Canadian Institute for Business and the Environment
Fisherville, Ontario, Canada
Tel. 416 410-0432, Fax: 416 362-5231
Vol. 15, No. 4, July 29, 2010
Honoured Reader Edition
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Our theme this issue is water quality but we will not be discussing the Gulf oil spill which is being extensively covered by the daily press. We will come back to the Gulf spill issue when the lessons learned become a little more clear. In this issue we are discussing some recent initiatives, including a US court case which has determined that pesticides are to be considered water pollutants, a move by the US Centers for Disease Control to expand reporting on drinking water pollutants to cover disinfection by-products, a move by Environment Canada to (very slowly) tighten the rules for sewage treatment plants, and we report on various aspects of the Canada-wide Strategy for the Management of Municipal Wastewater Effluent. Companies are also major contributors to reduced water quality, but a few are beginning to report on their performance. We report to you. Check your yogurt and make sure your home is doing what it can for reduced water pollution! Victoria BC has some tips that GL passes on.

If you voted for Premier Darrell Dexter in Nova Scotia you have voted for delayed enforcement of mercury pollution regulations. Yes, you! Your support of this pro-mercury pollution premier is pretty disgraceful. We explain why. East coast kids, and wild species such as river otters, are getting sick because of you.

At the other end of the table, where the good guys (or somewhat better guys) sit, the WBCSD and the IUCN have developed a guide to global and regional initiatives on water and business. We pass on a synopsis of their suggestions and applaud both organizations for moving in the right environmental direction. Even when humans do the right thing, however, nature can conspire to make it worse again. We summarize a recent article on how zebra mussels are returning PCBs to the flesh of the pickerel (walleye) of the Great Lakes.

Do you know Prof. John Giesy? If not, maybe you should at least learn more about his research. We introduce you to him, one of Canada's environmental good guys. Years ago, GL's editor went to an Environment Canada biodiversity conference and tried to promote the concept that biodiversity and business should be examined as compatible objectives if we truly want to preserve biodiversity. Back then, none of the government biologists was interested. Today there are not so many government biologists, which may explain why the concept of business and biodiversity is gaining ground. We explain, based on a research project funded in part by the G8 Another good guy, climate scientist Stephen Schneider, passed away recently. GL's obit is included in this issue. He will be missed - we explain why.

The Rubber Duck guys have got a lot of publicity for their toxic thesis but GL is not quite so enthusiastic. GL explains, in a book review in this issue, why Slow Death by Rubber Duck might be a catchy title but pretty weak science. Of course, nothing as weak as our concluding story, in which we point out that the Canadian Broadcasting Corporation has some very strange opinions about the naming of animal species. In this issue, Edmonton seems to have won G:'s 'good environment' prize and Premier Dexter gets the black hat award (other provinces failing to meet their mercury reductions targets may qualify for this award later this year). This is the  first of our issue by issue awards for who is good, and not so good, for the environment.

Talking of not so good, not a prize winner our editorial looks at an ecomess caused by very bad implementation of an ecofee program to pay for household hazardous waste recovery in Ontario. There is so much to tell that it would fill our entire issue, which we prefer not to do especially with local or provincial/state issues, so we have picked on a couple of aspects from the wreckage of this product stewardship program and may discuss more in a future issue.
Next issue we plan to review some of the environmental issues that are likely to be on the public policy agenda in the next six months. Meanwhile, enjoy this issue and don't hesitate to email us with your comments. Letters to the Editor, which we may publish, should be sent to 


On July 1st the province of Ontario introduced a new levy designed to meet the costs of recovery and environmentally sound management of a list of more than 7000 products generally classified as Household Hazardous Waste. Despite the serious political fallout which arose from this expanded program, the firestorm of voter outrage affects only a very small part of Ontario's overall packaging and product stewardship program - the introduction of a group of additional products to the household hazardous waste category.

The political problem arose when some retailers decided to pass the levy on to customers in the form of an 'ecofee' levied at the cash register. Within a couple of weeks there was a massive public outcry and the Minister of the Environment was forced to announce that he was prohibiting the ecofee on these products and was giving Stewardship Ontario, the industry-led group nominally responsible for the program, and his bureaucrats 90 days to come up with a new plan for funding the recovery and management of these products at the end of their life.

Far more mistakes were made in the introduction of this program than can be covered in one Gallon Letter editorial. GL has commented previously that Ontario's Waste Reduction Act really has much more to do with raising money to pay for municipal recycling programs than it has to do with protection of the environment. The legislation tends to encourage Stewardship Ontario to put higher fees on environmentally preferred packaging and products than are placed on conventional products and packaging. In this particular programme, SO made no differentiation between green and non-green products. If federal regulations required that a product be labelled as an irritant, SO and the Ministry of the Environment required that a stewardship levy be paid on the product even if its environmental impact was minimal. This is the first time that anyone has ever used an irritant label as an indication that a product qualifies as household hazardous waste.

We will be returning to discussion of stewardship programs in future issues but there are two aspects of the present Ontario fiasco that seem worthy of immediate comment. Readers looking for more information on what went wrong are referred to the thorough report issued this week by the Environmental Commissioner of Ontario and referenced below.

Many major retailers have been pushing for stewardship fees to be shown separately on cash register receipts. Their public argument is that only if consumers see the environmental end-of-life management fees attached to a product will they pressure the manufacturer to switch to less toxic and easier to recycle materials. Their private argument is akin to that of the airlines who advertise ticket prices exclusive of a big wad of taxes and fees that often serve to double the ticket price. In other words, they want to be able to advertise with prices which are below the actual price paid for the product.

