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 ...in 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 ....no.... 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 dioxins....as 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 ....by 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 ....in 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 done...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 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 experts......in 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