From the Acting Medical Officer of Health, Hastings Prince Edward Counties, 2005


(Facsimile transcribed from original letter; website posting December 27, 2005)


Hastings-Prince Edward Health Unit



August 18, 2005


Hon Carolyn Bennett

Minister of State for Public Health,

Health Canada

Brooke Claxton Building, Tunney's Pasture Postal Locator: 0906C

Ottawa, Ontario KIA OK9


Dear Madam Minister,


Air quality, air pollution, and smog is emerging as a significant Canadian public health issue. One of the five essential functions of public health is to prevent chronic disease, including cancer, heart and lung disease. Smog appears to cause all of these.


This summer has been hot and sticky. The Ministry of Environment now publishes the Smog Index daily for each community in Ontario. Air pollution in Hastings Prince Edward has been significant on many days this summer. On a number of occasions I have had citizens approach me to say that they are aware of smog in our local Prince Edward Hastings air. And of course it is not unusual as a practicing physician to see patients with chronic lung disease and asthma who are in no doubt that their breathing is worse on smoggy days.


Does smog have an impact on human health?


According to WHO 2004 "air pollution has been conclusively linked to adverse health outcomes, particularly in the elderly, and in those with heart and lung disease." This has been well established in the medical literature, most notably regarding London, England, California, Mexico City, and Eastern Europe, to name some specific locations. It appears that Ontario has now joined that list.

In June 2005 no less than five expert groups simultaneously and independently published reports on the subject. They are: Toronto Public Health, the Ontario Medical Association, Cancer Care Ontario, the International Joint Commission and the Commission for Environmental Cooperation.


The first June report was the Combined Impact of Extreme Heat and Air Pollution on Mortality study by Toronto Public Health, Dr. David McKeown, MOH, Dr. Monica Campbell and Dr. Fran Scott.

An earlier (2004) study by Toronto Public Health attributed 1700 deaths each year in Toronto to acute and chronic exposures to five common air pollutants. Of those, 695 deaths were attributed to acute exposures alone, and the remainder was associated with long-term exposures to fine particulate matter. The 2005 Toronto study attributes 822 deaths annually (based on average annual mortality 1954 - 2000; 818 in Montreal, 368 in Ottawa) to air pollution.


The authors note "there is growing concern with the current direction of the federal government that relies increasingly on voluntary and educational mechanisms to achieve reductions in industrial air releases." Others have said the same about the approach that the Ontario provincial government is taking to the problem.


The 2nd June report, from the Prevention Division of Cancer Care Ontario was their document Insights in Cancer: Environmental Exposures and Cancer, in which the specific issue of air pollution is addressed by scientists led by Dr. Anthony Miller and Dr Donald Wigle.


Their observation is that in essence, air pollution has the same health effects as cigarette smoke. Dr. Wigle notes that air pollution causes "cancers, cardiovascular and respiratory diseases and possibly pre-term births and intrauterine growth restriction." The report notes that "overall, the evidence ... provides some support for an association between air pollution and lung cancer."


It is not a great surprise that smog would cause human disease. Smog is a complex mixture of chemicals, some 80,000 of which are currently in production in modern industrial countries. Many of these find their way into industrial emissions. Fine particulate matter is the vehicle for these chemicals. These ultra small particles penetrate into deep lung tissue when inhaled.


Smog includes particulate matter, as well as acids (Sox, Nox, HCI, etc), VOC's/SVOC's (which include a wide variety of carcinogens), PABTS (persistent bioaccumulative toxic substances, such as dioxins and furans) and metals. All of these compounds have toxic biological effects.


If we accept that smog causes disease, the next question is how much?


The Toronto Public Health report partially addresses this.


The 3rd June report, from the Ontario Medical Association has expanded our understanding by publishing their ICAP, Illness Cost of Air Pollution report, 2005 - 2026 Health and Economic Damage Estimates. This report estimates annual figures for health effects attributable to air pollution for the Province of Ontario as a whole, and also for individual jurisdictions.


For Ontario in 2005 according to the OMA there will be 6,000 premature deaths, 17,000 hospital admissions, 60,000 emergency room visits, and 30 million minor illnesses attributable to smog. (Note that these figures only include those deaths due to the immediate health effects of smog, such as heart attack, and exacerbation of asthma and chronic lung disease, and do not include health effects and deaths from long-term exposures, such as cancer.)


For Hastings Prince Edward Counties, 85 premature deaths due to smog are predicted for 2005. (The population of HPE is 150,000.) Compare this to 7 deaths at Walkerton due to water borne disease.

The elderly will suffer the great majority of these premature deaths. Children and infants with compromised health conditions may also be at risk


Smog is thus an agent of air borne disease.


Is it a stretch to believe that 85 people will die prematurely of heart attacks or exacerbations of chronic lung disease in Hastings Prince Edward this year?


Based on my own observations in clinical practice, I do not think so. There is a good theoretical basis for the view that a heart attack or a worsening of chronic lung disease (or after years of exposure, a lung cancer) can be caused by a chemical exposure from air pollution and smog.


How much chemical pollution is being released into the Great Lakes Basin environment where 30 million residents drink the water and breathe the air?