It was these retailers who were the major cause of the ecofee debacle in Ontario this month. They did not warn customers of the ecofee when the customer picked up the product and put it in the buggy. When the customer got to the checkout the customer suddenly found that they were being charged an ecofee that in some cases amounted to several dollars, in a few cases legitimately but in many cases because the retailer was 'accidentally' grossly overcharging on the actual amount of the levy that Stewardship Ontario had applied to the product. Because of these massive retailer screw-ups, the Ontario government has now announced that it is prohibiting ecofees on these products, though they are still being charged without much fuss on such products as tires and electronics where they have been in place for many months.

The environmental policy community seems badly split on the issue of visible ecofees. Some agree with the official retailer position that consumers will only shift their purchasing preferences to more environmentally responsible products if the ecofee is visible on the cash register tape as well as on the price sticker attached to the product or shelf. Others see recycling and waste management levies as being a charge on manufacturers to encourage them to produce more environmentally responsible products. Given that the fee is generally only a very small percentage of the total product retail price, GL believes that the former approach has greater validity. We would like to see a system where consumers are made aware of the costs of environmentally sound management of end-of-life products and packaging before they make the choice to buy the product. Of course, this requires development of a system where more environmentally harmful products have higher environmental fees than greener products, something that the now failed Ontario program did not do, but that is another story for another day.

The second point for this discussion relates to the list of products that should attract stewardship fees. In this regard we believe that Ontario consumers outsmarted both the politicians, very few of whom had any real understanding of the program they were discussing, and the industry folks who run Stewardship Ontario. Indeed, we are still analyzing whether the failure of the ecofee program was policy and operational incompetence on the part of Stewardship Ontario or whether it was a deliberate conspiracy to embarrass the Ontario Government, given that some directors of Stewardship Ontario have strong links to Ontario's opposition party! Please bear in mind that Gallon Environment Letter is not normally a subscriber to conspiracy theories about the environment.

GL is of the opinion that if the visible ecofee had been limited to packages and products that obviously need environmentally sound management at the end of their life then the ruckus would probably not have broken out. $0.51 for a non-refillable propane tank, $6.66 for a 5 lb fire extinguisher, or $0.14 for a CFL lightbulb are the kind of fee that consumers will likely accept, given that it is obvious that they need proper management and that they are somewhat difficult to handle. The ecofee on the CFL lightbulb is a bit odd, given that governments are trying to encourage people to switch to CFLs or LEDs and that Stewardship Ontario did not put a fee on conventional lightbulbs, which are a product that should be diverted from landfill just as much as the CFL (the brass on the base of a conventional lightbulb often contains lead while the CFL contains mercury). The consumer protest arose, in GL's opinion, because Stewardship Ontario, at the urging of the Ontario Ministry of the Environment, also put a household hazardous waste levy on laundry detergent, household cleaners, and even dishwash detergent and hand soap (for which the levy was $0.0005, or one twentieth of a cent per package - how do you charge that to the customer?). Wait a minute! When did you last put laundry detergent in the garbage or take it to a household hazardous waste recycling depot? Doesn't most of the soap and household cleaner we all use go down the drain?

Stewardship Ontario's ecofee had all the appearance of a money grab, specifically a tax grab, because it made so little sense from a typical consumer's environmental perspective. If it looks like a tax grab, smells like a tax grab, walks and talks like a tax grab, then, according to many of Ontario's opposition party politicians, it is a tax grab. And given that the ecofee started appearing on some cash register receipts on the same days as Ontario's hated Harmonized Sales Tax, it is no wonder that the Environment Minister was brought to his knees by opposition criticism and may yet lose his job over the debacle. GL believes that, at this stage of development of stewardship programs in Ontario, it is absolutely absurd to apply ecofees to products like soap, cleaners, detergents, and fertilizers that are regularly used by pouring them into the environment.

We are not advocating that excess quantities of these products should be put down the drain or into the garbage, but when did you last throw away any laundry detergent? Consumers don't understand why they should have to pay an end-of-life environmental management fee for  a product they don't usually throw away?

One reason that the ecofee debacle gained such political traction is that no one is quite able to work out who is in charge of the now failed program. The legislation provides that Stewardship Ontario designs the program, the Minister approves it at a high level, and then Stewardship Ontario decides on the details and implements the program. However, the Ministry of the Environment also makes the decision on the products that have to be included. One might well think that the program has been deliberately designed to be so complex that it is impossible to determine who is in charge of what. However, to his credit, Ontario Environment Minister has publically taken credit for the debacle. What happens next is yet to be determined.

Colin Isaacs

Readers interested in a more in-depth analysis of who did what, when, and why are referred to the report of the Environmental Commissioner of Ontario entitled Getting it Right: Paying for the Management of Household Hazardous Wastes. July 27, 2010.  



In the past, pesticide applicators were exempted from registration as polluters under the US Clean Water Act. Now a court decision has changed all that.

In 2007, the US Environmental Protection Agency ruled that a New Pollutant Discharge Elimination System (NPDES) Permit was not required for pesticides applied to or around water if they were applied directly to water to control pests or if pesticides were applied over or near water in a way that would unavoidably have a portion deposited on water. The idea was that pesticides legally registered in the US would not be considered pollutants under the Clean Water Act.

Environmental groups challenged the rule and industry groups including the National Cotton Council of America also petitioned the court, mostly in support of the EPA's position.

