An NGO Submission to Environment Canada's Consultation on Canada's National Implementation Plan under the Stockholm Convention on Persistent Organic Pollutants (POPs): Demonstrating Canada's Commitment to the Reduction and Elimination of POPs

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On February 17, 2004, the 50^th ratification to the Stockholm Convention on Persistent Organic Pollutants (POPs) was received by the United Nations from France. Hence, on May 17, 2004, the Stockholm Convention will enter into force, marking a momentous moment around the world. To Canada as well as many developing countries and countries in transition, such a moment provides hope that the impacts of POPs will be eliminated and the vulnerable communities of society such as the aboriginal communities, children, women and workers will be protected from exposure to POPs. Within two years, Parties to the Convention will be required to submit their National Implementation Plan (NIP) to outline how it will achieve the elimination of POPs.

Canada is well positioned to demonstrate its leadership at the international level once again through its NIP. Since the Fall 2003, Canada's NIP process has encouraged participation by stakeholders in many aspects of the NIP discussions, an approach that has proven to be effective throughout the negotiations of the Stockholm Convention. Environment Canada's current approach promotes transparency and access to information by all stakeholders. The multi-stakeholder approach undertaken to this point places Canada in a good position to develop and submit a comprehensive NIP that aims to achieve the obligations of the Convention and reflects the spirit of the Convention. Given that each Party must submit its NIP to the POPs Secretariat by 2006, the discussions in the upcoming months on Canada's NIP will provide some indication as to the key elements or components that will be considered for Canada's NIP. If Canada can submit a NIP that effectively demonstrates the details of its efforts on POPs, and also provide detail on how it will address possible gaps and obstacles in its efforts to achieving the obligations of the Stockholm Convention, Canada's leadership on POPs will be well established within the global community. Canada's approach can be seen as model for other Parties to follow.

The Canadian NGO community is excited to engage in these discussions as it has created a unique opportunity to reflect on Canada's domestic regime on toxic substances in general and more specifically on POPs. When Canada ratified the Stockholm Convention in May 2001, it was the first country to do so. By this ratification, it was suggested that the elements of programs and regulatory framework were in place in Canada to achieve the obligations of the Convention. Other stakeholders, such as the environmental community were pleased with the early ratification by Canada. The NIP process is an opportunity to review the effectiveness of the current programs on toxic substances including POPs in achieving its stated goals and identify the opportunities to strengthen these programs.

Canada committed significant resources to these negotiations, in part, because of the unique impact of POPs on Canada's arctic communities and environment. Canadians should expect a NIP that can be adopted as a model by other Parties of the Convention. Canada's NIP should:

• be comprehensive in its approach;
• demonstrate transparency in its development;
• ensure effective public participation in all aspects of its development;
• undertake an assessment on the effectiveness of the programs and initiatives aimed at eliminating and reducing POPs;
• ensure an effective regulatory framework to support the programs and initiatives to ensure that the obligations and the spirit of the Stockholm Convention are reflected;
• require the implementation and promotion of safe substitutes and non incineration technologies for POPs;
• outline timeline for its implementation; and
• ensure capacity and resources are available to implement all aspects of Canada's NIP.

This section provides commentary and specific recommendations on a broad number of issues related to the development of Canada's NIP as required under the Stockholm Convention on POPs. The recommendations outlined in this section support and further the general recommendations outlined in the previous section of this report. These recommendations aim to provide Environment Canada with advice with respect to the components to be included in an effective NIP. The Canadian environmental community will continue to comment and participate in the process to develop Canada's NIP to ensure that the NIP can effectively fulfill the obligations of the Stockholm Convention within a timely manner.

The chart divides issues into general categories: process, overarching themes and concepts, and specific components for Canada's NIP.

