A. C. Goddard-Hill, MD, CCFP
General and Family Physician
306-210 Dundas Street East
Belleville, Ontario K8N 5G8
May 24, 2009
Dr. Arlene King
Chief Medical Officer of Health
Public Health Division
Ontario Ministry of Health and Long Term Care
11th Floor, Hepburn Block
Queen's Park
Toronto ON M7A 1R3
Dear Dr. King,
Congratulations on your recent appointment as Chief Medical Officer of Health for Ontario.
Enclosed is some correspondence directed to Dr. Robert Kyle , Commissioner and Medical Officer of Health, Durham Region, on the matter of the proposed municipal waste incinerator in Clarington, Ontario.
I call on you to put a stop to this proposal, for the benefit of the Ontario public health.
Sincerely yours,
A. C. Goddard-Hill
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A. C. Goddard-Hill, MD, CCFP
General and Family Physician
306-210 Dundas Street East
Belleville, Ontario K8N 5G8
May 24, 2009
Dr. Robert Kyle, MD, FRCP
Commissioner and Medical Officer of Health
Durham Region
605 Rossland Road East
P.O. Box 730
Whitby, ON L1N 0B2
Dear Dr. Kyle,
Recently I have examined the Review of International Best Practices of Environmental Surveillance for Energy-from-Waste Facilities (Jacques Whitford) as well as the Generic, and the Site Specific, Human Health and Ecological Risk Assessment Reports (Jacques Whitford), as presented by the consultant to Durham Region in support of the proposed 400,000 ton per year municipal waste incinerator for Clarington, Ontario.
I have also attended a public meeting in Bowmanville on May 19 held in compliance with EA requirements for the project, and hosted by the consultant Risk Assessor.
As a result I am concerned that this project constitutes a threat to public health and safety in the Durham Region (most particularly to the community of Bowmanville) and Eastern Ontario, as well as being out of compliance with binational agreements on transboundary air pollution as developed over the past two decades by the International Joint Commission of the Great Lakes.
Enclosed are a series of five questions posed to the consultant Risk Assessors and which highlight some of the concerns. Many other relevant questions were also posed by members of the public in attendance.
In Risk Assessment theory there are two classes of human disease, namely Cancer, and Non cancer (i.e. "everything else") diseases. It appears that the calculation of risk for Non Cancer diseases is fundamentally flawed. Non Cancer disease risk is estimated from a Hazard Quotient , the Reference doses of which are based on toxicological studies, and which seem to virtually ignore the recent epidemiologic medical literature. This literature demonstrates increased risk of cardiovascular and lung disease from atmospheric Particulate Matter, as well as the occurrence of neurocognitive and developmental injury in infants and children accruing from metal and "organic" chemical environmental exposure.
Specifically, I do not believe that adequate consideration for the future health of children, pregnant women, and other adults in the community of Bowmanville, particularly vulnerable as it is located immediately downwind from the proposed incinerator, has been shown.
It is a matter of record that under the current regulatory program for air quality in the Province of Ontario, in excess of one million tonnes of chemicals are being released into the Great Lakes basin atmosphere annually by industry. Clearly the so-called science of Risk Assessment, as it has been practised by industry for the past 30 years, is allowing this to occur. Current Ontario air regulations in essence allow industry to dump as much chemical waste into the astmosphere as it wants as long as the wind is blowing in the right direction. Clearly there is a need for a Public Inquiry into air quality regulation in Ontario, just as there was for water quality earlier this decade under the auspices of Justice O'Connor.
You will recall that in February 2005, eighteen Ontario Medical Officers of Health were signatory to a successful Petition to the United States Senate in the matter of the effect of the proposed Clear Skies Act on American transboundary air pollution as it affects our country.
I also note your presence at the 2005 Shared Air Summit conference in which Dr. Carolyn Bennett, at that time Minister of State for Public Health, gave a speech about mercury pollution which is of great relevance in the Clarington case. At that meeting you inquired as to how Local Health Agencies can contribute to improving transboundary Air Quality.
Here is an opportunity to do just exactly that.
It would be an embarrassment if the clear air of Clarington were polluted by this project, and the City had to be renamed Foggington. The public health of the community, both financial and medical, would benefit from your intervention.
I compliment you on your excellent work as a public health specialist in our province these many years now. You have the power to stop this pernicious project. I call on you to do so.
