Interventions in Committee
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View Ben Lobb Profile
View Ben Lobb Profile
2015-06-18 15:47
Good afternoon, ladies and gentlemen. I think this is the last committee meeting for all committees in the 41st Parliament, so the health committee is working right till the end.
We have two panels this afternoon. For our first panel, we have three different groups. As per usual, we'll connect first with Kathleen Cooper by video conference.
Welcome, Kathleen. You're welcome to go ahead with your presentation.
Kathleen Cooper
View Kathleen Cooper Profile
Kathleen Cooper
2015-06-18 15:48
I thought I was going third, but that's fine.
View Ben Lobb Profile
View Ben Lobb Profile
2015-06-18 15:48
You're first today.
Kathleen Cooper
View Kathleen Cooper Profile
Kathleen Cooper
2015-06-18 15:48
First of all, to tell you about the Canadian Environmental Law Association, we're a non-profit public interest organization specializing in environmental law. We're also a legal aid clinic within Ontario. We provide legal representation to low-income individuals and vulnerable communities.
Then we have law reform priorities, and in setting our strategic priorities, one of those is environment and human health. In deciding within that large topic how to set priorities, we take a population health approach, the same as Health Canada, the Public Health Agency of Canada, and public health agencies everywhere do. You set priorities by focusing on issues where large numbers of people are potentially or directly affected or where you have serious outcomes.
You can't get much more serious than a known carcinogen where there's strong science. Radon, as I'm sure you're going to hear later as well, is in a class by itself compared to most other environmental carcinogens. That's why we've focused on radon.
I'm going to speak today to a report we prepared last year, “Radon in Indoor Air: A Review of Policy and Law in Canada”. I believe you've been circulated the media release that was issued the day we released the report. That's all I was able to have translated given the time pressure of meeting with you today.
We canvassed policy and law across Canada at the federal and provincial levels and looked at jurisdictions and roles. We focused on public buildings and building codes, looked at other relevant provincial policy and law and the associated common law, and made a number of recommendations, but I'll focus today on just the recommendations we made with respect to the federal government.
Overall, our findings were that Canadians need better legal protection from radon. We found a patchwork of inconsistent and mostly unenforceable guidance.
For the federal government, we found that really important leadership has occurred, and Kelley Bush from Health Canada will provide some details on that for you today, although we definitely made recommendations for more that can be done. At the provincial and territorial level, where actually most jurisdiction lies, we found a wide range of laws that need to be updated or that contain gaps or ambiguities. There's very limited case law, which points to the need for improving a law or for law reform. I won't get into detail on what's been done at the federal level on radon, although the report does, because Kelley will be doing that for you later on.
Just in summary, under the national radon program there has been very valuable research, testing, and mapping of high -radon areas. The guideline for indoor radon was updated in 2007. The national building code was updated with respect to radon provisions, there's a certification program for radon mitigators, and there has been a national campaign to urge the testing by Canadians of their homes. It's recommended that every home in Canada be tested.
We recommended, to build on that important work, that there really is a logical next step here. Through the work of the Green Budget Coalition this past year, we recommended a tax credit for radon remediation. We recommended that the Income Tax Act add a tax credit for radon mitigation of up to $3,000 for individual Canadians, so long as it's done by a certified expert under the national program. That was not included in the budget, although we think it's still a very good idea. We had some very positive response from the federal officials we spoke to about it.
We also recommended that there be clearer messaging about radon, and that we use words like “radiation” and “radioactivity” because they are accurate and are what people understand more in terms of the risks of radiation and radon. We also recommended that there be better data sharing nationally between the federal government and the provinces and territories in terms of the testing that's done, along with the sharing of information that's paid for nationally, and that information be available publicly.
In terms of recommendations for federal action as well, we note that the David Suzuki Foundation report that came out just last month says the World Health Organization has recommended a lower level of 100 for indoor radon. Currently, our federal level is 200 becquerels per cubic metre. We definitely supported that recommendation and recommend that the federal government reduce the indoor radon guideline to 100.
The other two areas I want to touch on that are relevant to your investigation here have to do with the Canada Labour Code and the need to update it as well, and also the need for improving the uptake across Canada of the naturally occurring radioactive materials guidelines, the NORM guidelines. I'm going to speak to those two areas now.