The unique threats of POPs to the Canadian arctic environment, the Aboriginal communities, and its population provides the reason for emphasizing the importance of the process undertaken by Environment Canada to develop its NIP under the Stockholm Convention. The 28 recommendations outlined in this submission aim to advise Environment Canada on the elements and components required to ensure that Canada develops a comprehensive NIP that effectively achieves the obligations of the Stockholm Convention and reflects the spirit of the Convention. Canada has an opportunity to continue its leadership in these global endeavours on POPsthrough its NIP. Canada's NIP must aim to address the elimination of the twelve POPs currently targeted under the Stockholm Convention as well as anticipate how future POPs can be effectively identified and addressed in Canada.

The next twelve months will be critical to Canada's efforts on developing its NIP. The introduction section of this submission highlighted a number of recommendations that will need careful consideration by Environment Canada in its effort to develop an effective NIP. Canada should:

• Be comprehensive in its approach;
• demonstrate transparency in its development;
• ensure effective public participation in all aspects of its development;
• undertake an assessment on the effectiveness of the programs and initiatives aimed at eliminating and reducing POPs;
• ensure an effective regulatory framework to support the programs and initiatives to ensure that the obligations and the spirit of the Stockholm Convention are reflected;
• require the implementation and promotion of safe substitutes and non incineration technologies for POPs;
• outline timeline for its implementation; and
• ensure capacity and resources are available to implement all aspects of Canada's NIP.

The environmental community in Canada looks forward to furthering its participation in this process.

April 6, 2004

Ms. Brenda Koekkoek Senior Policy Advisor
Hazardous Air Pollutants Environment Canada
351 St. Joseph Blvd. Gatineau, Quebec
KlA OH3

Dear Ms. Koekkoek:

On behalf of the Canadian Public Health Association (CPHA), I am pleased to attach comments on Canada's initiative with respect to the Stockholm convention as provided by CPHA's representative on this issue, Dr. Tim Lambert.

We are appreciative of the process established by Environment Canada which provided the opportunity to comment on the convention. Public processes are valuable to ensuring the implementation of healthy public policy.

The Canadian Public Health Association is a national, independent, not-for-profit, voluntary association representing public health in Canada with links to the international public health community. CPHA's members believe in universal and equitable access to the basic conditions which are necessary to achieve health for all Canadians.

Please do not hesitate to contact me if we can be of any other assistance.

Janet MacLachlanr
Associate Chief Executive Officer

cc: Dr. Christina Mills, President, CPHA
Dr. Elinor Wilson, Chief Executive Officer, CPHA
Mr. Ron de Burger, CPHA Board of Directors
Dr. Tim Lambert, CPHA member

Thank you very much for providing the CPHA an opportunity to comment on Canada's initiative with respect to the Stockholm convention. The initiative is extremely important for the health of Canadian's and in particular, people in Canada's north.

The CPHA has several recommendations for Canada in maintaining a global leadership role in the Stockholm convention.

Recommendation 1: The CPHA recommends that an ethical grounding is developed to guide Canada's Stockhom Initiatives.

The CPHA recommends that Canada specifically ground its initiative in public health ethics. There are two ethical principles which relate to actions and consultation. Following from the principle of prevention and the precautionary principle, Canada should clearly articulate that we have a "duty" to eliminate the production and release of persistent organic pollutants (POPs). This ethical obligation stems from the duty to prevent harm to people and the environment. Following from a principle of fostering autonomy, CPHA recommends grounding the commitment for consultation with all stakeholders in Canada and internationally, i.e., shared decision-making and fostering the ability for stakeholders to participate in the process of eliminating and releasing POPs. A paper that briefly outlines an approach to consider is Lambert et. al. Ethical perspectives for public and environmental health. Environmental Health Perspectives 2003 volume 111, 133-137. This paper grounds the precautionary principle in a duty-based ethics, and illustrates the role of the public and stakeholders in consultation. The paper also illustrates the need for the precautionary principle with respect to POPs.

Recommendation 2: The CPHA recommends that Canada establish itself as a leader in consultation in meeting all aspects of the convention.