Court Decision

Under the Clean Water Act, all discharges of pollutants into navigable waters are illegal unless allowed by a permit. The EPA and state authorities issue permits for specific discharges and general permits for a specific pollutant or type of pollutant over a region. The law requires that a permit can be issued only if the discharge of a pollutant under the conditions of the permit will not cause undue harm to the quality of the water. US EPA estimates that about 365,000 pesticide applicators and 5.6 million pesticide applications will now require permits before applying pesticides to water or to land adjacent to water due to the court decision. The court decided that:
The EPA tried to argue that once the pesticides are released, there is no longer a point source requiring an NPDES permit but the court ruled that the application of pesticides was a point source and easy to identify. The EPA's rule exempting pesticides from permit requirements was declared invalid.

Draft General Permit

The EPA has proposed a general permit for those discharges for which EPA is the NPDES permitting authority with state NPDES authorities responsible for their permits. Any uses not specified will require individual permit or alternate general pesticide permits. The general permit applies to mosquito and other flying insect pest control, aquatic weed and algae control, aquatic nuisance animal control and forest canopy pest control. The general permit will not be issued for pesticides discharged to waters already degraded by the specific pesticides and their degradates or discharges to outstanding national waters known as Tier 3 waters which are said to be of high quality or to terrestrial pest control of crops or forest floors. Agricultural stormwater runoff and from irrigation return flows have an ongoing exemption even if they contain pesticides. A general permit covers multiple facilities, sites and activities, usually for no more than five years. The EPA is going to exercise discretion in requirements for operators with "relatively small areas" based on thresholds of treatment areas.

The general permit includes requirements such as control measures to minimize pesticide discharge e.g. using the lowest effective amount at the optimum frequency, perform regular maintenance to reduce leaks, spills, calibrate pesticide application, develop a pesticide discharge management plan, monitor and take action e.g. identify known breeding sites for mosquitoes and develop plans for source reduction and provide documentation about the entities applying the pesticides. The operators will be required to consider other action for pest control in addition to chemical pesticides such as:
a. No action
b. Prevention
c. Mechanical or physical methods
d. Cultural methods
e. Biological control agents

States may choose to issue state general permits which are different and more costly than the EPA-permit. Some states have laws that forbid regulating at a higher standard than the federal level. Only about 10% of pesticide applications are expected to be covered by the EPA regulation; the other 90% will be state issued.

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The Centers for Disease Control claims that "The Fourth National Report on Human Exposure to Environmental Chemicals is the most comprehensive assessment to date of the exposure of the U.S. population to chemicals in our environment. CDC has measured 212 chemicals in people's blood or urine—75 of which have never before been measured in the U.S. population. The new chemicals include acrylamide, arsenic, environmental phenols, including bisphenol A and triclosan, and perchlorate. . . Each two year sample consists of about 2,400 persons. The Fourth Report includes findings from national samples for 1999–2000, 2001–2002, and 2003–2004. The data are analyzed separately by age, sex and race/ethnicity groups."

The CDC notes that finding these chemicals in people does not mean that there is an adverse health effect. Although there is a discussion about the chemical groups and their potential health effects, studies of health effects are separate from the body burden survey. For some chemicals, the CDC is also trying to measure the metabolites. These may be compounds which result when the chemical is degraded by bacterial action or sunlight, for example or when it chemically reacts with other pollutants already in the water, soil or air. More toxicology research is highlighting the need to study the health effects of multiple exposure to so many chemicals.

Water Disinfection By-products (Trihalomethanes)
Dibromochloromethane (Chlorodibromomethane)
Tribromomethane (Bromoform)
Trichloromethane (Chloroform)

The National Report on Chemical Exposure reported for the first time the blood levels of these disinfection by-products (DBPs). Human exposure to DBPs is mostly from chlorinated drinking water and recreational water such as swimming pools. DBPs are formed when chlorine reacts with natural organic materials found in water. DBPs are volatile at room temperature and can be detected in ambient air when showering, bathing, dishwashing and swimming. In drinking water, trichloromethane is usually at higher levels than the others. It is also used in industrial applications for refrigerants and feedstock and may also be released wherever chlorine-based chemicals are used for bleaching and disinfecting or disposed of as hazardous waste. DBPs tend not to bioaccumulate in aquatic systems but may stay in the water in closed pipe systems. While workers are exposed e.g. at pulp and paper manufacturing or water treatment plants, general populations are exposed mostly through ingesting chlorinated water and inhaling the water vapour. One of GL's associates chose to switch fitness centres because one was equipped with a bubbling hot tub right in the middle of the exercise area. The bubbling spa generated lots of water spray and a heavy chlorine smell. Some DBPs are absorped through the skin while bathing or swimming. Median blood levels can increase two to four times over the baseline immediately after bathing or showering in chlorinated water but return to baseline rapidly within one to two hours. The DBPs are quickly distributed through the body and may metabolize into other chemicals which are toxic in large amounts. In less than four hours, half the chemicals are eliminated in urine with only a small amount of the DBPs eliminated unchanged in the urine.

It is unclear whether small doses or the biomonitored levels have health effects. High doses of either trichloromethane or bromodichloromethane caused cancer in rats. Unless maternal toxicity was present, DBPs didn't cause reproductive or developmental effects in animals but bromodichloromethane altered sperm motility.