Under the Canada Labour Code, there is the only legally enforceable limit for radon in Canada that's broadly applicable, but it's only for federally regulated workplaces and it remains at an outdated level of 800 becquerels per cubic metre. We think it should be brought down to the federal reference level of 200 becquerels per cubic metre to begin with, and we think that level should come down to 100 becquerels per cubic metre. On the updating of that level, apparently what was going to happen in 2015 now sounds like it's going to happen in 2016, so it would be great if your committee recommended speeding up that process.
In terms of the NORM guidelines, these are guidelines that were prepared by a federal-provincial-territorial committee. We interviewed occupational health and safety inspectors across Canada and found a lot of confusion and uncertainty about workplace radon rules or whether the NORM guidelines apply. In fact, they apply to every workplace in Canada. In any indoor space that is a workplace, including the room in which you are sitting, those guidelines apply.
However, it's a reactive, complaint-driven system. Inspectors get few or no complaints because there is a lack of awareness, so they don't take enforcement action. Also, some inspectors didn't think that radon was an occupational health and safety issue at all. They said that enforcement action was unlikely because the only agreed-upon levels for radiation are those for radiation-exposed workers. That is just not accurate, so we've made recommendations in response to that situation.
Turning to the recommendations we made with respect to the Canada Labour Code, as I've mentioned, it should be brought up to date swiftly. It's out of date by many years and still at that level of 800 becquerels per cubic metre.
With respect to radon, we recommended that the federal-provincial-territorial radiation protection committee, which deals with far more than radon—it deals with a whole manner of radiation exposure issues—convene a task force for occupational health and safety inspectors across the country so that there is clarity and there is a more generalized consistent application of those NORM guidelines to ensure worker health and safety. The consequences of that inconsistent application are that you're going to have uneven worker protection across the country and the possibility that people are overexposed, both in the workplace and in their homes, if they happen to be unlucky enough to have high radon levels in both of those indoor locations where they live and work. Related to that, we made a range of recommendations about provincial labour codes, which I won't get into.
In another area of occupational exposure, with respect to radon mitigators, we also recommended that CAREX Canada, who you're going to hear from later today, undertake, with the Canadian national radon proficiency program, research and dosimetry monitoring for radon mitigators so that we can make sure their workplaces are safe as well.
Just to recap on the findings in this report and to recommend to you to take up some of these recommendations in your deliberations on this topic, we found a need for greater legal requirements rather than guidance in this area for several reasons, including the need to underscore the seriousness of the problem and to support public outreach messages by the federal government and by other organizations who you're going to hear from today, including the Canadian Partnership for Children's Health and Environment.
Also, there's a need for legal requirements to require testing in public buildings and to ensure public access to that information. As well, there's the need to correct that inconsistent response among both the public health and the occupational health and safety inspectors and to provide them with tools to take action with respect to radon. As I mentioned, we found limited to no case law under either statutes or common law. We also found that improving the law or law reform is a better remedy than costly and situation-specific litigation to resolve radon problems.
Then, as I mentioned, there's a need for specific federal government action, including updating that federal guideline and putting in place a tax credit to help Canadians undertake radon mitigation when they have high levels, updating that Canada Labour Code, and ensuring the NORM guidelines are applied.
We've calculated the health care savings from prevented lung cancer deaths. If all homes in Canada were mitigated to the level of 200 becquerels per cubic metre, you'd see more than $17 million a year in savings through prevented lung cancer deaths. It likely would be double that if you were to reduce the level to 100 becquerels per cubic metre. Then, of course, anyone who works in cancer will tell you that the indirect costs are five times higher than the direct costs, so a lot of savings are possible there, along with the avoidance of the pain and suffering associated with lung cancer.
Kathleen Cooper
View Kathleen Cooper Profile
Kathleen Cooper
2015-06-18 16:00
I will stop there. Thank you very much for your time.
View Ben Lobb Profile
View Ben Lobb Profile
2015-06-18 16:00
You're right on time. Thank you.
Next up will be Erica Phipps from the Canadian Partnership for Children's Health and Environment.
Erica Phipps
View Erica Phipps Profile
Erica Phipps
2015-06-18 16:01
Thank you, Mr. Chairman.
Good afternoon. Thank you for the opportunity to contribute to this important discussion.