Canada was the first county to ratify the Stockholm convention, and should maintain this leadership. The CPHA recommends that Canada establish itself as a leader in consultation, by establishing open and transparent consultation and decision-making processes within in Canada. Also, CPHA recommends Canada foster open and transparent consultation processes in other signatory countries. The CPHA believes this will help all countries to develop sound initiatives to deal with POPs and address the problem from a global perspective. The current Canada process of holding multi-stakeholder meetings is commendable. The CPHA encourages Environment Canada to maintain this process in the future. Face to face meetings should occur in Canada prior to submission of the implementation plan. This will show leadership and a concrete example for other countries to follow, in developing national implementation within their own countries.

Canada should sponsor health and environment NGO delegates to participate in international meetings to demonstrate a commitment to open and transparent process and inclusion of public stakeholders in the process. This will encourage other countries to develop open and transparent processes as well.

Recommendation 3: The CPHA recommends that Canada develop and identify initiatives that are specific to the Stockholm convention.

The CPHA recommends that Canada have a set of specific initiatives to ground the national implementation plan (NIP). For unintentional POPs, it appears that the NIP is based largely on co-benefits from other processes underway in Canada, for example, the CWS for dioxins. While these other processes may result in reductions of POPs, the approach raises some concerns. The CPHA is concerned that the Stockholm convention will not be a primary impetus for reductions for these POPs and thus decisions may be reached in these other processes, which reflect the different goals of stakeholders in these processes, without considering the impact on Canada's approach to the Stockholm Convention. Alternatively, will Canada's role as a leader in the Stockholm convention drive these other processes? Environment Canada staff working specifically on the Stockholm convention, and NGOsrepresenting the interests of the Stockholm convention should be included in the decision-making on co-benefit initiatives to ensure that the Stockholm convention implementation plan is not compromised in other processes. In making this point, the CPHA is hoping to ensure that Canada positions itself as a leader in the Stockholm convention and that we demonstrate specific actions that other countries can follow.

The CPHA recommends that Canada should collect all initiatives identified in the NIPunder two basic headings: specific new initiatives and co-benefit initiatives. With respect to co-benefits initiatives, it should be clearly articulated how these processes have now considered the Stockholm convention. The Stockholm convention should be the central home of all co-benefit initiatives, or at least a reporting house, to ensure that they meet the commitments of the Stockholm convention.

Secondly, the CPHA discourages Canada from considering reductions for a specific POP that all ready achieves the goals of the convention, as part of the NIP. The CPHA recommends that Canada strive to go beyond these achievements. The NIP can clearly identify that the POP meets the achievement from processes all ready undertaken, but it should then identify and develop specific initiatives to obtain further reductions. This approach will help position Canada as a leader in the Stockholm convention.

Recommendation 4: The CPHA recommends Canada to work with other countries on the phase out of DDT for vector control.

The Stockholm convention says that countries can continue to use DDT for vector control until safe alternatives are available. Canada can show leadership in this area by sponsoring or conducting research into safer means of vector control. There are examples all ready in existence. For example, see the article below:

By Richard Black

BBC science correspondent, Chandigarh

Fish are being used to control malaria in India with remarkable success, according to researchers from the Indian Council for Medical Research.

The mosquitoes which transmit malaria have virtually been eradicated from some areas.Scientists presented the results of several pilot projects at the Indian Science Congress in Chandigarh. Malaria control takes up a substantial slice of India's health budget, largely through buying insecticides. The theory is simple: find fish which like eating mosquito larvae and put them in ponds, rivers and wells where mosquitoes lay their eggs. The eggs hatch, and the fish eat the larvae.

Dr VP Sharma, a former director of India's Malaria Research Institute who now works with the Council for Medical Research, told the meeting that pilot projects in four states have met with remarkable success. Introducing fish like guppies, he said, was one of the main reasons why the number of malaria cases each year in India was falling.

"They were more than two million," he said. "Now, actually, they have gone down to 1.8 million. The World Bank has a programme in 100 districts using the fish and it will take another five years before the real impact would be known."

