actively in that direction.
Ms. Paddy Torsney: Terrific. Thank you.
The Chair: Ms. Catterall, please.
Ms. Marlene Catterall (Ottawa West, Lib.): You mentioned that chlorine is not considered a pesticide, and yet I'm not sure what the difference is between something that kills a grub in my lawn and something that kills giardia and cryptosporidia in water.
I'd ask Mr. Thomas, why is it not a pesticide?
Mr. Barry Thomas: I'm not sure I'm a good expert on that. Somebody from the Pest Management Regulatory Agency may know the legislation. There's no doubt that in the definition of pesticide chlorine and other anti-bacterial agents.... As I think was mentioned in the CWAWA brief, the anti-bacterial agents in hospitals are not considered pesticides either.
So I think chlorine falls more into the idea of antiseptics and anti-bacterials. It's used to protect human health. That's really what it's all about. So it really comes down to a question of definition. If you're looking at it on a purely scientific basis, I suppose it's true, pesticides kill insects and disinfectants kill bacteria. That is the scientific difference, that we're moving from insects to bacteria, which are of course in a biological sense different even though they're both living systems.
Ms. Marlene Catterall: Actually both of you seem to skip fairly quickly.... And I do want, as the chair suggested, to return to the issue of pesticides, because that seems to be mostly why we have to chlorinate water. That's fine, but I would like to explore a little more the extent of pesticides in water.
You mentioned that it is possible to remove them, but there's very little about what is possible and what is not possible. There's virtually nothing here about the extent of pesticides in the water. As my colleague Mr. Pratt was about to ask, what are the trends here? Is it a tenfold increase over the last decade, a hundredfold, a thousandfold, or in fact a drop in pesticide residue in water? What does the presence of pesticides do to the overall quality of the water that we then have to deal with in terms of making it fit for human use?
Mr. Barry Thomas: Perhaps I should talk a bit about how often it occurs in drinking water, because that is in the area of responsibility for Health Canada and the drinking water program, and also, of course, the provinces and municipalities.
So the answer is that there are ongoing programs monitoring the overall quality of water from time to time. They tend to be done on a rather ad hoc basis, with a mixture of funding from federal and provincial agencies. Agriculture Canada, for example, will do farm surveys of well water quality, where you often do see pesticides. I have to say that the trend is not alarming. In fact, it's fairly good.
The most recent surveys that were done, funded by federal agencies, showed the number of farm wells, for example, with significant levels of pesticides was really quite low. I think they measured several thousand. And the number of wells with detectable levels was no more than a few dozen. I haven't come briefed with the actual numbers, but we do look at it.
There's no doubt that certain pesticides are the bad actors. There's one that, if you talk to a drinking water person, always crops up, and it's atrazine. Atrazine is the number one pesticide for getting into drinking water just because of its very nature. It's widely used, I believe, on corn, and it seems to show a great propensity to go right through the ground into the well water. That is considered a problem pesticide.
So we are monitoring the issue. There doesn't seem to be a big increase in the incidence.
I think I would leave the question as to what could be done about treatment to my colleagues here. We don't really get a lot into the treatment end of things. I always thought it was rather difficult to remove pesticides. Our colleagues here said it was fairly easy. I thought it was very expensive and difficult, which is why I certainly agree with the proposition that the best thing is to try to prevent pesticides from getting into drinking water sources in the first place. Trying to put in treatment systems, to me, is very expensive and very difficult. The system we use for the guidelines is that we only develop guidelines for pesticides when there is a problem. So when the system has failed and we have a problem, then we'll develop a guideline.
Ms. Marlene Catterall: So much for the precautionary principle.
Mr. Barry Thomas: There are literally thousands, hundreds. I don't know how many pesticides there are. So we obviously can't have a national guideline for every single one, because the process of setting a national guideline is a very lengthy process. It involves federal-provincial consultation and a full risk assessment by Health Canada. A typical process takes two to three years to establish a guideline for one pesticide.
At the present time, I believe, we're working on two pesticides; MCPA and dichloroprop. So we're working on two pesticides right now that we've identified as a problem and for which we don't have a drinking water guideline. We're working at the moment to develop them. But this is the system that's used.
Ms. Marlene Catterall: This is a side issue, but does that mean you haven't assessed the risks of the others?
Mr. Barry Thomas: No. The process of registering a pesticide involves an evaluation of its potential to contaminate drinking water. This is done by the Pest Management Regulatory Agency, not by Health Canada directly. Of course they're an agency of Health Canada. We don't do that work within the drinking water program. But they do look at the thing. I gather it's a black mark against a proposal if the field trials have shown it has a great propensity to get into groundwater, for example. So there is a protection in the registration process, as I understand it.
Ms. Marlene Catterall: Do I still have time to ask our municipal people if they monitor the presence of pesticides in water when they come in for treatment and when they leave—when they hit my house, for instance—and what the trend seems to be? What's the nature of the pesticides? What impact do they have on the quality of water? Then what do we do about it?
I was interested this week to hear about a process, I think in the Chatham area, for in fact allowing farmers to dump off pesticides that they had no other way of getting rid of. As somebody was pointing out, many of them were coming in steel drums that hadn't been used for years. So they've been sitting around in containers that are rusting and ready to burst at any time.
Have we ever done anything like that in the Ottawa-Carleton region?
Mr. Ian Douglas: The last issue you spoke of is an issue of hazardous waste disposal, and there are proper techniques for disposing of those materials.
There are about 80 parameters regulated in the Health Canada guidelines for drinking water. Roughly 50 of those, correct me if I'm wrong, are pesticides. So the lion's share of parameters that are there for Canadian drinking water are pesticides.
We've been monitoring the Ottawa River watershed for about 10 years, and each year we look for hundreds of pesticides. We have looked at upwards of 400 different parameters in the drinking water. We look at part-per-billion and part-per-trillion levels, so we're talking extremely trace quantities. The good news is that we haven't seen any increase. We rarely see anything detected.
Now, that's specific to the Ottawa watershed, and there are very limited agricultural impacts on that very vast watershed. My sense, from other parts of the industry and other parts of Canada, is that, if anything, it is a downward trend, and it's fairly rare to see a pesticide show up as a real concern. If it does show up, of course, you go back and find who's using it, get back to the users, and get it out of the watershed. It is monitored extensively across the country. Atrazine is probably the most notable one. I think in the midwest part of the States there's been a flare-up of atrazine being found.
