Madame Chairman, and  Members of CAB, and Honoured Guests,


Air-quality and industrial air pollution

has been a very big public health issue in Canada

in the last couple of years.


I think that we have to recognise the very strong contribution

that the Environmental Commissioner of Ontario

Mr.Gordon Miller ....

has made to our understanding

of the regulation of industrial air pollution in Ontario.


Although his office has no power,

in his last four annual reports ,which I commend to you.

Mr. Miller really has done a very good job

 in focusing on... how far behind

Ontario regulators have been the matter air quality.


The most recent edition of the Commissioner's report

is entitled ....Neglecting Our Obligations.


(The cover page shows a number of smokestacks in the background,

And the silhouette of a child in the foreground,

Itself a powerful image.)


 On page two of that report Mr Miller quotes Winston Churchill

 who in the British House of Commons in 1936

said " the era of procrastination, of half measures,

of soothing and baffling expedience, of delays,

is coming to its close.

 In its place we are entering a period of consequences."

Some the consequences of those half measures,

 and expedience,.... and delays... by various governments

in the regulation of industrial air pollution

in terms of human health effects ...are now better understood.


This has been apparent in the medical literature

In the past few years.


If you want to understand the health effects of industrial smoke

A good place to start would be with

The health effects of cigarette smoke

Which are quite well understood now,

And which are many.


There are said to be some 4000 chemicals in cigarette smoke.

There are probably a lot more industrial smoke.


Cancer Care Ontario, our provincial cancer agency

has had a lot to say , of course about cigarette smoking

But  about two years ago , CCO

Published a report on the health effects of

industrial smoke, and air pollution.


In that report in essence they said that

industrial smoke , like cigarette smoke

causes ....heart and ......chronic lung disease,

and probably causes lung cancer

as well has having effects on unborn children.


So the similarity in the health effects of the two

Is quite a powerful connection to make.


And I commend that report also to you.

It is available on the Cancer Care Ontario website.



Another quote from Mr. Churchill is also relevant.

In 1901, he said,


"I have noticed within the last three years

 that we have been very engaged in a tendency...

To hush everything up,

to make everything look as fair as possible,

to tell what is called the official truth,

to present a version of the truth

which contains about 75 per cent.... of the actual article. "


That was in 1901,

and apparently some things never change

because that is what I find disturbing

about the situation here in Bath.


The whole truth about what is going on here

is not being told... either by the company,

or.... by the government regulator.


And why do I say that?


Well, first of all.... what kind of waste is going to be burned here?


The company says, non hazardous waste,


And the regulator, does not disagree.


But the first point is that  

Tires, for the most part,

Are not made from natural rubber any more.

They are made  from synthetic chemicals,

Principally styrene and butadiene.


These are classified as toxic chemicals

under the Federal Environment Protection Act.

Therefore tires are hazardous waste.


And the second point is that

Your people have discovered that

Other types of hazardous waste

have already been imported from the United States

and have already been burned at Lafarge,

sometime in the last two years.


And this was apparently done

with the full knowledge of the MoE,

without any announcement to the public,

and presumably with no meaningful monitoring

of stack discharges whatsoever.


Personally I find that to be outrageous.


Secondly how will the process be monitored?


According to the MoE

monitoring will be ......Strict ....and Stringent

....and Rigorous............and Continuous .


But the first problem is that

 the guideline which will be used to regulate this process

will be the A 7 guideline

which is for the regulation of new Municipal waste incinerators,

which this facility clearly is not.


And the second problem

Is that there will be meaningful... monitoring

of the most toxic chemicals

that might be expected to leave the smokestack,

namely heavy metals,

dioxins and furans,

and carcinogens... such as volatile and semi volatile compounds.


For these toxics, annual sampling is to be done.


This consists of 3 hour  samples...

taken three times....  on one day.....  once each year.


And that amounts to about 1/1000

of the total time of operation of the facility

that monitoring will be done for these very toxic compounds

 and this is described by the company

and worse by the MoE, the regulator

 as "continuous" monitoring.


So the government has decided to do an experiment here in Bath.


And the rest of the  many cement companies

in the Great Lakes Basin

will be eagerly awaiting the results of this experiment.