Dr Sharma told the meeting that fish had virtually eliminated malaria-carrying Anopheles mosquitoes from some districts, though he cautioned that the strategy did not work everywhere.

Using fish in this way used to be a standard approach to malaria control, but when insecticides like DDT were introduced during the last century with apparently magical success, it fell into disuse.

Now mosquitoes have become resistant to many of these chemicals and fish are back on the menu. The other attraction is cost. Supplying ponds with guppies is a cheap alternative to buying insecticides.

Recommendation 5: The CPHA recommends that under the Stockholm convention that Canada place all POPs on CEPA's schedule 1 and virtual elimination list and adopt strict regulations to restrict the import of products that use POPs in the manufacture process.

First, Canada should place all POPs on the CEPA Schedule 1 and virtual elimination list. Second, until such time as POPs are no longer used in any manner they still may pose a threat to human health and the environment. Development of strict regulations that prohibit the import of any products that employ POPs at any stage of the manufacture

process will lead to the eventual phase out of POPs. If Canada adopts such a regulation, this will provide the impetus for other countries to follow and develop technologies that do not use or create POPs.

Recommendation 6: The CPHA recommends that Environment Canada develop a specific team for early identification of new emerging POPs as part of the T1IP./p>

Canada, and in particular the northern Canada, has been contaminated by global atmospheric processes. These processes will continue into the future. Therefore Canada needs to establish early detection systems for potential new POPs. Canada is uniquely positioned therefore to detect emerging POPs in the actual environment, i.e., monitoring for new potential chemicals migrating to Canada. Canada should also establish collaborative research with other Stockholm countries to identify any potential POPs prior to their use in production and eventual release into the environment.

Recommendation 7: The CPHA recommends that Canada adopt stricter timelines than the Stockholm convention to position itself as the first country to phase out the generation and release of POPs.

Canada is in a unique situation because POPs contaminate Canada's environment and cause health impacts to Canadians. In order for Canada to deal with this problem, we need other countries to aggressively address the production and release of POPs. Therefore Canada should position itself as the first country to effectively eliminate POPs; phase out use of POP containing equipement, POPs used in manufacturing and POP releases. This will position Canada in a place to call for the elimination of POPs in other countries. Canada should set a target date of January 1, 2015 for completion of the task.

Recommendation 8: The CPHA recommends that Canada invest in alternative technologies that do not lead to releases of chemicals to the environment to destroy stockpiles of POPs.

In order for the global stockpiles of POPs to be destroyed, there needs to be development of technology. At this time, incineration is widely used to destroy toxic chemicals. Incineration leads to the release of other toxic chemicals perhaps many which are currently not identifiable. Furthermore, for example in Alberta, the Swan Hills incinerator has resulted in wide spread contamination of the environment with PCBs and dioxins. The CPHA recommends that Environment Canada encourage investment in non incineration technologies for the destruction of POPs. There are all ready some examples in Canada, such as hydrogen reduction technologies. If Canada can develop these technologies, then Canada will be positioned to destroy the tons and tons chemical stockpiles of POPs around the world.

February 20, 2004

Ms. Brenda Koekkoek,
Senior Policy Advisor
Hazardous Air Pollutants
Environment Canada
351 Boulevard St. Joseph
Gatineau, Québec
K1A OH3

Subject : Consultations on Canada's National Implementation Plan under the Stockholm Convention on Persistent Organic Pollutants (POP's): Discussion document.

Dear Brenda,

I have prepared this letter in response to the above mentioned discussion document and to our exchange on this matter earlier this week. As I explained, I will be unable to attend the current series of consultation sessions arranged by Environment Canada on this subject, and I am therefore taking this opportunity to provide you in writing with some comments and suggestions regarding Canada's implementation plan for the Stockholm Convention on POP's.

For convenience in referring to this letter, I have listed my observations and recommendations in point form.