Some pesticides decay within days of application. Some last and last. It's a very complex system.
Ms. Marlene Catterall: So many municipalities across the country are doing this kind of monitoring. I gather that nothing is being done to bring it together in Health Canada, where there might be an interest in looking at the patterns as part of their research.
Mr. Ian Douglas: As Barry mentioned, the responsibility for drinking water quality is generally provincial. I know that in Ontario they have a surveillance program that is actively looking at all the utilities in Ontario, looking at all these pesticides and things, and if they find, for example, that North Bay has a problem with a pesticide that's showing up, then discussions go right to North Bay on how we're going to resolve this, and so on.
On the balance of problems in drinking water, I would not say that pesticides are currently a major issue. There are other larger issues that are looming. But they do occasionally crop up, depending on the watershed. The good news is that it is being tested rigorously down to trace levels to the limit of current analytical capabilities, and generally speaking, they're not found. We look for 200 compounds, and it's not surprising to find “non-detect” for every compound. So there are some positive strokes in that area.
The Chair: Thank you.
Ms. Marlene Catterall: Is my time over?
The Chair: Yes. We are running about 45 minutes late, so I apologize to the Canadian Labour Congress, who are patiently waiting. We would like at least to finish this round, and there may be a possibility for one question for those who wish to ask a question on the second round.
Dr. Thomas, in your presentation this morning you frequently made references to guidelines. That seems to be the mandate, perhaps, of your department. I don't know. Why don't you make references to standards?
Mr. Barry Thomas: We use the term “guidelines” because we don't have federal power to regulate them as standards. They actually can become standards, depending on the provincial legislation. The one I would mention specifically is Alberta. Essentially the guidelines become standards in Alberta, because their drinking water legislation says that whatever Health Canada produces in those guidelines becomes standards. There's a mosaic across Canada of provincial regulation, which I don't think we have time to discuss this morning. But each province has different levels of—-
The Chair: What stands in the way of Health Canada pronouncing, announcing, or setting standards that may or may not be implemented by provinces?
Mr. Barry Thomas: The likelihood of implementation is very great, because we do it through a federal-provincial system. So there is consensus at the provincial level with the numbers that we set.
The Chair: Why are they not announced as standards in the first place?
Mr. Barry Thomas: Because most provinces don't have the necessary legislative power to make them standards. They treat them as objectives or guidelines.
The Chair: Well, what would happen if Health Canada were to announce standards instead of guidelines? What would be the problem?
Mr. Barry Thomas: I think the problem would be that we wouldn't have any powers to enforce them.
The Chair: All right. What would be the advantage?
Mr. Barry Thomas: Of using the word “standard”?
The Chair: Yes.
Mr. Barry Thomas: I don't know.
It may raise public expectations. I guess that would be my fear, that people would expect those standards to be met. If Health Canada couldn't deliver, which we can't because we don't have the legislative power to do that, I think it would cause us a problem. But I think it's quite clear that these guidelines.... The term we use, incidentally, is “maximum acceptable concentrations”. So certainly the answer you get from Health Canada, if a guideline is exceeded, is that we say it's not acceptable.
The Chair: Mr. Thomas, the PMRA, at the present time, operates within your department, doesn't it? And it does not produce a yearly report, is that correct?
Mr. Barry Thomas: I'm not sure, because I don't deal directly with them.
The Chair: We are not aware of any report either. Do you think it should?
Mr. Barry Thomas: I'm really not in a position to judge that. As far as the drinking water program is concerned, as I say, we don't have a lot of linkages with PMRA. We can give advice if they seek it, not only on drinking water risks but on many health risks, when they do their own evaluation. But they do have their own scientists now who do their own evaluations. It was the case up to a few years ago that the drinking water part of the assessment was done by the part of Health Canada I work in, but they've now established their own staff to do the drinking water evaluation themselves.
The Chair: Who is “they”?
Mr. Barry Thomas: PMRA.
The Chair: Do you have any comments to offer on this change?
Mr. Barry Thomas: Not really. I gather the purpose of setting up the agency was to have it all under one roof, so having part of the evaluation done in a different office was, in a managerial sense, problematic. But other than that, I have no real comment. As I say, we no longer actively participate in the drinking water assessment of new pesticides.
The Chair: You don't?
Mr. Barry Thomas: No.
The Chair: Do you think you should?
Mr. Barry Thomas: I've no reason to believe they're not doing an adequate job. I would say it that way. On the other hand, we do not police it, because of course it isn't the role of one part of the department to police another part. I've no evidence that new pesticides that are being released are causing a problem.
I think what you've just heard now, that there's no evidence of a certain upsurge of pesticide contamination of drinking water, would I guess be indicative. If it happened that when new pesticides were being marketed they caused a lot of problems for drinking water, that would suggest a breakdown of the registration system. But I've no evidence that is occurring.
The Chair: Don't you find it strange that an agency in charge of pesticide management should also be in charge of water quality studies and the enforcement of water policies?
Mr. Barry Thomas: Not really. It's part of the information package they receive from the applicants. The pesticide manufacturers have to do field trials, as I understand it, that look into the question of what impact there is on surface water and ground water. So it's part of the total package they receive from industry, which they evaluate. As I pointed out, we used to do some of that evaluation up to a few years ago.
The Chair: When was the evaluation transferred to the PMRA?
Ms. Véronique Morisset: About two years ago.
Mr. Barry Thomas: Ms. Morisset actually did quite a lot of those evaluations.
The Chair: Perhaps I should be addressing my question to her.
Is that arrangement satisfactory?
Ms. Véronique Morisset: We have no reason to believe it is not. There is no evidence of increased pesticides found in the drinking water. So obviously there does not seem to be a problem.
The Chair: Who is “we” when you say “we”?
Mr. Barry Thomas: Well, I guess she's talking about the drinking water program. Following up on what was said about the monitoring and how it gets to Health Canada, as we meet with the provinces, they come to the table with the sort of monitoring data that my colleagues here have mentioned. They will tell us at those federal-provincial meetings that a pesticide is cropping up in their water. That's why MCPA and dichloroprop, for example, are currently being looked at by Health Canada for its drinking water program. The provinces have come to us saying that their monitoring programs are finding these are problem pesticides.