Interestingly, when GL's editor first joined the staff of the environmental group Pollution Probe in 1982, one of the first issues he had to deal with was the Metro Toronto Chairman Paul Godfrey's response to a Pollution Probe report, Toxics on Tap, discussing the possible health effects of halomethanes occurring in drinking water because of chlorination. Godfrey was outraged and had lined up a group of so-called experts to claim that Toronto's drinking water was perfectly safe. Now, twenty eight years later, the Centers for Disease Control have come out with a similar report with similar conclusions: halomethanes in drinking water and recreational waters MAY pose a health risk. Fortunately, alternatives to heavy chlorination of drinking water were available 28 years ago and are still available today. If only more municipalities would start to use them.

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Environment Canada published proposed Wastewater Systems Effluent Regulations on March 20 with a 60 day comment period ending May 19. 2010. The regulations will not be having much of an effect for several years (see below) but should eventually lead to cleaner discharges from many (but not all) municipal sewage treatment plants..

The regulatory impact statement states that these proposed regulations implement the Canadian Council of Ministers of the Environment Strategy for national effluent quality standards, applicable to secondary treatment or equivalent. The regulations also specify:
Costs are estimated to be $5.9 billion in discounted 2010 dollars but the benefits are said to be three times that or $17.6 billion. Most of this benefit is in increased property value.

There are about 3,700 wastewater systems in Canada. More releases to coastal waters have lower treatment levels than to inland fresh waters e.g. British Columbia has 36% of its served population receiving less than secondary treatment. This is in contrast to the US where the Clean Water Act requires secondary treatment for all municipal wastewater treatment facilities which also have permits which limit discharge and require monitoring and reporting. 949 facilities in Canada require upgrading and of these 399 are high-risk, which need to meet the regulation by 2020. Federal jurisdictions have 150 facilities in this high risk category needing upgrading, second only to Newfoundland and Labrador with 185.

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In 2003, the federal, provincial and territorial governments agreed to work together for a Canada-wide strategy for the management of municipal wastewater effluent under the Canadian Council of Ministers of the Environment. In Canada, responsibility for effluent is dispersed amongst the municipal, provincial/territorial and federal governments. Municipalities are required to provide wastewater treatment. Provincial/territorial governments regulate wastewater treatment operations and most require permits for the wastewater systems operators. These permits also specify discharge limits for specific substances in the effluent. At the federal level, The Fisheries Act covers release of harmful substances into fish habitat and the Canadian Environmental Protection Act allows for regulations of toxic substances released to the environment, but there has been no federal regulation of wastewater effluent in general [see preceding article]..
The CCME web site contains a number of technical and other reports. The general backgrounder discusses typical contaminants such as
Emerging Contaminants

Even at low concentrations, other contaminants have been found to be persistent, bioaccumulate and are toxic. Effects in birds, fish and wildlife, for example, in the Great Lakes, include tumours, organ damage, behavioural changes, reproductive disorders and population decline. They include:
Note: While all other provinces and territories have signed on to the CCME Strategy, Newfoundland and Labrador, Nunavut and Québec have not endorsed the Canada-wide Strategy for the Management of Municipal Wastewater Effluent. [From CCME Website April 21, 2010]

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To meet effluent standards, municipalities are encouraged to adopt model sewer by-laws. While industry is most often required to meet requirements related to individual company Certificates of Approval issued by provincial environment ministries, municipalities may try to control water emissions from business and homes. For example the Capital Region District in Victoria British Columbia has mandatory codes of practices for businesses called regional source control to reduce water emissions from specific business activities associated with certain pollutants. Each business activity has a guidebook for environmental regulations and best management practices for that activity and the section of the sewer bylaw which addresses the sector. Among these are:
Residential Source Control

The CRD also has advice for householder in source control. Whether home or business/industry many contaminants are only partially removed or require very expensive treatments to remove. CRD says, "Prevention is the best and the most economic alternative." Examples include:
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A report by CERES, a national US network of investors, environmental organizations and other public interest groups working with companies and investors to address sustainability challenges, reviews the water-related risks disclosed by 100 publically-traded companies in eight sectors: beverage, chemicals, electric power, food, homebuilding, mining, oil and gas, and semiconductors. Filing of information in annual 10-Ks or 20-Fs or 40Fs for non-US companies, all reports mandated by the Securities and Exchange Commission for publically traded companies, is considered by CERES to be better company disclosure than sustainability reports. The US SEC  issued a guidance in January requiring companies to report on climate change and water because, according to the SEC, 'Changes in the availability or quality of water…can have material effects on companies.'

Also expected by Ceres is discussion of management systems, water accounting data, performance in geographic context and supply chain water risks. Disclosures released before June 2009 are assessed. Scoring was out of 100 except for chemicals and homebuilding sectors which had another category called opportunity with a maximum score of 112.

Water presents both negative impacts e.g. 100,000 acres of farmland as well as housing developments stopped due to California water shortages or an estimated loss of 21,000 jobs and of $1 billion in revenues or positive e.g. DOW and DuPont see opportunity in products enhancing availability of freshwater. Newmont in Peru had to abandon gold reserves in 2004 due to local residents protest about water. Low water levels reduced hydroelectric generation during the 2007-8 drought in Georgia forcing the utility company Southern Company to buy $33 million in fossil fuels instead.

Generally water disclosure was seen as weak. No single company got more than 43 points. Diageo (UK) which makes alcoholic beverages scored the highest.