1. The opportunity to comment on the proposed implementation strategy is welcome, and I would encourage Environment Canada to maintain a forum for regular and substantive consultation with stakeholders in the course of the implementation of Canada's strategy. I also encourage Environment Canada to ensure that aboriginal constituencies are adequately represented in this process, and that the Department consult aboriginal organizations and their constituencies to determine how best to accomplish this goal.
2. One of the key pieces of legislation in Canada relevant to the national implementation plan is CEPA (1999). It is, of course, important to make use of this legislation in a way that is clear and transparent. This is a shared legislative responsibility of Environment Canada and Health Canada, and is important, in my view, that Health Canada be seen as clearly engaged in this matter.
3. A tangible responsibility for Health Canada in this respect would be to ensure that there is an adequate mechanism for the identification of vulnerable populations and for tracking human exposure levels in an epidemiologically credible manner, i.e. so that trends within populations can be identified and distinguished with respect to age group and sex in relation to the population at large. Such mechanisms do not appear to be in place at this time.
4. Here as elsewhere in this implementation plan, there is a need to co-ordinate actions with those proposed or initiated in the framework of the North American Agreement on Environmental Co-operation. I refer here specifically to the North American Regional Action Plans (NARAP's) dealing with dioxins, furans and hexachlorobenzene, with PCBs, and with the over-arching theme of Monitoring and Assessment. This comment is directed at both health and environmental issues. In some cases, it might be possible to use the CEC initiatives as a mechanism for directing or overseeing the implementation process.
5. I believe that a particular problem for aboriginal communities, and probably more generally for relatively isolated rural communities in Canada, is the role of uncontrolled and at least partially open combustion as process, or collection of processes, responsible for the generation of certain classes of dioxins and furans, as well as certain co-planar PCBs and hexachlorobenzene (HCB). - and the corresponding problem of evaluating the toxicological significance for these populations of combustion-related generating of these compounds.
6. The complex and diffuse problem of combustion-related production is not adequately reflected, in my opinion, in the National Pollution Release Inventory (NPRI), and further work - including supporting research - is needed to address the shortcomings of the existing inventory. This is a problem which has been recognized in the United States, and I believe that is being tackled there; it should receive corresponding attention here in Canada.
7. Combustion-related production research, and the companion issue of the historical accumulation of dioxins and furans in soil organic matter and wetlands or peats, is the subject of a rapidly evolving research literature in the different countries affected by this issue. Environment Canada/Health Canada would do well to collaborate in ensuring (perhaps through a web site) that the individuals and agencies concerned by or with responsibilities for this issue have convenient access to relevant developments in the research literature (i.e. on such topics as congener distributions and their significance, analytical and quality control issues, combustion chemistry and factors which favour (or otherwise) the production of dioxins and furans; microbial degradation; and relevant toxicological developments). This comment could also be extended to the brominated and fluorinated compounds which are now the subject of increasing attention but which do not appear on the initial list of compounds in the Stockholm Convention.
8. Forest fires, stubble burning in agriculture, and probably wood stoves together constitute a group of uncertain but geographically widespread sources of dioxin and furan production and mobilization. There is very little data available to support estimates of their role in D/F production (and therefore their incorporation into national inventories). This is an example of an area requiring further, collaborative research. Environment Canada could play an important role in the promotion and support of such research.
9. Solid waste management in many remote communities on the Canadian Shield (and probably some other physiographic regions) often involves burning to reduce volume before burial in trenches. The practice is widespread (particularly in geographical settings where land suitable for waste burial is in short supply and where water tables are high), but poorly documented. There are probably well over a thousand small communities with populations ranging from a few hundred to a few thousand individuals which face this problem (both aboriginal and non-aboriginal). The avoidance of burning in itself can be the source of significant local environmental problems, and they also need to be taken into account.
10. There is an evident need for data collection and the creation of a central repository for information on this subject. In the case of aboriginal communities, one might expect Indian and Northern Affairs Canada (INAC) to be in a position to play a major role here, but this department does not appear at this time to collect and compile the data which is needed on this subject. The role of INAC should be explored further. The provinces and territories, and in particular the departments responsible for municipal affairs, have important roles to play in this area.
11. As unconfined combustion starts to dominate the inventoried and reported sources of dioxins, furans and coplanar PCBs, (a situation which is already apparent in the U.S.A.) so it will become increasingly important to tackle the issue of documenting production from solid waste management practices. I would add here that simple across-the-board prohibition of municipal waste burning creates its own environmental problems and is not necessarily a realistic or useful approach to control. In addition, forest fires and stubble burning remain as diffuse and often unpredictable sources.
12. The complex nature of this problem, as outlined above, leads me to add a caveat about reliance on the existing Canada Wide Standards (and equivalent actions in Québec). A number of the standards relevant to the Stockholm Convention were the subject of CWS developed some years ago, and on the basis of probably inadequate inventories. There are often severe sampling and analytical issues involved, even for clearly identifiable sources. The CWS process should kept open and adaptable to our evolving knowledge and understand of the subject matter. Over-reliance, for an extended period of time, on numerical standards based on incomplete and sometimes inaccurate information can become an implementation problem in its own right.