So that's how we monitor the program, really, with pesticides—through the provinces and their monitoring programs. In other words, it's like a pyramid.
The Chair: So are the provinces reporting to you that their findings of pesticides are increased or decreased?
Mr. Barry Thomas: I would say they're pretty level. I'm not hearing from the provinces that they're seeing an increased evidence of pesticide contamination of drinking water.
The Chair: And would you expect a decline over time?
Mr. Barry Thomas: I would hope there would be a decline.
The Chair: And on what do you base that hope?
Mr. Barry Thomas: I hope we would be more careful in registering pesticides to avoid the problem. If we can avoid causing problems for our drinking water systems by not registering pesticides that are going to cause a problem, then I think that's a very cost-effective way of doing it.
The Chair: How is this element of carefulness going to be advocated?
Mr. Barry Thomas: I believe that is in the mandate of the pesticide agency. As they say, they're certainly supposed to evaluate the safety of pesticides for human beings, which includes getting to human beings through the drinking water.
The Chair: And you are satisfied that they are?
Mr. Barry Thomas: So far as we know. I'm not pretending that we are doing a close evaluation of their program.
The Chair: Don't you think you should?
Mr. Barry Thomas: No, I'm not so sure that I would feel comfortable to evaluate another program, no, unless t his was a mandate that was given to us. But it hasn't been given to us.
The Chair: Why wouldn't you be comfortable?
Mr. Barry Thomas: I guess I would say it would be second-guessing. These scientists are as competent as I am. Why should I be in a superior position to them? That is the problem I'd have.
The Chair: But in an equal position, that wouldn't be offensive, would it?
Mr. Barry Thomas: I wouldn't have any objection if there were some sort of peer review of the program. If you're asking me if I would object if we were asked to review some of that, I guess not. But it's certainly not the way the program's being managed, and I could see it causing some logistical problems to have, again, an outside group involved. The agency, as I understand it—
The Chair: You're not outside; you are in the same department.
Mr. Barry Thomas: Yes, I guess—
The Chair: Are you or are you not in the same department?
Mr. Barry Thomas: We are in the same—
The Chair: Well, then, why are you outside?
Mr. Barry Thomas: Organizationally we're separated. The drinking water program is in the environmental health directorate, under the health protection branch. I guess there is a level at which the two programs unite, but there's never been any request.
The Chair: At which level?
Mr. Barry Thomas: I think at the branch level, if I'm correct.
You have to realize you're dealing here with a scientist, not a manager. I'm a scientist, so I'm not always too clear on these management issues. But I believe the pesticide agency is part of the health protection branch, so the common element would be Dr. Joseph Losos, the assistant deputy minister of the health protection branch, if that's the case. If there were a need for that part of the pesticide agency's work to be reviewed, it would have to be decided at that level, obviously not by a working-level scientist like me.
The Chair: Thank you. I have one final technical question. Is there any co-relationship between the presence of pesticides in water and the use of chlorine? In other words, does chlorine use increase in the presence of pesticides, or are the two totally unrelated?
Mr. Barry Thomas: In that respect, I would say they were totally unrelated.
The Chair: Thank you.
We'll have a quick second round. Mr. Reed.
Mr. Julian Reed: Thank you very much, Mr. Chairman.
There was a comment made that I found very interesting: that some pesticides actually disappear within a short period of time after their application and others seem to linger. In your experience, are the new pesticides that are coming out now and being approved more liable to be the type that will disappear quickly rather than hang in?
• 1040
The reason I asked the question
is that we're struggling with this business of the
approvals process for new pesticides. Some new
pesticides that have come on are used in smaller
quantities, they're biodegradable, etc. I just
wondered if you've seen a trend in that direction.
The Chair: Barry, would you comment, please.
Mr. Barry Thomas: I'm not sure I know the answer to that. I know the evaluation procedure because, as I said, we used to be involved in it.
One of the tests you make is repeated application. If it's persistent, you obviously tend to get accumulation. If the accumulation led to the pesticide reaching a critical level from a health perspective, that was a big mark against the pesticide.
From a scientific point of view, I would say the evaluation process should give a sort of black mark against a chemical that's very persistent, because that inherently will cause problems with repeated application. It certainly was part of the evaluation that you didn't just do one application, you'd do a series and see whether there was an accumulation in soils in a field, for example, or in groundwater.
As to whether or not the new pesticides that are currently coming on the market are less bio-persistent than the previous ones, I really don't know the answer.
Mr. Julian Reed: Thank you.
Thanks, Mr. Chairman.
The Chair: If there are no further questions, we thank you very much, Mr. Ellison, Mr. Proulx, Mr. Thomas, Madame Morisset, Mr. Douglas. It was very helpful, and we hope to see you again.
Mr. Barry Thomas: Could I just correct something? I was just given a note that I gave you wrong information. Dr. Franklin, the head of the PMRA, reports to the deputy minister directly, not through the health protection branch. I'm sorry.
The Chair: Thank you.
We will call now on the next witnesses, Mr. Bennett and Mr. Yussuff, from the Canadian Labour Congress.
Mr. Bennett, welcome to the committee. The same to you, Mr. Yussuff. I recognize that it's your first time here.
We apologize to you for the delay. I appreciate very much your presence today. Would you like to start?
Mr. Hassan Yussuff (Executive Vice-President, Canadian Labour Congress): I'm Hassan Yussuff, the executive vice-president for the congress. I'm responsible for the health, safety, and environment department and a number of other departments in the congress.
As you are aware, the congress is very much involved in health, safety, and environmental issues, to the extent that we have a department dedicated to ensuring that our work is ongoing. Of course public policy work is just as important. Similarly, we have two standing committees, one on health and safety and one on environment, and we meet on a regular basis to look at the question of environmental issues and health and safety issues. In regard to the matter that we're here to talk about today, around the question of pesticide regulation and management, we're hoping that our perspective will assist the committee in its final deliberations.