Some positive practices include:
However, the report says that the performance of companies falls far short of what is needed:
A Couple of the Eight Sectors

Beverage Sector

Water issues relate not only to bottled water and water contained in other beverages such as soft drinks, alcoholic beverages but many of the inputs are water intensive: sugar, wheat, hops, corns, grapes, and fruits. Freshwater sources such as surface and groundwater may be polluted or demands for limited supply due to climate change and agriculture, growing populations and industry. qnp45 For example drought in India in 2008 reduced sugar yields by 45% compared to the year before and can be problematic again. Consumer boycotts and governments responding to cut contracts for bottled water in some markets are a risk. Beverage companies are coming under increased scrutiny to meet wastewater discharge standards. qnp46

The top three companies are Diageo (43 points out of 100), Anheuser-Busch In Bev (34) and The Coca-Cola Company (34). Other companies included SABMiller(30), PepsiCo (29) and Dr Pepper Snapple (8).

The Chemical Sector

The Chemicals Sector uses water for cooling, cleaning, diluting, dissolving and generating steam and has impacts through wastewater discharges and spills, manufacturing, transport, and storage of chemicals. When the products are used, they can contaminate water and harm aquatic life. The Chemical Sector also plays a role in water treatment. And some companies say they are developing drought resistant seeds and agricultural inputs which reduce water use. Water scarcity is a risk factor especially as companies set up in water-stressed areas such as the Middle East. Spills, bans on chemicals which have turned out to harm the environment and health and explosions such as Bhopal have damaged the reputation so that citizens are increasingly resistant to siting of chemical plants which could pollute the water. The EU's Water Framework Directive is phasing out 33 priority chemicals that harm water in river basins. The US EPA is updating its toxic control law 52 The US Chemical and Water Security Act of 2009 will require high risk chemical plants in the US to reduce production and use of dangerous chemicals or make the chemicals less dangerous. An explosion in China in 2005 releasing 100 tons of benzene into the River led to revisions of the Water Pollution Control Law with higher penalties. 43 water companies in the US are suing the maker of Atrazine to get the company to pay for removing the chemical from drinking water.

The top three companies of water risk disclosure are Mitsui (33 points out of 112), Sumitomo Chemical (32) and PotashCorp(32). Other companies included DuPont (31), Monsanto (23), Syngenta (23), Dow (22), BASF (20)

Ceres is a national coalition of investors, environmental groups, and other public interest organizations working with companies to address sustainability challenges such as water scarcity and climate change. Ceres directs the Investor Network on Climate Risk, a group of more than 80 institutional investors and financial firms from the U.S. and Europe managing over $8 trillion in assets.

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The threat of higher electricity prices was plenty of political motivation for Premier Darrell Dexter's government in Nova Scotia to (some say) "cave in" to Nova Scotia Power Incorporated and affiliated companies in regard to reducing mercury emissions.

The Air Quality Regulations set the cap for at 168 kg of mercury emissions a year in aggregate from March 2005 to December 31 2009. Commencing in January 1 2010 and in each calender year following, the annual emissions of mercury were not to exceed 65 kg. per calendar year. When the lower cap was announced in September 2007, the press release began with "Nova Scotia's new air-quality regulations will reduce mercury emissions, improve air quality, protect people's health and safeguard the environment." The adoption of the national standard was said to part of the commitment in the Environmental Goals and Sustainability Prosperity Act to reduce mercury emissions by 70 per cent by 2010. The lower cap is now to be in effect in 2014.

CCME: Mercury Standards for Coal Power Plants

The Canadian Ministers of the Environment agreed to Canada-wide standards on mercury because of the hazards to wildlife and humans. Mercury converts in water to highly toxic forms, methylmercury, which accumulates in fish and other species such as river otters causing damage to the nervous system and reproduction failure. Human exposure is primarily due to food ingestion such as fish Effects include neurological and development damage and even low exposure can have effects such as learning disabilities in children. Risk is especially high for pregnant women, children and populations relying heavily on fish for food. Local and regional mercury emissions also add to the global pool of emissions which are transported across distances and borders to be deposited on soil and water elsewhere. Canada receives ten times the mercury it emits from elsewhere such as from coal fired plants n the US and Asia.

The coal-fired electric power generation EPG sector is the largest source of man-made mercury emissions in Canada. In 2003, an estimated 2,695 kg of mercury were emitted by the EPG. The CCME agreed to set mercury Canada-Wide Standards CWS for this sector.

In the CCME standard, the implementation for each province and power companies are described. Nova Scotia Power was to choose options to:
A Little More Foresight

So the Government and Nova Scotia Power had four years to plan and implement something that has been agreed to on a Canada-wide basis. It could be that it might not have been completely feasible but both parties ought to have known before they are more than six months into the key target year 2010. The threat of higher prices for electricity seems to be a surprise to the government and becomes the reason for failure to honour the CCME agreement. For the last decade, this is exactly the gambit that GL's editor has heard from the coal-fired power sector at whatever regulatory event he attended: "If the government increases the requirements (usually related to climate change), we will raise the rates and they will lose their political heads because of public outrage." Brennan Vogel of the Ecology Centre in Halifax was interviewed on the CBC and suggested that the health effects of mercury were significant and that the government could have been more creative in finding solutions and used more foresight.

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A 41 page guide to global and regional initiatives on water and business has been prepared by the World Business Council for Sustainable Development and the International Union for Conservation of Nature. A table groups the initiatives under one, two or three ideas:
Each initiative is on one page with various information about it in a common format. For example, the WBCSD Global Water Tool©) provides a web site, contact, objectives such as "Enable effective communication with internal and external stakeholders", key features such as "an Excel workbook, online mapping system that plots site locations with external water datasets and spatial viewing via Google Earth." Also included is who can access the tool, target audience, available materials, geographic and sectoral focus and other details. A water glossary and other links are also provided.