Sincerely yours,
A.C. Goddard-Hill
cc. Dr. Arlene King, Chief Medical Officer of Health, Ontario
Dr. Richard Schabas, MOH, Hastings Prince Edward
Dr. Peter Munt, Chief of Staff, Kingston General Hospital
Dr. Elaine Macdonald, Ecojustice
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Site Specific Human Health and Ecologic Risk Assessment for the Clarington municipal waste incinerator: Public Meeting for presentation of the Report , including question and answer session, Tuesday May 19, 2009, Garnet Rickard Recreation Complex, Bowmanville, Ontario, 1900 - 2200 hours. (Panel included consultants from Jacques Whitford and Stantec)
Question 1.
Why are there no public health physicians on the panel at this public meeting organized to present the long awaited Site Specific Human Health and Ecologic Risk Assessment for the Clarington municipal waste incinerator proposal?
Answer. (various explanations given)
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Question 2
If I were a resident of Bowmanville
and I learned that I was going to be living
immediately downwind
of a garbage incinerator
that would burn 400,000 tonnes of garbage
every year.... for the next 35 years
I think that I would want some reassurance
that whoever is regulating this facility
is going to have a very good idea
of exactly what chemical emissions
are coming out of that incinerator smokestack,
because with the prevailing wind being SouthWest as it is,
living in Bowmanville, I might well find myself breathing in
some of those chemical emissions.
For an answer to this concern, I could turn to a Report entitled
Review of International Best Practices of Env Surveillance.
It was written by 5 highly qualified scientists,
including Dr. Olsson
and Peer Reviewed by a very eminent Public Health Specialist,
Dr. Smith
These people together have reviewed
5000 scientific papers,
in the course of their deliberations.
So one could conclude
that this is a credible and authoritative source.
And indeed the central message of this Review
seems to be very reassuring.
because the conclusion of this group
as it is stated in Option 1 (a), which is their recommended option:
is that (quote) "Robust.... Continuous ......
stack monitoring of combustion gases,
in Combination With
Annual source testing
would ensure ...... that chemical concentrations
used in the Risk Assessment are being achieved." (end of quote)
My question to you Dr. Olsson
is that in communicating with the public
about how ....monitoring ....of stack emissions is going to be done
is this a Clear Statement......or is it a Misleading statement?
(Option 1 (a) statement repeated)
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Answer: (consultant indicated that it is a clear statement to the public.)
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Member of the public, further comment:
Thank you for your answer.
Just for the Record, and with respect, in my opinion,
this statement about Robust and Continous monitoring
is a...... Very..... Misleading ......statement.... for the General Public.
In fact, I think it is a False statement,
The reason is simply that
the Statement..... Fails.... to make the Distinction between
monitoring of what I call Nuisance chemicals,
such as Nox and Sox,
which will give you a runny nose ,
or cause your asthma to be a little worse .....
and which will indeed be Continuously monitored.
It fails to distinguish between them and
the..... Nasty Chemicals,
such as Particulates......and Metals...... and the Carcinogens,,
which we now very well know
may cause, and do , cause....serious illness,
such as .....heart attack and..... lung attack ...... and brain attack (stroke),
and..... brain damage in children,
and ....cancer.
These nasty chemicals are not going to be monitored
Robustly and Continuously.
These nasty chemicals are going to be sampled......
once each year.......three times on one day...
with lots of advance notice to the Operators.
Indeed the numerous Carcinogens (SVOC, Pah, Mah, VOC)
will not be measured individually at all
(but rather as Total Organics, as Methane.)
This is not.....Robust.....Continuous monitoring,
Rather it amounts to ....no Meaningful Monitoring at all
as it will be monitoring that covers ... 1/1000 , if you work it out, 1/1000
of the annual operating time of this incinerator.
So this is a Very misleading, ambiguous statement
subject to misinterpretation ....by the public,
and I believe that it is falsely reassuring .....to the public.
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Question 3
Recently, in Eastern Ontario, a Risk Assessment was done
for various emissions coming from the smokestack
of a Cement Plant.... in a community in Eastern Ontario.
The Mercury emissions for that plant
were reported through the ESDM,
the Emission Summary and Dispersion Modelling,
as .....15 kg .......per year.
The RA on this case,
which was done according to standard Government of Ontario methods,
(AAQC methods)
as you have done here,
showed that there was
no......Human Health Risk from 15 kg of Mercury
and furthermore.... that the plant would have had to release
more than 100 times that amount,
in other words, more than 1500 Kg
of mercury each year
in order for the RA to trigger a human health alert.