The Canadian Labour Congress represents 2.3 million workers in both the public and private sectors across Canada. Many workers are in direct contact with pesticides, for example, manufacturing workers and formulators, agricultural workers, forestry workers, municipal workers, railway workers, lawn care applicators, and others who are exposed to chemical pesticides in the course of their work. Furthermore, we're involved as bystanders in pesticide use. We are subjected to pesticide waste—for example, through the contamination of water supply—and furthermore, we are consumers who ingest pesticides daily in the form of residues on food.
The Canadian Labour Congress was a member of the pesticide registration review in 1990, on which the Pesticide Management Regulatory Agency, the PMRA, was based. The CLC did not sign the final report of the review since, in our view, it was too weak to be useful. The CLC statement of dissent is included in the final report. Furthermore, not all of the consensus report was implemented by the government of the day, in particular over the alternatives office and pre-notification and right-to-know requirements.
• 1045
The Campaign for Pesticide Reduction,
CPR!, was founded based on the
inefficiency of existing organizations dedicated to the
proper elimination and control of chemical pesticides.
The CLC is a founding member and steering committee
member of the CPR!. At its inception, about half the
member organizations of the CPR! were local unions and
municipal labour councils. The CLC has strongly
supported moves by the CPR! to ban the cosmetic use of
pesticides, to pass municipal bylaws banning or
severely restricting chemical pesticide use, and to
work for the full public right to know about chemical
pesticides and their effects on human health.
In connection with human health, almost all the human evidence used by the International Agency for Research on Cancer, IARC, to classify pesticides as carcinogenic comes from occupational exposures. Workers are in the front line when it comes to chronic diseases caused by chemical pesticides, in addition to the acute effects documented in the presentation by the CPR! to this committee.
The federal government is committed to pollution prevention, evidenced by its policy document, Pollution Prevention - A Federal Strategy for Action in 1995. Further, the Canadian Environmental Protection Act, CEPA 1999, is an act specifically aimed at pollution prevention. The preamble commits the government to pollution prevention as a national goal and as the priority approach to environmental protection.
According to the government's pollution prevention policy, pollution prevention should focus on avoiding the creation of pollutants rather than trying to manage them once they have been created. Pollution prevention is defined as:
In regard to chemical pesticides, we encounter a problem that is unique to their use. Once a pesticide is actually used, it becomes impossible to control its escape into the general environment, with the consequent effects on human populations, workers, consumers, and the environment. Limited controls are possible for acute worker exposures, such as personal protective equipment and re-entry times for workers to re-enter sprayed fields, but these are inefficient and far less efficacious in practice than they are in theory. They also fail to protect workers from the chronic health effects of pesticides, which are, in industrialized countries such as Canada, much more important than acute effects.
This being so, not only is pollution prevention the priority approach, it is virtually the only approach to address the human and environmental consequence of chemical pesticide use. As the government itself acknowledges, control and management are far less effective than eliminating pollutants at the source, known technically in pollution prevention methodology as “source reduction”. The only point at which we can implement source reduction is in the registration process under the Pest Control Products Act, PCPA, administered by the PMRA.
How does the PMRA rate when matched with the declared aims and policies of the federal government? It rates a D minus, or a failing grade. While the Pest Control Products Act certainly monitors the introduction of chemical pesticides into the Canadian environment, it utterly fails to prevent pesticide pollution. There are no recorded cases of a new registration ever having been rejected under the act from among the more than 6,000 pesticides registered. There is no attempt to restrict the entry of chemical pesticides onto the market, nor to deny re-registration when less unsafe alternatives have appeared. The PMRA utterly fails in the one device it has within its power to avoid the creation of chemical pollution, pollution that would be regarded and classified as extremely hazardous toxic waste were it produced and disseminated in any other context but its legal use under the PCPA.
Opponents of chemical pesticides are reduced to working for bans once a pesticide is in use and the damage to environmental health is already done. This is a slow, costly, uncertain process that eliminates a handful of pesticides at best, with no guarantee that substitutes are any less dangerous. Likewise, the PMRA is reduced to encouraging alternatives when the horse has already bolted from the stable, with massive amounts and types of pesticides proliferating and polluting the environment, backed by commercial propaganda and incentives on the part of the pesticide distributors.
On the right to know, the picture is almost equally bad. Pesticide material safety data sheets, MSDS, are still not required by law, meaning that workers and the public have no access to the chemical content of what is being used, no information for formulants or inert ingredients that are far from inert, nor any company-generated data that are required to be submitted in the registration process. There is no independent scientific verification of the data, which is in any case impossible if the chemical composition of the pesticide is unknown. Quantities of chemical pesticides used in Canada are likewise unknown, a situation almost unique in the industrial world.
• 1050
Under the review of the Workplace Hazardous Materials
Information System, WHMIS, the relevant
parliamentary committee agreed in 1992 to bring
pesticides up to the standards for industrial chemicals
with respect to labels, for MSDS, and for trade secret
issues—confidential business information, CBI—to be
handled by a Hazardous Materials Information Review
Commission. This would mean that, in all
respects, post-notification—i.e.,
post-registration—pesticides would be on the same
footing as industrial chemicals and would meet the same
standard of disclosure. In the coming revisions to the
PCPA, it is essential that the bill enable WHMIS to be
implemented, along with HMIRC scrutiny of pesticide
trade secret claims, followed immediately by
regulation.
Currently international discussions are underway over chemical classification, pesticide labelling and data sheets, trading and CBI, under the auspices of the Intergovernmental Forum on Chemical Safety, IFCS. These discussions are part of Agenda 21, chapter 19, on the environmentally sound management of chemicals mandated by the UNCED conference in Rio in 1992. However, any resulting international standard will not be implemented within the next five-year legislative cycle. We have to act now on the right to know.
This is respectively submitted on behalf of the Canadian Labour Congress.
My colleague Dave Bennett and I will be prepared to answer any questions the committee may have.
The Chairman: Thank you, Mr. Yussuff.
Mr. Mancini.
Mr. Peter Mancini (Sydney—Victoria, NDP): Thank you, Mr. Chairman. I have a couple of questions.
First of all, your rating for the PMRA is quite telling. You don't mince too many words there in giving it a failing grade. I just want you to expand on that a little bit for me.
It's pretty clear for me. You say, “There are no recorded cases of a new registration ever having been rejected under the Act from among the more than 6,000 pesticides registered.” Do you want to expand on that? Is there anything the PMRA is doing that's good? Let me ask you that.