The federal governments of Canada (through the National Pollution Release Inventory, NPRI) and the U.S. (through the Toxies Release Inventory, TRI) have been actively reporting chemical releases into the environment based on mandatory self-reporting by industry for at least a decade now.


The 4th June report came from the International Joint Commission biennial meeting in Kingston, which considered these releases, and their implications for the public and environmental health of the Great Lakes Basin.


The mission of the IJC, (current Canadian chair, Hon Herb Gray, former Deputy Prime Minister) through the Great Lakes Water Quality Agreement (1972/8) is to preserve the biological, chemical and physical integrity of the Great Lakes Basin environment. To accomplish this goal, Zero Discharge, or Virtual Elimination of Persistent Toxic chemicals into the Great Lakes Basin has long been recommended by the IJC.


Unfortunately the actual figures for chemical releases are staggering in their inconsistency with this goal.


Various interpretations of the federal data are available, for example:

· 1 Billion Kg of chemicals are released annually by Canadian industry into the Great Lakes Basin, principally into the air. (Canadian Environmental Law Association, from federal and CEC figures.)

· 3 Million Kg of carcinogens are released into the same area annually.

· 600,000 Tonnes of VOC's (which comprise many of the carcinogens) are released annually in the Province of Ontario by industry. (MoE) 

· 13,760 T (= 1 M kg) of CEPA toxic/carcinogenic chemicals were released in 2000.

· 10% of 2002 releases were known or suspected carcinogens.




Another international commission, the Commission for Environmental Cooperation, released The 5th June report, entitled Taking Stock. The CEC was created through NAFTA, the North American Free Trade Agreement between the three countries, to monitor environmental quality. Taking Stock is the CEC's 9th annual catalog of toxic emissions. As did the IJC, the CEC found the volume of chemical releases by both countries to be unacceptable.


To these five reports I might add my own


Locally I have had the opportunity to look specifically at three industries, which have an interest in burning hazardous waste, a practice that is notorious for potential release of toxic waste into air, soil or water.

Company A is currently doing so, Company B has a license to do so, and Company C is applying for a license to do so.


Based on my review of these local examples my impression is that the Air Standards in this province, which these companies have to meet in order to achieve their objectives, are ineffective.


Thirty five years ago, Dr. Donald Chant, a Canadian scientist who founded Pollution Probe in 1969, and who headed the Ontario Waste Management Corporation in the nineties, warned that without effective control of industrial emissions we would be in the position that we find ourselves today.

His predictions have proved all too correct. Indeed, things seem to bad getting worse


The yellow dome of smog over the City of Toronto is a new summer spectacle.


The Canadian Environmental Protection Act regulates relatively few chemicals.

· Environment Canada is creating the Chemical Sector Sustainability Table to advise the department on regulation of chemicals. The CSST will be co-chaired by Industry Canada and the chair of Imperial Oil. The conflict of interest here is obvious.

· Ontario Ministry of Environment Air Standards, by the MoE's own description and by that of the Environmental Commissioner of Ontario, are 30 years out of date. An updating process which is to take into consideration human health effects of air pollution has been under way for 10 years now.

· One response by the Ontario MoE has been their proposal for a more elaborate Smog Index.

· The Organization for Economic Development (OED) identifies Canada as one of the worst polluters in the industrialized world.






To conclude, five important reports, from Toronto Public Health, the OMA, the CCO, the IJC, and the CEC all appeared in June 2005.


These reports clearly indicate the important impact that air pollution is having on the health of citizens in Hastings Prince Edward, in the Province of Ontario, in the Great Lakes Basin, and in North America at large.


The release of one billion kilograms of chemicals annually by Canadian industry into the Great lakes Basin is obviously completely unacceptable.


There has been a very clear failure by both countries to control industrial air pollution. In Canada, that is the responsibility of the federal and the provincial governments. The result is a clear and significant negative impact on public health. People are dying.


Madam Minister, you are a physician and the federal minister responsible for public health in this country. 1 respectfully submit for your consideration that in the matter of air quality and air pollution, there is a great deal of work to be done for the protection of the public health, and that you are well positioned to facilitate this.


It is well known, and 1 have heard corporate industrial engineers make the statement, that profitable industries can effectively control their poisonous discharges, but that they will only do so when regulations require mandatory compliance.


Therefore you have an opportunity here.


I invite you to do what you can to improve the situation.


Respectfully yours,



A.C. Goddard-Hill, B.Sc, M.D

Acting Medical Officer of Health


Chief Medical Officer of Health of Ontario, Dr. S. Basrur

Ontario Minister of Health and Long-Term Care

Ontario Minister of Public Health

Ontario Minister of Environment, Hon. Laurel C. Broten Federal Minister of Environment, Hon. Stephane Dion

Toronto Public Health, Dr. David McKeown

OMA, Dr. Ted Boadway

CCO, President & CEO Dr. Ted Sullivan

IJC, Canadian Co Chair, Rt. Hon. Herb Gray

CEC, Canadian Co Chair, David McGovern

Canadian Environmental Law Association, Mr. Paul Muldoon

Environmental Commissioner of Ontario, Mr. Gordon Miller