Public meeting, Wilson Room, Kingston Public Library


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


Air-quality and industrial air pollution  

has been a very big public health issue in Canada

in the last few years.


In November , the Environmental Commissioner of Ontario,

Mr.Gordon Miller ....held a public meeting

Here .... At Kingston City Hall,

as part of a series that he held.....across the Province.


I think that we have to recognise the very strong contribution

That Mr. 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.                         (Show)


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

And the silhouette of a child in the foreground.


This image itself is a very Powerful one.



On the inside cover  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 very well understood now,

And which are many.


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

There are probably a lot more in  industrial smoke.


So you can draw your own conclusions.



Our provincial cancer agency........Cancer Care Ontario

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.                         (show)


In that report.....CCO  said that

industrial smoke , like cigarette smoke

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

and probably causes lung cancer

and as well has effects on unborn children.


So the similarity in the health effects of the two

Is quite a powerful connection to make

As you think about this subject.


And I commend that report also to you.

It is available on the Cancer Care Ontario website.

Another publication to be aware of is

a recent paper by Grandjean and Landrigan

from the Harvard School of Public Health.    (show)


 The paper is entitled

Developmental Neurotoxicity of Industrial Chemicals.


In was published in the Lancet  ,           

Coincidentally,        in the same week

that the MoE

Made their  December announcement.


I think this is a very important paper

to  consider.


It describes yet another aspect

of the human health effects

Of industrial  pollution.



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 do not  change

because that is what I find disturbing

about the situation here in Bath....


Because in my opinion

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 there?


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, at the end of their useful life

tires are hazardous waste.


And the second point is that

Your people, at Clean Air Kingston,  have discovered that

Apparently,  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.                         (Show)


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 particular revelation...

To be very disturbing.



Secondly,   and again in the truth telling department,

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.....  as particulates,

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.


So,  if you work it out..... 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.


1/1000th  of the time.

So the government has decided to do an experiment

in Bath........and in Eastern Ontario.


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  ....60 miles to the West of here

in 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 a contaminant.


This,          the Steam Reformer process.

 was an untested, experimental technology.

In December 2001

the Minister of Environment ,

who at the time was the Hon Mr. Stockwell,

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.


However , the reality has proved to be very different.


It was just 2 weeks ago      that the MoE revealed that

3 months ago, sometime in mid October

Stack emissions testing was done at the Steam Reformer,

 apparently for the first time,

And that  data is currently "under review" by the MoE.


So in other words, since December 2001

and as of today, ...5 years after the Minister's letter,

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

despite repeated requests......  

absolutely no data whatsoever ...

about emissions from that facility

has been produced the regulator

for public review.


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 Counties

I submitted a 28 point Document to the MoE

in which I 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 was 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 seems to have 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 public health 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 emissions 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.



On Nov 23, of this past year

the KFLA Board of Health passed a motion

which requested that the MoE  conduct

an Env Review Tribunal Hearing

On the Lafarge proposal.


This was one year after the government had announced

That they would not do a full EA on the proposal.


On Dec 20, the KFLA Board

received acknowledgement of this request

from the MoE.


Then,  the next day, on Dec 21,  the MoE announced

That no such Hearing would be held ,

And that the project would proceed

when the Company was ready to do so.

Now through all of this exercise

We have heard about  a number of Lawyers

Who have been very busy... filing Appeals

To the December, Christmas Eve, decision by the MoE,


But.. we have heard very little from Doctors.


And...This is rather odd, because again

at bottom, this is a human health issue.



However, we are very fortunate

here in Eastern Ontario.


First of all we have right here in Kingston

The very best medical school in the whole country,

And at that school.... there are many outstanding specialists

in heart disease,  and lung disease.

and cancer, and reproductive medicine,

And public health.


So perhaps some of these doctors

Will have something to say about the proposal.

Secondly, at the two Health Units in the region

Which are the Kingston,   and the HPE Public Health Units

We happen to have, again, ....two of the best

public health the country....

Two very experienced ...and very capable

Medical Officers of Health.


And I would think that

Now that the MoE... has repudiated

the motion... from the Kingston Board of Health....


and therefore , for a second time in this case,

has apparently ignored the statutary requirements

of the Ontario Health Protection Act......


That now...... is the obvious time

for these Medical Officers of Health

to take up this question publicly

and to act as Advocates..... for this community.

It is the Department of Health ...and the Chief MOH of Ontario..

Who have the Power.... to Stop this project,

Not the MoE.


As Mr. Miller, the ECO,  has recently pointed out

Of every dollar of the Ontario Provincial Budget

the Ministry of Health gets 40 cents, or more

Of every provincial dollar.


The MoE,   on the other hand,

 gets 1/3 of one cent.

That is how much we are investing in environmental protection

In this province.....1/3 of one cent.


So the MoE... is not going to help us.


It is to.... the Medical Community

And the Department of Health....and the Chief MOH of Ontario ... 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 apparently 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 taken into account.

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


And I can tell you..... that Medical Officers of Health ....

love to get personal phone calls ...

from individual citizens

on public health issues.


So my advice to each and every one of you here tonight

Is to pick up the phone tomorrow

And call one, or both , of these doctors... to voice your opinion.

They are waiting for your call.



In conclusion,


I compliment the Council of Canadians,  Clean Air Kingston........

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

And Clean Air Bath.........

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.




M. Chairman


Alban Goddard-Hill

Eastern Lake Ontario Environmental Research Group/

                                                Waupoos Institute of Public Health and Environment

                                                          January 2007