Mr. Dave Bennett (National Director, Workplace Health, Safety and Environment, Canadian Labour Congress): In regard to the Pest Control Products Act—because it's really the act itself that drives the work of the agency—one question that Mr. Mancini raised was whether the PMRA is doing anything right. Strictly speaking, the answer is that we don't know. The public has no access to the data that are used by the agency in registering pesticides. The public has no access to the regulatory reasoning, or the reasoning by which pesticides are registered and the terms by which they're allowed to come onto the market.
In terms of its reputation internationally, the reputation of the PMRA is a high one in that it demands a large volume of data from pesticide manufacturers. That includes data on the efficacy of the pesticide product, not only its toxicity and its possible effects on human beings and the environment. The reputation it has is that when it comes to monitoring the introduction of pesticides into the Canadian environment, it is rated highly as a government agency.
But let's be clear as to what the agency is doing. Assuming that the public knowledge is as the reputation indicates, what the agency is doing very effectively is monitoring the introduction of chemical pesticides into the Canadian environment. By monitoring, that means it has a very good handle on the efficacy of the pesticide, the toxicological effects of the pesticide, the likely progress of the pesticide through the environment.
• 1055
That's why we would give it a D minus grade. It does
something, and evidently it does it very well. However,
on the one key function the agency has, namely to
allow, to restrict, or to forbid the introduction of
chemical pesticides into the Canadian environment, the
answer is quite simply that it doesn't do that.
Why doesn't it do this? Why is it that the agency has this permissive attitude towards chemical pollutants? Why is it that the agency allows, without any evident restriction, any product that comes before it to come onto the market. Why does it do that?
We would like to suggest that in the original writing of the act, which was many decades ago, the mentality of parliamentarians and government personnel was that technical issues like pesticide registration should be the property of competent, technically informed, scientifically qualified personnel. In other words, it was seen as a purely scientific matter as to whether pesticides should or should not enter the Canadian market and the Canadian environment.
This being so, there are no tangible criteria written down in the act or the regulations that give guidance or prescriptions to regulators when they do or they do not register chemical pesticides. In other words, it's a charter for scientific bureaucrats to do exactly as they please—in other words, to decide whether or not the Canadian environment is to be polluted by such and such a pesticide.
What has happened historically, we believe, is that parliamentarians have allowed the government machinery to take the place of proper policy-making decisions. These proper policy-making decisions, in our view, are properly the property of Parliament, the House of Commons, parliamentarians such as you. So what we are asking for and will be asking for when the Pest Control Products Act comes to be revised is that parliamentarians themselves take charge of what is quite properly a public policy issue.
It is not only a technical, scientific, bureaucratic function to decide how much the Canadian environment will be polluted, but it's also the property of parliamentarians to decide what criteria are going to be used when a product is allowed or is not allowed onto the Canadian market. These criteria are public policy issues that should be written into the act itself. Once that is done, the possibility will then arise of a wholesale restriction and reduction of chemical pollution into the Canadian environment.
As it's written now, the act means there is a policy decision that is entirely the property of scientific bureaucrats. And what happens? We have an entirely permissive policy that allows no restriction whatsoever on the introduction of chemical pesticides into the Canadian environment.
Mr. Peter Mancini: I'm going to ask you to help me with this. You talk about the pesticide material safety data sheets that are not required by law. There's a lack of independent verification of chemical pesticides used in the workplace, and you make the statement that this is almost unique in the industrialized world.
I would assume that what you're referring to by “pesticide material safety data sheets” is some kind of indication of what kinds of chemicals and pesticides are in the workplace, and the data sheet measures how much people in the workplace are exposed to. I don't know if I'm right on that, so if I'm wrong, can you correct me? Are we alone in the industrialized world in not requiring that this information be shared?
Mr. Dave Bennett: We'd like to make a general observation about chemical pesticides in relation to industrial chemicals. Again, for historical reasons and perhaps for reasons that are really not very well understood, pesticides are treated very differently from industrial chemicals.
If you look at Canada's regime for the notification of new chemicals, for example, which is chemical testing requirements for industrial chemicals, if you look at the right to know about industrial chemicals in terms of labels, data sheets and worker training, if you look at some very strict rules about what manufacturers must disclose and what they may conceal, you see there's an enormous discrepancy between the way industrial chemicals are treated and the way pesticides are treated. They're all chemicals. Many of them are toxic. They're all potential pollutants. And yet there is a huge discrepancy between the way the pesticides are treated and the way industrial chemicals are treated.
Regarding confidential business information, the whole industry is much more secretive than is the case with industrial chemicals. The privileges they have to withhold information from the public are much higher than for industrial chemicals. There is again what is evidently a double standard in that once a pesticide is registered, there is in fact virtually no restriction on the amount of pollution allowed into the Canadian environment.
If you had a major industrial plant that put out effluent of a similar chemical nature to chemical pesticides, the executives in the plant of that company would go to jail for chemical pollution. Yet, when the chemical pollution happens to be pesticides, this is legitimized, it's encouraged, it's regarded as a normal part of behaviour in an industrial society. We see this discrepancy, even a double standard, over the way the two are treated.
In regard to data sheets, no, very few countries require pesticide data sheets, so Canada is not unusual in that respect. What is unusual is again this discrepancy whereby industrial chemicals are subject to rules of disclosure, to rules governing trade secrets and confidential business information, whereas data sheets are not.
There's a rather different question, Mr. Mancini, about the volume of chemical pesticides used in Canada. There is no monitoring system for the volume of chemicals sold or used, and I believe I'm correct in saying that Canada is almost unique in this regard. I believe it's only Slovenia, among the industrialized countries, that has no such rule.
Mr. Peter Mancini: Thank you.
The Chair: Mr. Reed, please.
Mr. Julian Reed: Do you differentiate at all among biodegradable versus non-biodegradable pesticides, that is, pesticides that are consumed by soil bacteria after application within a relatively short period of time?
Mr. Dave Bennett: When chemicals are evaluated, including pesticides, there are conventionally three categories addressed in assessing a chemical. One would be persistence, how long it lasts in the environment; a second would be bioaccumulation, how much it accumulates in the food chain; and a third would be toxicity of various sorts.
