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 ...in 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 ....no.... 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 ....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 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 ....in 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 here...in 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 ...to 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
....you 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 ...support 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
https://eloerg.tripod.com/waupoos
January 2007