I'd like to share a few perspectives based on our work to raise public awareness, particularly among families with young children, about the lung cancer risk posed by radon and what can be done to reduce that risk.
My name is Erica Phipps. I serve as executive director of the Canadian Partnership for Children's Health and Environment, CPCHE, a collaboration among public health, medical, legal, and child-focused organizations that have been working together for nearly 15 years to advance children's environmental health protection in Canada. The 10 core CPCHE partners include the Canadian Environmental Law Association—you've just heard from my colleague, Kathleen Cooper—and the Canadian Child Care Federation, which has been actively involved in our work to promote radon action in the child care sector.
Much of our work within CPCHE involves engaging with and learning from service providers, such as public health nurses and child care providers and others, who work with families on a day-to-day basis and empowering them to integrate children's environmental health protection into the support they provide to families.
I thought it would be fitting to start with one of their voices. These are the words of a child care provider in Winnipeg, who was one of the participants in the radon vanguard initiative that CPCHE and the Child Care Federation undertook last year, with support from Health Canada. She said:
I wouldn't want to work in a centre that had [high radon] and didn't do anything about it. I wouldn't want to do that. I wouldn't work there. And I wouldn't put my children in the centre either.
This child care professional had known very little about radon before getting involved, but she, like others in the project, was motivated to learn more because of her dedication to the children in her care and because she desired a healthy workplace. It did not take her or any of the other staff involved in the project very long to get that this is a critical issue and one that demands action.
Through the vanguard project, she and other child care providers shared information on radon with their client families and voluntarily tested their child care centres for radon. Through that process, the project participants made the transition from a group of people who had hardly even heard of radon to being nearly unanimous in rating it as a high priority for health in their centres.
When asked what they thought would need to happen to protect children and staff from this lung cancer risk, most felt that radon testing would somehow need to be made mandatory. In the words of another participant:
...what I see in child care tends to be...people don't take action unless they're forced to, unfortunately.... It's like carbon monoxide detectors, right. We never had them before and then finally we were forced to have them and so everybody got them. And you know meanwhile they're only like $40 dollars or $50, and yet people didn't do that before it was made sort of expected of [them].... I think unless [radon testing] was made mandatory or there was some kind of assistance in ensuring that it was done, I think it would be unlikely to get done...when it should be.
This viewpoint was echoed by others and supported by the results of the vanguard project. Despite good intentions and the fact that radon test devices were supplied directly to the participating day care centres, only two-thirds of them were able to complete the testing. What this suggests is that for a sector in which staff are already stretched, providing them with information—and even providing them with do-it-yourself test devices—is not likely to be enough.
CPCHE has been putting significant effort into radon outreach over the past few years, including developing a plain-language tip card for families and teaming up with Health Canada, the Canadian Lung Association, Parachute, and the Canadian Association of Fire Chiefs in a campaign that links radon testing to the more familiar home safety messages of smoke detector use and carbon monoxide detector use. I've brought copies, which you should have before you.
We have prioritized radon as a focus of our collective work because of the well-established high level of risk posed by radon and because we firmly believe that protecting children is an investment in lifelong health. The harm from radon exposure is cumulative, which means that if we can ratchet down exposures during childhood by promoting radon safety in homes and by zeroing in on those six to eight hours that many children spend per day in child care or other learning environments, we can give Canada's kids a better start towards lifelong health, such that their generation and future generations are less likely to suffer from the devastation of lung cancer.
There's also an equity question here. Radon exposure is a prime example of a housing-related health risk that is beyond the ability of low-income people, especially tenants, to address on their own. Knowing about radon is not enough if you can't afford to buy a test kit, let alone pay for a remediation. It is just this sort of issue that we are seeking to address in a new CPCHE-led initiative called “RentSafe”, which will build social service sector capacity to respond to health concerns in low-income housing.
Reducing the financial barrier to radon mitigation should be a matter of priority if we are to achieve the goal of healthier housing for all Canadians. That would potentially include the Green Budget Coalition ask that Kathy mentioned in her remarks, of having an income tax credit for radon mitigation. Federal leadership to help families get action on avoidable health risks in their housing, including radon, would be a well-targeted investment in the health and well-being of the people of Canada.