If you took the profile of a chemical, quite clearly a chemical is going to be less hazardous, less harmful, less dangerous if it persists for a shorter period of time than one that has a high degree of persistence. This is only one factor among several factors in a chemical evaluation. Quite clearly, if a chemical is less persistent, on the face of it, it's going to be somewhat less dangerous than one that lasts for a very long time.
• 1105
However, one of the misconceptions about
persistence is that it's automatically assumed that
since one chemical has a half-life that is
considerably smaller than another chemical, its
potential for affecting human health, for example,
is thereby automatically going to be less. This is not
so. If you're constantly polluting the
environment with a chemical, it's no consolation to
know that for any one unit it's relatively benign in
terms of its persistence, because you have the
constant loading of the environment with the pesticide.
Also, until that pesticide actually disappears, it's still capable of producing both chronic and acute health effects on human beings. It can also contribute to environmental degradation. So although persistence is an important factor, I don't think its significance should be overrated when you're looking at the overall toxicity profile of a chemical.
Mr. Julian Reed: Would you prefer that pesticide use be done away with?
Mr. Hassan Yussuff: I guess the answer would be yes. Its toxicity is quite far-reaching in human health. And we're concerned about human health.
Mr. Julian Reed: There's a serious question that follows that.
Mr. Hassan Yussuff: Yes, I do recognize it.
Mr. Julian Reed: The only thing worse than finding a worm in an apple is finding half a worm. How many half worms will you tolerate when you go to the grocery store to buy your apples?
Mr. Hassan Yussuff: There may be another mechanism that can be used to deal with some of the claims the pesticide industry continues to try in order to get us to believe these are the only forms of dealing with certain pests within our environment.
Mr. Julian Reed: I've been involved in agriculture all of my life and I do know there are management techniques you can apply in certain situations that will reduce the pest count. The question is, where is the level? For instance, if I am going to do the kind of management to try to reduce the amount of pests in my orchard without using any pesticides, there will always be an infection of pests or some other thing that now I would spray for. If that product is not suitable for sale in a store, it means the product that remains and is suitable for sale comes at a much higher cost. How are you prepared to make that compromise?
Mr. Hassan Yussuff: If you're going to measure the question of cost, we have to measure the cost of ill health that the system absorbs, and it's never measured. That's the other measurement we have to use. Quite often, the effects of an exposure to a pesticide is not seen immediately. We see it over a period of time through a number of problems that people start having with their health. So we don't measure it.
It's like second-hand tobacco smoke. Immediately you can measure the effect, but over a period of time I don't think we can measure the effect. We know there are effects on human health. If we want to deal with human health over a long-term period, we have to start looking at alternatives to ensure that pesticide contaminants getting into our bodies are not going to be as prevalent as they are now.
It means that workers have exposure to these pesticides through the spraying of their fields, their trees and end up using them in their day-to-day responsibilities. We need to be cognizant that this is going to have detrimental effects on their health. We need to be recognizing that in terms of the regulation that needs to be there.
Mr. Julian Reed: Forty years ago we were spraying apple trees with heavy metals, and I happen to be one who was. We moved then to things like organophosphates and organochlorines, which seem not to have produced a larger body count than the application of heavy metals.
• 1110
I'm trying to put this into some perspective, because
the recognition of the need for some kind of pest
control, or the beneficial impact, was known many, many
years ago, but after a period of time we
realized the kinds of pesticides that were being used
were not good, and we should be using something else.
Well, now we are using something else, and it would
appear that the impact on general health, etc.,
has not increased over that period of time.
Maybe my exposure was the thing that got me into politics, I don't know.
Mr. Dave Bennett: It drove you out of farming.
I think it's a complex question, and a very fair one. The Canadian Labour Congress is a member, in fact a founding member, of the Campaign for Pesticide Reduction. And note the title. It says “reduction” in the use of pesticides. I don't think anyone claims or pretends there will be zero exposure of the Canadian public, Canadian workers, and the Canadian environment to chemical pesticides. What we want to see is a drastic reduction in the use of chemical pesticides and treating chemical pesticides as if they're something that sometimes and for some industries you have to use—they're necessary—but not to see pesticides as an integral, routine part of agricultural practice.
The second thing is that no one is advocating cold turkey. No one is saying, as of the year 2001 there will be no more chemical pesticides used. What we're advocating is a regime for pesticides that acknowledges that most chemical pesticides are highly dangerous pollutants and it would be better if they were not used at all. If they are used, use them as parsimoniously as possible. Use them on occasions only when it's necessary. If there are regimes that require the repeated application of pesticides, look very seriously at those regimes to see whether the spraying and application is necessary.
There has been much work in many universities to show that, even using current agricultural techniques, you can get a 50% reduction in the use of any given pesticide if the application conditions are looked at properly.
So if you combine a regime for restricting registration with the promotion of genuine alternatives, we believe you're going to see a dramatic and effective shift in the pattern of chemical pesticide application and, by the same token, see a shift in the pattern of Canadian agriculture and horticulture.
We don't think this is an unreasonable thing to ask. We don't think it is some sort of pernicious public policy. We don't see it as something that is set to ruin farmers and entrepreneurs.
Mr. Julian Reed: Every farmer would agree with you. Every farmer who is using pesticides at the present time would agree with you 100%. They have no stomach for spending money that is unnecessary in the growing of a crop, none at all. They won't use a pound more pesticide than is deemed to be necessary to achieve the goal.
I would say they'd be in total agreement with what you're saying about reduction. They're on the front line. As a matter of fact, one of the reasons for looking at new pesticides that are registered coming into this country is to look at the ones that are more biologically friendly and where less of the pesticide needs to be used to achieve the same purpose.
The Chair: Thank you.
Madame Torsney, followed by the chair.
Ms. Paddy Torsney: I have just a quick question. Do you have a program of encouraging your members in their own choices for their lawns, a pesticide reduction program that you can submit to us? You must have done some public education internally.
Mr. Dave Bennett: We do. The congress's education program on chemical hazards, which includes pesticides, has a number of strands to it, and one is what we call elimination of the hazard at the source. That means to stop the exposure of workers completely by restricting or banning or otherwise eliminating the pesticide. Then there's a regime of control measures that says once a pollutant is present in the work environment, or in the social environment, there should be proper controls on it to restrict exposure as much as possible.