I hope that these suggestions will be of some use. I would be willing to provide additional clarification if that is considered appropriate.

Yours sincerely,

ALAN PENN
Science Advisor
Cree Regional Authority

cc: Grand Chief T. Moses
W. Iserhoff
V. Shantora (CEC)

March 12, 2004

Dear Brenda Koekkoek:

I attended the conference on "Consultations on National Implementation Plan Under the Stockholm Convention on Persistent Organic Pollutants (POPs)", yesterday, in Halifax, Nova Scotia.

The following are added comments that I wish to make in regards to this file.

Programs currently in place to evaluate and assess POPs and Toxic Waste is inadequate and is in need of revision(s). Multi Stakeholders should be included in the consultations process and based on yesterdays meeting this was not the case.

If we are really serious about creating a document/draft and implementing a concrete plan for success in the area of POPs, we need to have the flexibility to add on to your current list. Basically twelve of these POPs are no longer used in Canada but there are many other pesticides, which are currently being used and have been banned in other countries around the world. Pesticide users most apply these products as a preventative measure, not because the necessarily need to apply them. This mindset needs to be changed so that toxic products are used on a need basis. Those who require quota should have to apply to chosen agency to obtain the products.

One example is Endosulfan. The US Department of Health and Human Services claim that male school children exposed to the pesticide Endosulfan showed delayed sexual maturity compared with similar children who were not exposed. (Study published in the December issue of the peer-reviewed journal of Environmental Health Perspectives. Endosulfan also appears to interfere with sex hormone synthesis, according to the study's results. Males between the age of 10 to 19 years in a community of cashew plantations in northern Kerala, India. Although this product Endosulfan is no longer manufactured in the United States, it is estimated that 1.4-2.2 million pounds are used in the United States on squash, pecans and strawberries. Endosulfan damages the male reproductive organs and hromones.

Endosulfan is also used on Prince Edward Island and other parts of Canada. This product needs to be added to the list of POPsbecause of its ability to alter genes and its noted health risk. We must be responsible to the people or else we should all work in a different place. It is up to us to ensure that Endosulfan and other pesticides which have a negative impact upon our genetic code, once it is mutated, it is changed forever and passed onto to offspring's. "Our study results suggest that Endosulfan exposure many delay sexual maturity and interfere with hormone Synthesis in male children. Endosulfan is banned in Cambodia, Colombia, Germany, Sweden, Norway, Indonesia and other. The Canadian government is irresponsible if it too does not ban Endosulfan and other genetic altering pesticides like it.

