A.C. Goddard Hill, B.Sc, MD, CCFP
General and Family Physician
306-210 Dundas Street East
May 28, 2011
Chief Medical Officer of Health
Public Health Division
Ontario Ministry of Health and Long Term Care
11th Floor, Hepburn Block
Toronto ON M7A 1R3
Re: Clarington MSW incinerator C of A application
Dear Dr. King
Further to my previous correspondence with you of May and July 2009 on the Clarington municipal waste incinerator which proposal is now in a period of public review of application for Certificate of Approval by the MoE:
Recent literature suggests that 15% to 66% of Canadian women of reproductive age already carry a body burden of mercury which is at Lowest Observed Adverse Effect Level. (1, 2)
Paradoxically, current regulatory requirements in Ontario for the monitoring of toxic emissions into the air from industrial facilities for metals such as mercury are very crude indeed. Guideline A7 requires that air emission samples for these toxics be taken on one day each year. (It must be challenging to perform statistical analysis on one data point.)
It therefore appears that although significant amounts of mercury and other toxics may be released from the proposed facility, regulators will effectively have no idea what those amounts are despite their claims for “continuous monitoring”. A better description would be “no meaningful monitoring at all”.
Given the current detailed understanding of the effects of metals and particulates on human health, and in the specific case of mercury the effects of that substance on the developing human fetus, it appears that this facility may pose a threat to the public health. According to the literature previously cited body burdens of mercury in many pregnant Ontario women are already at the tipping point.
For these reasons and out of consideration of the public health I again call on you to stop the construction of this potentially dangerous facility. Clearly there needs to be a review of Ontario air standards using the model established by Justice Dennis O’Connor for water quality standards some years ago. As the Environmental Commissioner of Ontario has already noted, current Ontario air standards are inadequate. I and others have documented this elsewhere. The Clarington case is a good example.
Will you now stop this application for Certificate of Approval pending further review?
Alban C Goddard Hill
Eastern Lake Ontario Environmental Research Group/
Waupoos Institute of Public Health and Environment
cc. Wendy Bracken
(1) Fish consumption in pregnancy and fetal risks of methylmercury toxicity
Gideon Koren, MD FRCPC FACMT and John R. Bend, PhD
Can Fam PhysicianVol. 56, No. 10, October 2010, pp.1001 - 1002
(2) Healthy fish consumption and reduced mercury exposure
Counseling women in their reproductive years
Abelsohn et al
Can Fam PhysicianVol. 57, No. 1, January 2011, pp.26 – 30