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Research published in the Journal of Great Lakes Research indicates that even when chemicals are banned and toxic exposures are reduced, conditions can increase the exposure. Researchers led by David Jude of the University of Michigan and including John Giesy who is Canada Research Chair in Environmental Toxicology located at the University of Saskatchewan found that invasive species are changing conditions.

In 2000-2001, dredging of the sediment at the mouth of the Saginaw River removed many harmful chemicals from the Bay leading to a steep decline (65%) in the levels of the PCBs in the walleyes, a sportfish in the Saginaw Bay. The food of the walleyes used to be alewives a fish which has declined. Now the walleyes feed on round gobies which in turn feed on zebra mussels. Each zebra mussel filters a litre of water every day accumulating its own body burden in contaminants including relatively high concentrations of Polychlorinated biphenyls PCBs. The manufacture of PCBs was banned in the United States in 1979 (in Canada in 1977), Now that the walleyes eat the invader zebra mussels, the toxics are transferred to the walleye and in turn to the birds that eat the walleye and the mammals that eat the birds. The cycle is putting PCBs back into circulation.

The US Environmental Protection Agency allows 2,000 nanograms per gram of fish before a fish advisory has to be issued. The highest levels were in large walleye containing an average of 1,900 nanograms per gram of fish.

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One of the authors of the above study is John Giesy, who as Canada Research Chair in Environmental Toxicology at the University of Saskatchewan, developed a H295R Steroidogenesis Assay which is a rapid, relatively low cost test for screening for chemical compounds which have the potential to disrupt the human endocrine system. The research which was supported by the Western Economic Diversification Canada was approved for use by the US Environmental Protection Agency and the Organization for Economic Development and Co-operation. The University of Saskatchewan has set up a wholly-owned subsidiary to market the test globally. A number of government agencies are wanting to test wastewater effluent for hormone disruptors.

His lab has also developed other analytical methods for assessing such chemicals as perfluorinated chemicals PFCs which he said were never expected to show up in the environment and accumulate in animals. The chemicals represent multi-billion dollar businesses and are found in widespread applications including industrial, medical and household products. PFCs have been used as replacements for CFCs in refrigeration but are potent greenhouse gases. Until just a decade ago, there weren't even the measures to test for their fate in the environment but now they are found in many types of habitats and in the tissue of wildlife around the world. He is active in green chemistry with the idea of achieving the benefits of chemicals without the negative environmental impacts. Giesy's honours from around the globe and publications make a big list, for example, he was named Einstein Professor by the Chinese Academy of Sciences, a rarified and select group of scientists similar to those who win the Nobel Prize and was awarded yet another honourary title, a prize and an offer of over 1 million dollars of research grents for him and a Saudi Arabian scientist from King Saud University in Saudia Arabia.

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The Economics of Ecosystems and Biodiversity (TEEB) is a global study funded by the G8 and five major developing economies. A TEEB report on biodiversity and business released July 13 by the UNEP, the European Commission and supporting countries provides some insight into how business faces risks and opportunities from biodiversity. Among the many biodiversity issues is also water supply and quality. Biodiversity provides water services and requires water. Ecosystem water services include riparian vegetation which filters waters and reduces erosion, flood protection, catchment services such as receiving wastewater, microbiological purification of wastewater, carbon sequestration, recreational and cultural services. Many businesses require reliable sources of water and influence water quality through wastewater discharge. Water supply is dependent on well functioning ecosystems including lakes, rivers, streams and wetlands, as well as  on land use practices.

The report suggests that water represents both risk and opportunity. Water quality is harmed by overuse of fertilizer, poor sanitation facilities, and stormwater runoff. Businesses may have risks of increased water costs, shortage of water including restrictions and rationing, and damage to reputation due to excess use of water or poor water treatment. Business opportunities include water trading, new technologies fo waste-water treatment, desalinization and closed loop systems, new products and processes using less water, improved reputation through water management initiatives and partnerships with local communities. Water quality trading using water footprint methodologies are emerging as a form of water accounting . For example, SAB Miller collects data for sites and regions to produce a foot print for a particular product e.g. litre of beer. Climate change exacerbates local stresses due to water quality affecting coral reefs and other biological resources.

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The report is also supported by the European Commission; the German Federal Environment Ministry; the UK Government’s Department for Environment, Food and Rural Affairs; UK Department for International Development, Norway’s Ministry for Foreign Affairs; The Netherlands' Interministerial Program Biodiversity; and the Swedish International Development Cooperation Agency.


Stephen Schneider, climate scientist at Stanford University died of a heart attack July 19, 2010 while flying from a science meeting in Europe. He was one of the scientists who believed that scientists should participate in popularizing and communicating climate science. In the university press release, his colleague Jeff Koseff, also at Stanford's Woods Institute for the Environment, said Schneider was so sick with cancer seven years ago that he was just about gone then. But he participated aggressively in his own treatment documented in a book called Patient from Hell (2006) and drew a connection about the need for action in the face of uncertainty with both the cancer and the climate. He wanted to inform the media and people that climate wasn't a matter of either/or but a range of possibilities.