But if they were to look just 120 miles due east of here

to Ticonderoga, New York,  which is on the border with Vermont

they could anticipate the result of the experiment.


Because ..the International Pulp and Paper Company

has recently,  about two months ago,

shut down a pilot tire burning project

after they were surprised to  find

high levels of toxic emissions coming out of their smokestack.


So the experiment has already been done, and it failed.

Our Ontario MoE

In defending their decision to perform this experiment

say that they have "no experience

monitoring the environmental performance

of facilities that incinerate tires."


But it is not especially clear

that they would be able to learn from their experience

even if a proper monitoring program... is put in place.


I say this because  as we speak

an experiment in burning hazardous waste

is under way neighbouring Trenton, Ontario.


And the  performance  of the MoE

in that case speaks volumes

about the ability of the regulator to monitor this type of facility.


Norampac in Trenton,

which is doing very good work in recycling cardboard fibre,

built a facility called a Steam Reformer in 2002

in order to burn pulp waste

which contains low levels of dioxins.

This was an untested, experimental technology.


In December 2001

the Minister of Environment , in a letter to me ,wrote that,


"The Certificate of Approval (C of A)

for Norampac's steam reformer

imposes very Stringent operating and monitoring conditions....

....There is to be Continuous monitoring

of the operation of the Steam Reformer"


That was in December 2001.


Well, since that time , and as of today,

5 years after the Minister's letter,

And after perhaps 2 or 3 or 4 years of operation (we don't really know)

despite repeated requests,

absolutely no data whatsoever ... about emissions

has been produced by the regulator.


So this is not a reassuring testimonial

to the ability of the MoE

to deliver on the grand promises ....of intensive monitoring

that they made that particular project.

Finally, more than two years ago now,

as Acting Medical Officer of Health of Hastings and Prince Edward

I submitted a 28 point Document to the MoE

Which raised questions about  potential public health problems

with the Lafarge proposal .


Under the Ontario ...Health Protection Act,   Section 12

The MOH is obliged to investigate

environmental issues of potential public health significance,

 and  the MoE in turn is obliged  to provide information

on those issues, as requested.... to the MOH.


And that point had been doubly emphasised

At the Walkerton Commission by Judge O'Connor

who noted the importance of co-operation

between the  Ministry of Environment

and Ministry of Health

whenever a potential public health threat arises,

as it has Bath.


However the MoE never answered

my request for information,

and certainly never denied,

the 28 points that were made.


That document is as valid now as it was then .

These 28 points need to be addressed by the regulator

before this project goes any further.


The recent decision  by the Ontario MoE

To allow the Lafarge Cement Company in Bath

To burn tires and other hazardous waste

Is not appropriate.


In my opinion the decision suggests

That the wrong government department

Is regulating industrial air pollution in Ontario.


This is a human health issue.


And it is the Ontario Public Health officials

Who are the experts in human health,

Not the MoE.


So it is the Department of Health

That should be making this decision,

And it is to them,     I think,

That we should appeal... until we get some answers.



And the questions that need to be answered

Are around the 5 points that I have made this evening:


1.     The Lafarge kiln will be burning hazardous waste.

2.     "Continuous monitoring" actually means no monitoring at all

                                                  for the most dangerous emissions.

3.     Trenton, needs explanation.

4.     Ticonderoga, needs to be considered.

5.     The 28 public health points, need to be addressed.



In conclusion,


I compliment Clean Air Bath........

And the Loyalist Environmental Coalition..........

And Clean Air Kingston.........

On your work.

You are doing very good work, very worth while.


Do not be discouraged.


Do not give up.


You have a very strong case here.


It took the Concerned Citizens of Tyendinaga

10 years stop the expansion of the Richmond Landfill

But stop it they did.


If every one  you out there tonight
spends just 5% of your time on this thing can do  the same.


And I'm telling you.....

if there is one force that Corporations...

and Governments .....and Politicians......are afraid of

It is that of Women in the community....

Who are acting to  protect..... the Children... of the community.


So please the people

who have organized this meeting... this evening..


M. Chairman


Alban Goddard-Hill

Eastern Lake Ontario Environmental Research Group/

                                                Waupoos Institute of Public Health and Environment

January 2007