13 December 1999
Brian Emmett, Commissioner of the Environment and Sustainable Development
Thank you, Mr. Chairman, and good afternoon ladies and gentlemen. This afternoon, I would like to make some brief introductory remarks, and then I would be pleased to answer your questions. With me here today is John Reed, a Principal in my Group and project director for our work on toxic substances.
The focus of my remarks today will be on pesticides. I will base my remarks on chapters 3 and 4 of my May 1999 Report.
Chapter 3, Understanding the Risks from Toxic Substances - Cracks in the Foundation of the Federal House, emphasized the importance of good scientific information when making decisions on the risks posed by pesticides and other toxic substances. We found weaknesses in interdepartmental co-ordination of research, fragmented departmental programs and conflicting agendas, incomplete monitoring networks, and a growing gap between demands placed on departments for information and their ability to meet those demands. Cumulatively, these cracks in the foundation threaten the government's ability to detect and understand the effects of toxic substances, including pesticides.
In Chapter 4 of my report, Managing the Risks of Toxic Substances - Obstacles to Progress, we reported on continued departmental in-fighting, a lack of action against established commitments and government-wide policies, voluntary initiatives in need of strengthened accountability, and weak performance monitoring and data tracking. We concluded that the government was not adequately managing the risks posed by existing toxic substances.
Since we tabled our Report, we have been following the hearings you have been conducting with great interest. Based on the transcripts I have read, I believe our findings are still relevant. I have seen nothing that causes us to change our views or that assures us that the major problems I identified are being addressed in a systematic way.
In addition to the broad issues identified in chapters 3 and 4, there are a few specific key issues that I would like to emphasize.
First, research and monitoring work under way in federal departments has the potential of providing a unique Canadian perspective on the presence and impact of pesticides. But generating good research and monitoring information is a moot point if it is used ineffectively. In this regard, my Report raised significant concerns about the lack of co-operation and sharing of information between the Pest Management Regulatory Agency(PMRA) and the departments that undertake scientific research such as Health Canada, Environment Canada and Fisheries and Oceans. This situation must change if the federal government is to use its full expertise to make decisions on pesticides, and to consider the precautionary principle.
Second, our concerns with the re-evaluation process and special reviews of pesticides are twofold. First, the government's track record with pesticide re-evaluations is alarmingly poor, both in relation to long-standing domestic commitments and in comparison to other countries where re-evaluation seems to have been taken much more seriously than in Canada. Many pesticides used today were approved when standards were much less stringent than they are today - in some cases, standards were approved over 40 years ago. Second, the ground rules for conducting re-evaluations and "special reviews" are unclear and need to be clear.
I realize that you have heard from many witnesses on this subject, therefore, I will not say much more except that I would like to stress that our work did not address initial pesticide registration.
The third key concern raised in our Report was the absence of an overall policy direction or strategic game plan within the PMRA for pesticide risk reduction. Risk reduction in this context refers to a host of different activities - such as reductions in use, adoption of alternatives, or less-toxic pesticides - aimed at reducing overall risks to people and the environment. Governments world-wide have specifically enacted such policies and programs. The Canadian government even directed the PMRA upon its formation to develop a risk reduction policy. It has not yet done so and needs to.
Another area on concern is the inadequate tracking of toxic releases and pesticides. You know from my Report that I place a high value on the measurement of such releases. My specific concern was the lack of a national database on pesticide sales and use, despite explicit direction and previous commitments to establish one. Unlike many OECD countries, Canada does not have one, undermining our ability to gauge reduction efforts.
The last area I would like to address is the use of voluntary instruments. As my Report noted, these are used extensively in the management of industrial chemicals but not as extensively for pesticides. That will likely change. Although I believe that properly designed and implemented voluntary programs can help achieve risk management objectives, members know that we made several recommendations aimed at strengthening the accountability, reporting and monitoring provisions of existing instruments. If voluntary initiatives are a subject of interest, the Committee may wish to refer to the relevant sections of our Report.
In conclusion, Mr. Chairman, the main message in my May Report is that there continues to be a substantial gap between talk and action on the federal government's environmental and sustainable development agenda. As a result, we are paying the price in terms of our health, environment, standard of living and legacy to our children and grandchildren.
I would like to leave you with three thoughts. First, although we fully recognize that toxic substances and pesticides are a complex issue for the many reasons cited in our chapters and by witnesses, I am not convinced that the problems we identified are rooted in the complexity of the issues. On the contrary, many of the problems have an all-too-familiar human "ring" about them, and in my view, are very solvable. For example:
Second, solving the issues and concerns identified in our chapters and raised by many witnesses, cannot be done in isolation from broader issues. The need for co-ordinated research, effective monitoring networks, consistent application of the precautionary principle and pollution prevention, robust voluntary agreements, and effective tracking of results are examples of the types of issues that I would hope would be included in your recommendations.
Third, as I have said several times before, the work of this Committee is vital to Canada's success in meeting its environmental and sustainable development goals. Chapters 3 and 4 of my May 1999 Report made a series of recommendations aimed at improving the assessment and management of toxic substances and pesticides. Most of these were directed to several departments simultaneously, reflecting our belief that improved working relationships among departments are needed. We were naturally pleased that six federal departments were able to agree on a single 'high-level' response and commit to take action on our recommendations. However, the price of such solidarity was specificity: There were no specific commitments made by departments. This is where I believe the Committee can play a key role. If the Committee agrees with our observations and recommendations, it can hold departments accountable for developing and implementing specific action plans and for reporting progress periodically.
In closing, I would like to thank the Committee for its ongoing interest and support. We will be pleased to answer your questions.