Scientists Popularizing Science. Gallon Environment Letter. March 26, 2010. Vol 15. No. 1

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Rick Smith, Executive Director of Environmental Defence (Canada) and Bruce Lourie, President of the Ivey Foundation wrote the book Slow Death by Rubber Duck. They tried to "detox" themselves for a couple of weeks , for example by not drinking or eating out of plastic, then sat in a condo with air fresheners and other possible polluting household products for  four days and then tested their urine or their blood. Lourie ate canned tuna and sushi because he was testing for changes in mercury levels. The results showed that their exposure had resulted in some increased levels of certain chemicals (measured in nanograms per mL) of Smith's urine and in mercury of Lourie's blood. Seven groups of chemicals are discussed: phthalates. "the non-stickies" (perfluorochemicals) , polybrominated diphenyl ethers (PBDEs), mercury, triclosan, pesticides, and bisphenol A.

Some of the stated take home messages are pretty good although most of the emphasis is on consumer choices:
1. Consumer choices have an effect on the pollution levels in their bodies.
2. Consumers should get involved in pushing legislators to protect against these toxics.

There is a lot of valuable insight here which might encourage householders to consider more what they buy and to use their purchasing power to buy safer alternatives. There's an observation that industry favours regulation when it supports their cause e.g. the fire retardant maker who lobby for legislation increasing fire protection for clothing, furniture fabrics, and electronics.

On the down side the book has a disturbing parallel track which seems to be saying that the threat in the home from consumer use of products, not industrial pollution, is responsible for toxic levels in the blood. Also although popularizing science is a good thing and the title is certainly clever they say so many things about such a wide range of issues that it is difficult for this reader to disentangle what is anecdote, opinion, wise precept, scientific uncertainty, scientific consensus or just plain wrong.

The authors are so very keen to get credit for what they call "Environmental Defence Canada's groundbreaking Toxic Nation campaign" for which they tested the blood of 30 Canadians for over 130 pollutants. That's a big project with a big price tag if done right and they should get credit although biomonitoring and the concept of body burden has been part of toxicology for quite a few years and isn't their innovation (See example in note (1)). Also they purport to be doing an "experiment" but without any proper methodology and with extraordinary keenness to get results ie increases in blood levels of certain chemicals. They interpret some very tiny changes e.g. an increase of 3000 nanograms (1 billion nanogram = 1 gram)/mL as huge. GL notes that it is true that there is scientific support for concern about even very small concentrations of certain chemicals but an increase of this small amount is still a very small amount.

Foreword by Theo Colborn

Theo Colborn wrote the foreword to the book which ought to be a good recommendation. She writes that most of the hormone-disrupting chemicals are made from oil and gas and that industry deliberately created more and more chemicals in greater quantity, keeping the public in the dark about any problems. She suggests that hormone-disrupting chemicals may be "a more imminent threat to humankind than climate change" but both are "a spin-off from society's addiction to fossil fuels." She recommends switching to alternative forms of energy to reduce the availability of such compounds as benzene which is a building block used to make bisphenol A, phthalates, triclosan, PCBs,  and PBDEs (flame retardant). She recognizes that exposure is more than in the household, writing, "the primary source of mercury (and in our bodies) is the emissions from coal-burning power plants."

GL's editor attended a session at the AAAS (American Association for the Advancement of Science) annual meeting in 2010 at which Theo Colborn spoke about efforts to have legislators adopt rules on endocrine disruptors. She is author of the 1996 book Our Stolen Future which is about chemicals which have endocrine disruptoring ED impacts. The endocrine system are the various glands in the body which regulate the system through hormones. This is why these chemicals are sometimes also called hormone mimicking. EDs are defined on the website as "Endocrine disrupting chemicals alter development of the fetus in the womb by interfering with the natural hormonal signals directing fetal growth. Their impacts, sometimes not detectable until years or decades after exposure, include reduced disease resistance, diminished fertility and compromised intelligence and behaviour." EDs were just a small wedge of the topics presented at the AAAS conference on toxic materials; many of traditional and new chemicals are still being produced which affect health and the environment. For example, asbestos still shipped out of Canada though its use is banned here is responsible for 90,000 deaths globally from asbestos-related cancer and many more suffer from debilitating disease.

Detox and You'll be All Right

The book says "Our choices as consumers really do have a profound and very rapid, effect on the pollution levels in our bodies. Through doing things that people do every day, Rick increased his urine levels of monethyl phthalate MEP 22 times, his levels of bisphenol A 7.5 times and his levels of triclosan a mind-blowing 2,900 times. Bruce increased his mercury levels almost 2.5 times." The home is seen as the most serious source of pollution as they write, ""Today's most serious toxins lurk in the most private recesses of our homes." (2) They

The implication is that if one conscientiously avoids certain products in the homes, then one's body will "detox" and the next measure of urine or blood will show the reduction. When the authors in quite a few instances say the only safe level of exposure is zero, one isn't sure why this positive view about this quick detoxing is presented with such enthusiasm. Apparently other exposure: in the workplace, in the playground, in congestion, at school, in the water, in the air, in the soil seem to be considered relatively insignificant although in reality, chemicals from all these source add to body loading of chemicals.

Biomonitoring or testing people's blood or urine provides an indicator (if done with a more scientifically valid methodology) and important insight in how people are exposed to chemicals but by itself while it might be a reason for paying attention to the alarm is not in itself proof of harm or of safety. For example, Lourie has 400% of the average concentration of mercury in Canadians to start with possibly because he eats mostly fish or he has been studying mercury and been exposed elsewhere. Any increase detected in mercury blood levels were lower than what he had already which he didn't seem that concerned about. And he seemed quite happy to accept other types of risks e.g. eating raw fish which in the US every restaurant post as a potentially hazardous.