In another study regarding Endosulfan, (National Institute of Occupational Health, led by Dr. Habibullah found when Endosulfan was sprayed by air for more than 20 years 117 boys in a village were effected. The results suggest also that Endosulfan exposure many delay sexual maturity and interfere with hormone synthesis in male children. Endosulfan is classed as an organochlorine, in the same family of pesticides as DDT and dieldrin, endosulfan and its' breakdown products are persistent in the environment with an estimated half-life of nine months to six years. It is one of the most commonly detected pesticides in US water, found in 38 states. Exposure to Endosulfan happens from eating contaminated food, may also occur from skin contact, breathing contaminated air or drinking contaminated water, according to the federal agency that evaluates the human health effects of exposure to hazardous substances. Endosulfan is reported to affect the Central Nervous System and prevent it from working properly, hyperactivity, nausea, dizziness, headache or convulsions have been observed in adults exposed to Endosulfan.

ENDOSULFAN AND SIMILAR PESTICIDES SHOULD BE ON THE BANNED LIST OF PRODUCTS WE DO NO WANT IN OUR AIR, WATER OR AFFECTING HUMAN HEALTH IN OUR COUNTRY.

Dr. William J. Rea and his colleges state, "Recent literature confirms the harmful effects of chemical incitants, like formaldehyde, phenol, some pesticides, chlorine, petroleum, alcohol, glycine, DDT, Toluene and Turpentine along with drugs such as hydralazine have been found to induce advanced staged disease process. also nickel, cobalt, chromium, aluminium, mercury, platinum and other common environmental chemical incitants, which include xylene, various acrylates, acrylated prepolymers, benzyl peroxide, carbon tetrachloride, sulfates, dithiocarbamates and diisocyanates are included in the list of chemicals that cause compromise human health and create disease.

I refer you to the Science Corner, Hazardous Waste Conference of 1993, "Hazardous Wastes and Public Health Approaches written by Devra Lee Davis, PhD., M.P.H., Office of the Assistant Secretary for Health, U.S. Department of Health and Human Services, Washing., D.C.; Linda Miller Poore, M.L.S., (Contractor) Office of Pollution Prevention and Toxic Library, U.S. Environmental Protection Agency, Washing, D.C. Their research, in part is as follows:

"the population of farm owners and operators in the United States now numbers about 2 million farmers, 3 million farm workers and 6 million farm family members. Because most farms use traditional, chemical-based, modern agricultural methods (as opposed to organic farming), this population is occupationally exposed to fuels, solvents, animal viruses, sunlight, and pesticides. In fact, farmers use a relatively small number of pesticides and changes in the particular chemicals used occur slowly over time. As we have shown elsewhere, with colleagues from the National Cancer Institute, (DL Davis et al. 1992b), farmers have some fascinating patters of cancer (Hoel et al. 1992). Results combined from 20 studies conducted on farmers in 8 different countries have revealed several common cancers associated with agricultural exposures, including multiple myeloma and childhood leukemia; lymphoma; and cancer of the connective tissue, stomach, prostate, lung, bladder, and brain. Overall mortality among farmers compared with the U.S. average indicates that farmers die less often from all causes. Indeed, their relative risk of dying from all heart disease and from all types of cancer is 60% to 90% that of the U.S. average. They claim that farmers die more frequently from certain types of cancer than do members of the general public. The tumours that farmers have in greater numbers have several interesting characteristics; they are not associated with tobacco (farmers smoke less and have less lung cancer), and several tumours are associated with immunodeficiency's or compromise in the immune system.

These research examples are only a few of the hundreds that I have in regards to the unhealthy characteristics of pesticide use for farmers and their neighbours.

This means that by allowing these types of pesticides (realizing PMRAis responsible for registrations and compliance of these products), the government is not taking care of its' people like they presupposed to. Every individual has the right to a health environment, IT IS THEIR RIGHT. Besides our health care system will not be able to cope in the very near (perhaps, less than five years) with the growing number of people who are being poisoned by toxic chemicals and toxic waste in our land fills so that we do not even have clean water to drink.

In terms of the conference, I feel that Environment Canada needs to include multistakeholders consultation meetings in regards to POPs. I support the Draft, "An NGO Submission to Consultation on Canada's National Implementation Plan under the Stockholm Convention on Persistent Organic Pollutants (POPs): Demonstrating Canada's Commitment to the Reduction and Elimination of POPs, which was prepared by Canadian Environmental Law Association.

