Letter to Hastings Prince Edward Medical Officer of Health, April 3, 2006


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

General and Family Physician

306-210 Dundas Street East

Belleville, Ontario

K8N 5S8 613 968 8692


April 3, 2006


Dr. Richard Schabas

Medical Officer of Health

Hastings-Prince Edward Counties Health Unit

179 North Park Street,

Belleville K8N 4Z5


Re: Regulation of Industrial Air Emissions in Ontario


Dear Richard,


Further to my letter of November 30, 2005, thank you for your January 4, 2006 acknowledgment.

Review of five cases in the region, namely Norampac (Trenton), Lafarge (Bath), Essroc (Picton), Canadian Waste (Napanee) and Material Resources Recovery (Cornwall) suggests that there may be significant deficiencies in industrial air emissions regulation by the Ontario Ministry of Environment in the areas of certification of operational approval, establishment of appropriate air standards, and monitoring and enforcement of existing standards.


For example, some of these firms appear to be effectively certificated to operate hazardous waste incinerators without being publicly identified or regulated as such.

The MoE response (or lack thereof) to the October 2004 submission of the HPE Acting Medical Officer of Health on Lafarge is another in a series of eastern Ontario point source air quality regulatory concerns which have arisen over the past seven years.


Furthermore, the Environmental Commissioner of Ontario in his last two annual reports has indicated that Ontario air standards are thirty years out of date.


The mandate of the MoE is the protection of environmental and public health. However, examination of the eastern Ontario cases suggests a pattern in which the MoE has placed priority on protecting the interests of industry.


Because chemical air pollution is an agent of human disease, and because there are questions regarding the effectiveness of the Ontario MoE as the air quality regulator, I request (1) that the MoE response in the Lafarge case be reviewed; (2) that the status of monitoring of the other four facilities be reported upon; and (3) that a public inquiry into the regulation of industrial air emissions in Ontario be convened.


Sincerely yours,


A. C. Goddard-Hill