In our toxics work within the CPCHE partnership, we frequently bump up against the complexities of scientific evidence, fraught with great debates about cause and effect and proof of harm. Radon, regrettably, is refreshingly simple. Radon causes lung cancer, full stop. We know how to test for it. We know what to do if levels are high. We know that it amplifies the risk posed by the other big lung cancer culprit, tobacco smoke. Now we need the courage and investment to ensure that the homes and buildings where we spend time, and especially where our children spend time, are not a source of this preventable lung cancer risk.
Thank you.
View Ben Lobb Profile
View Ben Lobb Profile
2015-06-18 16:07
Thank you very much.
Next up we have Kelley Bush, senior head of radon education and awareness at the Department of Health.
Go ahead, please.
Kelley Bush
View Kelley Bush Profile
Kelley Bush
2015-06-18 16:07
Good afternoon. My name is Kelley Bush, and I am the head of radon education and awareness under Health Canada's national radon program.
Thank you, Mr. Chair and members of the committee, for inviting me to be here today to discuss radon as a cause of lung cancer and to highlight the work of the Canadian – National Radon Proficiency Program.
Through the ongoing activities of this program, Health Canada is committed to informing Canadians about the health risk of radon, better understanding the methods and technologies available for reducing radon exposure, and giving Canadians the tools to take action to reduce their exposure.
Radon is a colourless, odourless radioactive gas that is formed naturally in the environment. It comes from the breakdown of uranium in soil and rock. When radon is released from the ground in outdoor air, it gets diluted and is not a concern. However, when radon enters an indoor space, such as a home, it can accumulate to high levels and become a serious health risk. Radon naturally breaks down into other radioactive substances called progeny. Radon gas and radon progeny in the air can be breathed into the lungs, where they break down further and emit alpha particles. These alpha particles release small bursts of energy, which are absorbed by the nearby lung tissue and lead to lung cell death or damage. When lung cells are damaged, they have the potential to result in cancer when they reproduce.
The lung cancer risk associated with radon is well recognized internationally. As noted by the World Health Organization, a recent study on indoor radon and lung cancer in North America, Europe, and Asia provided strong evidence that radon causes a substantial number of lung cancers in the general population. It's recognized around the world that radon is the second leading cause of lung cancer after smoking, and that smokers also exposed to high levels of radon have a significantly increased risk of developing lung cancer.
Based on the latest data from Health Canada, 16% of lung cancers are radon-induced, resulting in more than 3,200 deaths in Canada each year. To manage these risks, in 2007 the federal government in collaboration with provinces and territories lowered the federal guideline from 800 to 200 becquerels per cubic metre. Our guideline of 200 becquerels per cubic metre is amongst the lowest radon action levels internationally, and aligns with the World Health Organization's recommended range of 100 to 300 becquerels per cubic metre.
All homes and buildings have some level of radon. It's not a question of “if” you have radon in your house; you do. The only question is how much, and the only way to know is to test. Health Canada recommends that all homeowners test their home and that if the levels are high, above our Canadian guideline, you take action to reduce.
The national radon program was launched in 2007 to support the implementation of the new federal guideline. Funding for this program is provided under the Government of Canada's clean air regulatory agenda. Our national radon program budget is $30.5 million over five years.
Since its creation, the program has had direct and measurable impacts on increasing public awareness, increasing radon testing in homes and public buildings, and reducing radon exposure. This has been accomplished through research to characterize the radon problem in Canada, as well as through measures to protect Canadians by increasing their awareness and giving them tools to take action on radon.
The national radon program includes important research to characterize radon risk in Canada. Two large-scale, cross-Canada residential surveys have been completed, using long-term radon test kits in over 17,000 homes. The surveys have provided us with a much better understanding of radon levels across the country. This data is used by Health Canada and our stakeholder partners to further define radon risk, to effectively target radon outreach, to raise awareness, and to promote action. For example, Public Health Ontario used this data in its radon burden of illness study. The Province of British Columbia used the data to inform its 2014 changes to their provincial building codes, which made radon reduction codes more stringent in radon-prone areas based on the results of our cross-Canada surveys. The CBC used the data to develop a special health investigative report and interactive radon map.