Thirdly, there are personal attitudes, personal behaviour among workers, both in the workplace and in the social environment, that involve responsible behaviour, lifestyle choices.
For us there's a hierarchy of, first of all, trying to eliminate the chemical, to ban it, to phase it out, to impose use restrictions on it. Then, secondly, there's a regime of control measures, and thirdly, the lifestyle and personal behaviour as a third line of defence.
So it's there, but I have to emphasize that it's not the ideal way of restricting exposures to chemical pesticides. I mean, if children's school grounds are being sprayed with highly dangerous chemicals, it's really asking an awful lot to tell the children, well, you should really take care, because if you're not careful you're going to be exposed to chemical pesticides.
Mr. Hassan Yussuff: Also on the one point, we have worked with a lot of our labour councils across the country to get municipalities to stop the outright use of pesticides on public property per se. It doesn't mean an individual can't have their property sprayed with pesticide to control their lawn pests, and what have you.
Ms. Paddy Torsney: But that's my point. Apparently homes are actually one of the highest concentrations, more than farmers' fields and other things. So through all of your membership, which is a pretty impressive number of people across the country, you could see a dramatic decrease in pesticide use in people's homes if you were to educate your own members.
You send them all kinds of information, and you obviously care about the issue. I'm just trying to ask what you are sending them about the choices, so they can arm themselves with the information and make better-informed choices about their own gardens, and therefore perhaps influence at the PTA whatever is happening with the schools.
But it would be helpful if we're going to be talking.... We were talking to the waste water people about what they're doing, the municipalities about what they're doing, to educate people about the choices they're making on their own lawns, and you obviously have a lot of research and information. I'm just wondering what you're sending out.
Mr. Dave Bennett: As we pointed out in the submission, we are a founder member of the Campaign for Pesticide Reduction, and much of our public education takes place through the campaign.
When the campaign started, well over half of the members of the campaign were either labour councils, local unions, or individual workers, and it's an essential part of that campaign to work for the abolition of the cosmetic use of pesticides in municipalities, and abolition by individuals, by the private sector, and by the municipal government. So there's a very high degree of participation of workers in the campaign, and the educational aspect of the campaign is one of the most prominent things undertaken.
Ms. Paddy Torsney: So we can get a copy of whatever that would include? I don't think it's here.
Mr. Hassan Yussuff: Yes.
Ms. Paddy Torsney: Okay.
The Chair: I suppose what Paddy Torsney is diplomatically trying to ask you is whether or not you are actively campaigning with your membership to encourage the reduction of cosmetic pesticide uses at the level of your membership.
Mr. Hassan Yussuff: The answer is yes.
The Chair: If you do, could you let us have some documentation to that effect?
Mr. Hassan Yussuff: Yes, we will.
The Chair: Thank you.
I suppose what Mr. Reed is also driving at, which is an issue we will have to face very soon—I believe the organic farmers will be here before our committee next week—is the following question: There is a general belief out there that with the use of pesticides the cost of food is lowered, and that with a reduction in the use of pesticides the cost of food is higher. The cost of one tomato treated with pesticides, per unit in the marketplace, is apparently one-third of the cost of a tomato produced without pesticides. So this committee will sooner or later be facing this economic Rubicon; we'll have to cross that river. Do you have any comments to make on that general belief?
Mr. Hassan Yussuff: Yes. This is a debate about the consequences of using pesticides on human health and what we are prepared to bear in terms of cost to reduce that.
There are some pesticides about which we know what ill effects they may cause in human health over a short period of time. What we don't know is what would happen if you continued to ingest it and have it in the food chain over a long period of time. In terms of public health, any ability to control or restrict or reduce the use and its effect on human health is a desirable one, even if it costs more. We have seen in the manufacturing side of this that we have been faced with some of the same choices.
In my own union, there was a good example. In the manufacture of foam, which is on your chair, there was a chemical that used to be used. The effects of that particular chemical on human health was far-reaching. You become sensitized overnight, and you can't do anything about it once you become sensitized. Over a period of time, we worked to eliminate that particular chemical from the workplace completely and to bring in something else that was less harmful to workers in terms of exposure. Thousands of workers suffer from being sensitized, but today in the industry that's manufacturing foam and using foam, it has resulted in a much friendlier workplace.
Of course there was a cost, but the cost was necessary, otherwise it only takes one split second for somebody to be exposed and for them to become sensitized for their entire life. Now, it's a cost that's borne by the industry. Of course, you and I wouldn't know there had been a shift, but the reality is that there has been a shift in the use of chemicals.
I think that is a reasonable balance. For the Canadian Labour Congress, in any reduction of the use of a pesticide that has ill effects on human health, if there is a cost, I think in a general nature we would support that, because we recognize that to have fewer sick people and the public system having to pay for that is something we believe is more—
The Chair: Even if it means a higher cost of food?
Mr. Hassan Yussuff: Yes, even if means a higher cost of food. All of us make choices, and if you were to give people a question of choices, that of eating food without chemicals or food with chemicals, I think a lot of people would say, yes, I would prefer to have that choice.
The Chair: Mr. Yussuff, in the last paragraph on page 2 of your brief, you refer to the fact that re-registration has not been denied when less unsafe alternatives have appeared. Could you give this committee an example or two of names of products that have been re-registered even when alternatives have appeared?
Mr. Hassan Yussuff: My colleague will answer that.
Mr. Dave Bennett: It's difficult to prove a negative, because we are saying that every application for re-registration has been approved. Manifestly, there is no consideration in the registration process of the availability of less unsafe alternatives.
The Chair: There is no consideration in the examination of the re-registration? Is that what you mean?
Mr. Dave Bennett: Right. There's nothing in the act that requires or even indicates that the registration body actually does that. We can safely assume that in fact it's not done.
As just one example, if you look at the domestic spraying of potato crops, a range of treatments can be used, starting from synthetic chemicals going down through biological agents to chemicals whose toxicity would be manifestly less than those at the higher range of registered pesticides.
We claim that the question never being asked is whether there has been any attempt to restrict those products of higher toxicity and to restrict them through the registration process. We can confidently say the answer is, no, there hasn't. The question has never even been addressed.
I have one further comment on the cost of produce. It's a very uneven playing field right now when the odds are stacked against organic farming. We're not advocating that treated food become more expensive. We're simply advocating alternative methods of pest control and the advocation of those methods through changes in the registration system.
