Notice of Objection filed by the Cement Association of Canada

September 14, 2000

Vic Shantora
Director General
Toxics Pollution Prevention Directorate
Environment Protection Service
Department of the Environment
Ottawa Ontario K1A 0H3

Subject: Canada Gazette, Part I June 10, 2000: Order Adding Toxic Substances to Schedule 1 to the Canadian Environmental Protection Act, 1999

Dear Mr. Shantora:

In response to the above order published in the Canada Gazette, Part 1, dated June 10, 2000, the Cement Association of Canada would like to give notice of its objection with regard to the classification on of respirable particulate matter equal to less than 10 microns (PM₁₀) as toxic under the Canadian Environmental Protection Act (CEPA), and its subsequent addition to Schedule 1. In previous submissions to Environment Canada, we have raised numerous issues regarding the Priority Substances List (PSL) Assessment Report used to justify this classification, and feel they have not been given sufficient consideration. Some of these are outlined below.

First of all, the PSL Assessment Report appears to consider only those studies which support the classification of PM₁₀ as toxic, while overlooking numerous other studies which refute this conclusion, and consequently, cannot be considered a thorough, balanced assessment. However, even the evidence supplied in this report does not appear to adequately support the conclusion that PM₁₀ is toxic; the reported association between PM and morbidity and mortality is weak at best, and the relative risks presented are not typically considered to be meaningful.

Additionally, there is a considerable amount of uncertainty regarding various aspects of the studies cited in this report, including the statistical methodology used and the possible contribution of other pollutants to health effects which have been ascribed to PM. Also, considering the fact that PM is not a single substance, but a composite of variable composition, it seems premature to list all types of particulate matter as toxic based merely on size, regardless of composition.

While the Canada Gazette notice acknowledges that there are deficiencies in data, it suggests that these be dealt with during the risk management phase of the process. However, it is our opinion that there has not been sufficient scientific evidence presented to warrant the addition of PM₁₀ to Schedule 1. If you require further information, please do not hesitate to contact me.

Alicje Cornelissen, M.Sc
Director, Environment
Cement Association of Canada
60 Queen Street, Ste. 1500
Ottawa, Ontario KlP 5Y7