The national radon program also conducts research on radon mitigation, including evaluating the effectiveness of mitigation methods, conducting mitigation action follow-up studies, and analyzing the effects of energy retrofits on radon levels in buildings. For example, in partnership with the National Research Council, the national radon program conducted research on the efficacy of common radon mitigation systems in our beautiful Canadian climatic conditions. It is also working with the Toronto Atmospheric Fund to incorporate radon testing in a study they're doing that looks at community housing retrofits and the impacts on indoor air quality.
This work supports the development of national codes and standards on radon mitigation. The national radon program led changes to the 2010 national building codes. We are currently working on the development of two national mitigation standards, one for existing homes and one for new construction.
The program has developed an extensive outreach program to inform Canadians about the risk from radon and encourage action to reduce exposure. This outreach is conducted through multiple platforms targeting the general public, key stakeholder groups, as well as populations most at risk such as smokers and communities known to have high radon.
Many of the successes we've achieved so far under this program have been accomplished as a result of collaboration and partnership with a broad range of stakeholder partners. Our partners include provincial and municipal governments, non-governmental organizations, health professional organizations, the building industry, the real estate industry, and many more. By working with these stakeholders, the program is able to strengthen the credibility of the messages we're sending out and extend the reach and impact of our outreach efforts. We are very grateful for their ongoing engagement and support.
In November 2013 the New Brunswick Lung Association, the Ontario Lung Association, Summerhill Impact, and Health Canada launched the very first national radon action month. This annual national campaign is promoted through outreach events, website content, social media, public service announcements, and media exposure. It raises awareness about radon and encourages Canadians to take action. In 2014 the campaign grew in the number of stakeholders and organizations that participate in raising awareness. It also included the release of a public service announcement with television personality Mike Holmes, who encouraged all Canadians to test their home for radon.
To give Canadians access to the tools to take action, extensive guidance documents have been developed on radon measurement and mitigation. Heath Canada also supported the development of a Canadian national radon proficiency program, which is a certification program designed to establish guidelines for training professionals in radon services. This program ensures that quality measurement and mitigation services are available to Canadians.
The Ontario College of Family Physicians as well as McMaster University, with the support of Health Canada, have developed an accredited continuing medical education course on radon. This course is designed to help health professionals—a key stakeholder group—answer patients' questions about the health risks of radon and the need to test their homes and reduce their families' exposure.
The national radon program also includes outreach targeted to at-risk populations. For example, Erica already mentioned the three-point home safety checklist that we've supported in partnership with CPCHE. As well, to reach smokers, we have a fact sheet entitled “Radon—Another Reason to Quit”. This is sent out to doctors' offices across Canada to be distributed to patients. Since the distribution of those fact sheets began, the requests from doctors offices have increased quite significantly. It began with about 5,000 fact sheets ordered a month, and we're up to about 30,000 fact sheets ordered a month and delivered across Canada.
In recognition of the significant health risk posed by radon, Health Canada's national radon program continues to undertake a range of activities to increase public awareness of the risk from radon and to provide Canadians with the tools they need to take action. We are pleased to conduct this work in collaboration with many partners across the country.
Thank you for your attention. I look forward to any questions the committee members might have.
View Ben Lobb Profile
View Ben Lobb Profile
2015-06-18 16:16
Very good.
In order to fit everything in for both panels I think we'll have to reduce the length of time for the questions to five minutes instead of seven. That will get everybody through and done in time.
Ms. Moore.
View Christine Moore Profile
Thank you, Mr. Chair.
I will ask only one question, and then I will yield the floor to Mr. Rankin.
As we know, many homes have never been tested for radon, although a number of them are at risk. Could it be appropriate for CMHC, when processing a file for a home purchase, to require that the new buyer test for radon? That way someone buying a new home would know whether it contains radon or not and whether they have to make improvements to remedy the problem.
Kelley Bush
View Kelley Bush Profile
Kelley Bush
2015-06-18 16:17
We are already working with CMHC on the radon issue.
Here is what is being done to remedy the problem. Canada Post has a program called smartmoves, or déménageur in French. Every time someone submits a change of address request, they receive an information kit on everything they need to think about when they move into a new home. Information on radon is part of that kit. That's a way to inform homeowners when they should test radon levels before they move into a new home.
You asked a question about moving, but I forgot what the second part of your question was about.
Kelley Bush
View Kelley Bush Profile
Kelley Bush
2015-06-18 16:18
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