The fact that you have an uneven market there doesn't seem to us to be a criticism of the proposals we're making. After all, we're not telling growers to stop using chemical pesticides, where the result will be that their produce will have to go up in price to match the price of organic foods. We're not saying that. The market impact is not going to take place in that fashion or in that time scale.
With due respect, then, it's an unfair question.
The Chair: Well, it may be unfair, but we have to face it, and we will face it, as I mentioned to you, when we hear from the organic farmers.
With the benefit of hindsight, Mr. Bennett, and with a new piece of legislation, do you think PMRA should continue as it is organized at the present time, without a legislative mandate?
Mr. Dave Bennett: Our concerns are twofold. One is with the registration process itself and the other is with the concern to add right-to-know provisions to the act when it's revised.
As we've said, the act does, or seems to do, a good job of monitoring the introduction of chemical pesticides into the Canadian environment, but if you're looking for the act to do the one thing that will at least address the issue of chemical pesticide pollution, then it fails utterly to do that.
I would hope that parliamentarians, in consultation with progressive scientists and progressive risk analysts, would come up with a formula that could be incorporated into the law whereby the Pest Control Products Act becomes a restrictive act and not a permissive one.
The Chair: Thank you, Mr. Bennett.
Second round, Mr. Mancini.
Mr. Peter Mancini: No.
The Chair: Second round, Mr. Reed.
Mr. Julian Reed: No.
The Chair: Perhaps I can ask you, Mr. Bennett, before concluding, to expand on a sentence in the last paragraph on page two of your brief, where you say, “The PMRA utterly fails in the one device it has within its power to avoid the creation of chemical pollution”. Can you perhaps elaborate, with some examples?
Mr. Dave Bennett: If you look at pesticide registration regimes in such countries as Sweden or Austria, you find a very different public policy approach to pesticides. The approach in Canada, and for that matter the U.S., seems to be, look here, chemical pollution is an inevitable part of industrial life, and it's a characteristic of industrial societies. We should keep tabs on it, we should monitor it, but basically we're not prepared to do anything about it as a society except in extreme cases and as a result of a judicial process where a ban, a restriction, or a phase-out is required by law.
In other countries, the public attitude is very different. The attitude says, yes, of course we have to use chemical pesticides, but these are highly dangerous to the environment, to wildlife, and to human health, and therefore they should be restricted as much as is compatible with agricultural efficiency, the production of food, and the protection of social amenities.
What happens? First of all, you get the mindset that we have to restrict the sheer number of products on the market. In those countries, which admittedly are very different from Canada geographically and in terms of climate and terrain and so on, you get restrictions of chemical products going down to single figures. They're prepared to admit only a certain number of products on the market.
You can see that in whole areas of social policy, which includes dyestuffs in the textile industry and chemical pesticides in agriculture, there is this mindset that part of the problem is the sheer proliferation of the number of products on the market, and that society will not get a handle on chemical pollution unless it restricts the numbers of products available.
Then there are also qualitative restrictions in that you take the universe of chemicals and then you look at their possible applications. Then you decide which of these chemicals we can do without. Again, it's the restrictive attitude, that you want as few as possible and as small amounts as possible used.
Above all, you use the public policy device of an act of Parliament to do it. You don't rely solely on an alternatives agency within the government or within governments. You don't rely solely on public education and public pressure. To choke off chemical pesticides at their source, you use the one device you have, which is the Pest Control Products Act.
We don't claim to have all the answers as to how this can be done, but we're asking this committee to look seriously at the registration process, at the registration criteria, so that when the bill to amend the act finally appears from the government—and it's like waiting for Godot, I'm afraid—there will be a serious public debate on how you restrict the entry of chemical products into the marketplace. Therefore, that requires a radical change in the philosophy that surrounds the act itself.
The Chair: Has the CLC been consulted on an excerpt from a proposed bill that apparently has been circulated in recent months? If so, what are your observations?
Mr. Dave Bennett: We've been involved to a degree in consultation processes with Health Canada and with the government, but our attitude has been ambivalent and the attitude of the government has been ambivalent.
We first declined to participate—“boycotted” is too strong a word—in the work of the Pest Management Advisory Council when it was set up in the early 1990s. Our position was that, frankly, the changes in the act were not significant enough to warrant public consultation.
When we asked for representation on the new advisory body to monitor the introduction of the bill, we were refused membership, or our membership application was declined, partly for good reason, I think, and partly bad.
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The fact is, in some areas of public policy the CLC
has been out of the policy-making loop. If drafts of
the bill have been leaked, we haven't seen them,
although we do understand, through contact with Health
Canada, that some of the concerns over the right to
know would be incorporated into the new bill.
The Chair: Is the CLC now available for consultation, and if so, has the government been notified to that effect?
Mr. Dave Bennett: Yes, we're available, and we've notified the minister that we are available for consultation.
The Chair: But you've not been part of this recent consultation on a proposed bill?
Mr. Dave Bennett: No, because our membership in the council was refused.
The Chair: Have you seen this document, “Proposed Amendments to the Pest Control Products Act”, dated January 1999?
Mr. Dave Bennett: No.
The Chair: And you've not been consulted?
Mr. Dave Bennett: No.
The Chair: Look, it's now pretty late. Again, we apologize for holding you up for an extra hour. We appreciate your patience and the quality of your input. It's certainly a serious shortcoming that you are not being consulted. We will make, in a quiet way, representations to the minister to that effect.
We thank you very much.
Mr. Dave Bennett: I thank the committee.
Mr. Hassan Yussuff: On behalf of the congress, thank you very much. I know some of you who get relegated to these committees can think these are very mundane tasks, but we do recognize it is important work, especially in the area of having information for our members to know what they're actually dealing with. We've been arguing for that information for quite some time.
There needs to legislation there. It's not there currently. In your deliberations we hope that will be a strong recommendation in that this is valuable information for us. We have it in a number of areas already, but one area we don't have it is in the workplace. We need to have it, because it allows our members to know what they're working with, if they're exposed to it, and how they would then react to it.
Again, on behalf of the congress, we want to thank the committee for the opportunity to present today.
The Chair: Thank you, Mr. Yussuff.
The meeting is adjourned.