I also believe the word minimization should be replace by the word elimination of all toxic POPs.

In regards to Dioxins, I refer you to (15. Case study on Dioxins/Furans in Japan ) by Shingo Kimura, Office of Environmental Risk Assessment, Environment Agency of Japan. "The main routes of absorption of dioxins are the digestive tract, skin and lung. Regardless of the route, the rate of absorption differs depending on the animal species, vehicle, isomer of dioxin, other substances present in diet, dosage and animal age. In general, the rate of absorption decreases as the dose is increased and the number of chlorine atoms in the dioxin is increased.

Ingested dioxins enter the bloodstream and are distributed to all tissues of the body. Depending on the isomer of dioxin, the dioxins tend to accumulate, mainly in the liver and adipose tissues. Human and laboratory animals have different characteristics as to which of these tissues stores more dioxin. In humans, more is stored in adipose tissue, while in laboratory animals, excluding guinea-pigs, more is stored in the liver. Sewage from factories and herbicides (examples, Seveso and Italy) re sources.

Symptoms and conditions observed in animals and people exposed to 2, 3, 7, 8-TCDD include weight loss (wasting syndrome), atrophy of the thymus, obstructed hepatic metabolism, cardiac muscle damage, changes in metabolism of sexual hormones, thyroid hormones, and cholesterol and other fatty substances, dermal symptoms such as chloracne, and symptoms related to the Central Nervous System Damage, such as reduced ability to study. Carcinogenicity is associated with Dioxins/Furans as well as cell carcinomas, lung tumours, thyroid gland, reproductive effects Immunotoxicity and a host of other related health problems.

If you are unable to locate these research document, please let me know and I will fax them to you.

Another point is landfill sites with toxic chemicals, which include cement which causes problems with water contamination and ozone problems. We should eliminate our dependency on these type of cites, encourage industry/manufacturing to create more environmentally friendly products/packages, which can be easily recycled.

There is a lot more work needs to be done on this file. More discussions with all stakeholders is necessary, more public awareness on the part of Environment Canada to encourage changes.

Industry should have a facility, which can filter/prevent their releases from going into external air. They need to be made more aware. I don't think the government and industry realize how angry citizens are in regards to the pollution problems, not being looked at seriously or industry continuing to pollution, our water becoming unfit to drink in many locales (especially Halifax and Dartmouth, which I drank two mouthfuls and experience sore through and enema from).

I would be quite willing to work for free, if it would mean a serious effort to clean our environment for our children and grandchildren. We cannot take five years to decide these things, while I realize Rome wasn't made in one day, we do need to become more progressive in regards to the environment. Citizens are fed up with their children being sick constantly. Besides our Health System cannot sustain with so many health problems caused by a filthy environment.

Thank you for the opportunity to submit more of my views and research.

Best regards,

Sandra Boswell
Writer, Research Analyst
P. O. Box 1482
Charlottetown, P.E.I.
C1A 7N1
Telephone: 902-368-2730
Fax: 902-894-9299
E-mail: que@pei.eastlink.ca

Cheryl Heathwood
Chief, Hazardous Air Pollutants
Environment Canada
Transboundary Air Issues
351 St. Joseph Blvd.
Gatineau, QC
K1A 0H3
cheryl.heathwood@ec.gc.ca

Subject: Support for NGO submission on Canada's NIP Process

Dear Cheryl Heathwood,

We would like to express our support for the comments contained in the document entitled An NGO Submission to Environment Canada's Consultation on Canada's National Implementation Plan under the Stockholm Convention on Persistent Organic Pollutants (POPs): Demonstrating Canada's Commitment to the Reduction and Elimination of POPs, prepared by the Canadian Environmental Law Association, and dated March 10, 2004.

Sincerely,

Julia Langer
Director, International Programs
WWF-Canada