To put things into perspective, 1500 kg of mercury
is about 1/3 of the total releases of mercury into the air each year
by the state of Texas,
which has been the largest industrial polluter
in North America for many years, so it is a significant amount.
So this case itself suggests that,
although you might think that RA
is a very ...Sophisticated... Device
when you look at these highly technical 3245 page reports
that in fact this case suggests that .. Risk Assessment.....
is a very Crude ...and Ineffective... device
for the protection of human health.
Because this RA seems to say
that if it wanted to, this company could discharge
1500 Kg of Mercury into the atmosphere
without triggering a human health Alert.
Dr. Olsson, my question is,
how much mercury will be released annually
by your incinerator,
when it is burning 400,000 Tonnes per year?
and how much mercury would have to be released
in order to trigger a Health Alert
using your Risk Assessment?
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Answer: (Consultant did not seem to know how much mercury would be released, and did not know how much mercury would have to be released in order to trigger a Human Health Alert using his Risk Assessement.)
***********************
Answer: (From the SSHHERA documents):
Mercury: 2 Tonnes over the life of the facility, (increasing the background burden by 50%)
Particulate Matter: 30 Tonnes annually, adding to the background burden of PM 2.5 which is already near the maximum level according to the Canada Wide Standard. (29 mcg at the Courtice monitoring station, 30 mcg CWS
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Question 4.
Both .....the Generic and the Site Specific RA 's
contain 128 ....Equations.
124 of those are...... equations that calculate
exposure of some individual person
to the chemical of concern
by each of the various routes,
e.g. inhalation.....skin absorption....eating... drinking.....etc
and these in turn are fed into
the final 2 equations each
for the calculation of
Cancer Risk, .....and Non Cancer risk ("Hazard quotient")
Of these 128 equations,
some have as many as 15 variables,
and , at a conservative estimate
there must be approximately.......1000.... variables
(and a few Constants in addition)
which lead up to the calculation
of Cancer..... and Non Cancer risk ....for each chemical.
With 1000 variables in the formula,
it appears that in each RA
there are 1000 opportunities
for Error in the Risk calculation,
to say nothing of a significant opportunity
for Manipulation of results.
(We have recently had two examples of this in Eastern Ontario.)
My question is:
Do you agree that... with 1000 variables
in the formula for calculation of Cancer and Non Cancer Risks
that RA is very prone
to Error,
and to Manipulation, of results?
Answer: (consultant seemed to find this question risible, and disagreed.)
Background Information: 2 Eastern Ontario examples:
In the first, an RA by the MoE on chemical emissions from a hazardous waste incinerator produced Exceedences for some carcinogenic chemicals. The response of the MoE on receiving these reports from the consulting laboratory was to send the data back for reanalysis "using a different model."
In the second Eastern Ontario example, in the late 1990's, a consultant Risk Assessor (GPEC International) found significant cancer and non cancer risks on a City of Belleville recreational site that was located on a former hazardous waste site. That RA was replaced by the City concerned with another Risk Assessor (University of Ottawa, Sam Kacew), who confirmed the findings of the first. The City then replaced that RA with a third, who found that there were no human health risks after their new RA. That Risk Assessor was Stantec (associated in the Clarington RA with Jacques Whitford).
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Question 5.
According to Risk Assessment theory,
there are two kinds of human diseases,
namely Cancer,
and Non Cancer (i.e. everything else) diseases.
Non Cancer Risk
is calculated using a Hazard Quotient
which uses Reference Doses
which are obtained........from the toxicologic literature.
However it appears to me
that the Hazard Quotient
that you have used in your RA
fails to take into account
the recent epidemiologic literature
on, for example,
the relationship between atmospheric Particulate Matter
and the occurrence of
Heart attack, .... and Lung attack, ......and Stroke in adults,
and, as another example,
the relationship between...
atmospheric heavy metals and "organic" chemicals
and the occurrence of brain damage in infants and children.
Do you agree that for this reason,
your Risk Assessment is fundamentally flawed,
and that therefore your RA
fails to protect the health
of the children,
and the pregnant women
and the other adults
of the community of Bowmanville in particular,
and of Durham Region .........and Eastern Ontario in general?
Answer: (consultant disagreed.)