Chapter 5 on mercury is written by Lourie who takes a somewhat broader view than just the "consumer products are responsible" but still focus on home exposure. He "detoxed" by avoiding what he thought might contain mercury and then ate canned tuna to see a rise in mercury concentrations by 250% by the end of 48 hours. We have no way of knowing whether his higher level to start with affected how much he retained but the authors seem to suggest that he can "detox" again. While reassuring, this optimism might be misleading. Mercury is bioaccumulative which means it may stick around. The actual body burden of chemicals isn't just about blood or urine levels. Persistent toxic chemicals find a home in the body as the blood circulates; some chemicals are more prone to settle in some locations than others e.g bones, fat, brains, organs such as kidneys, glands such as thyroid, and so on. The mercury may be change into other forms of mercury which settle somewhere in the body. These stored chemicals may not be easily measured.

Local Pollution is Out: Environmental Justice No Longer An Issue

The book states that the idea that poor people "are more adversely impacted by toxic chemicals because of their proximity to industry, toxic waste dumps and the like" is no longer an issue as even the wealthy carry a body burden so everybody has a problem and everyone needs a solution. GL: This seems to be another part of the agenda of this book to dismiss the impacts of industrial pollution. They say that the nature of pollution has changed and that
1. Pollution is now global rather than local
2. It's moved from being highly visible to invisible and
3 in many cases, its effects are now chronic and long term rather than acute and immediate."

GL wonders how these points which seem to colour their perspective can possibly be supported by evidence. We have local (and regional) and global pollution. Some of it is visible. Some of it has always been invisible e.g. the reason early industrial mining operations used to carry canaries into coal mines is because the gases which could lead to an explosion couldn't be seen or smelled. If the canary in the coalmine died, it was time to get out. Most people in the past and now don't see the water pipes which in some cases (then and now) are lead and contaminate the water with lead. Many people in the world still die of water-borne diseases because they can't see whether the water is safe and even if they could still have to drink water to survive. GL wonders how these Torontonians can think that the haze over their city is invisible. While chronic disease from pollution is also an issue, acute effects are serious as well. A 2007 Toronto Public Health report on traffic-related pollution estimates that children experience more than 1,200 acute bronchitis episodes per year. In 2004, Toronto Public Health (TPH) estimated that air pollution (from all sources) is responsible for about 1,700 premature deaths and 6,000 hospitalizations each year in Toronto. Smith especially seems to have a view which is a kind of eco-colonialism. The book don't make sufficient connections to the lifecycle of household products - it is as if the only thing that matters is the householder not the pollution along the chain of the product such as the pollution caused locally in China or India where many of these products are made. David Suzuki wrote a back-jacket recommendation for this book and GL wonders whether he is just being an environmental partner with another environmental group or if he supports this view which seems to say we don't have to worry about the smokestacks, the pipes, ships, manufacturing facilities and damaged drilling rigs releasing toxics into the air and water into the environment.

A New Kind of Pollution

The authors apparently believe that finding pollution inside human bodies is a new discovery they personally have made and revealed to the public, "Pollution is actually inside us all. It's seeped into our bodies. And in may cases, once it is in, it's impossible to get out." They imply that this is a change from the other kind of pollution: "Belching smokestacks. Sewer outfalls. Car exhaust. ...It's still seen as an external concern. Something floating around in the air or in the nearest lake. Out there. Something that can still be avoided." GL thinks that they must believe that the "old" kind of pollution doesn't find its way into the human body because they verge on the gushing in congratulating former President George Bush for a law restricting certain endocrine disruptors in plastic for children's toys, "The most significant pieces of consumer protection legislation in generations." That regime actively denied climate change negotiations, and delayed action on court-ordered action on acts such the Clean Water and Clean Air Acts. How does this "consumer protection" address even a minute portion of the concern the authors raise on their seven categories of chemicals, the most important effects of which may be for the unborn child developing in the womb. They offer similar high-level kudos for the Canadian government regulation of BPA in infant bottles and its chemical management program although no information is given for what impact either of these have on body burden. The authors say the toxic loading is from "countless' applications so why is such a small effort judged so highly.

When it comes to judging the dangers of these groups of chemicals, the authors seem to see extreme hazard but when it comes to solutions, very simple ones seem facilely great in their eyes. It is like the US education program in the Cold War era when children were taught to respond to the question "What do you do when you see the flash?" with "Duck and Cover" (seek shelter under their school desks) in case of a nuclear bomb explosion.If the bomb was far away enough, that might save some lives and injuries from flying objects but most would have died from nuclear fallout even if they survived the blast. The advice was inherently useless since there was no protective action the children and their teachers could take.

Consumer Roadmap

The Roadmap of simple changes consumer can "detox" their lives has some good advice with links to web sites with more information. but it too is idiosyncratic and sometimes wrong. For example, they suggest avoiding meats and dairy because of their fat content without acknowledging the importance of the nutritional value of these foods. There seems to be a lot of throwing out of stuff although instead of getting rid of a computer with flame retardant PBDE, an option is to recycle to a community group. Natural fibres such as cotton, hemp and wool are said to be good alternatives to synthetic fabrics because "They are chemical free and naturally fire resistant." GL: This advice is poor. The lifecycle for producing and processing conventional cotton can involve a range of chemicals. Health Canada doesn't agree with this assessment of flammability saying instead that cotton is among the fibres with the highest flammability. Hemp isn't mentioned but wool and bamboo are relatively nonflammable. Flammability is also affected by other factors such as texture e.g. a loosely woven fabric is more flammable than a tighter weave of the same fabric which is more difficult to ignite and has a slower burn. Health Canada says that the choice of fabric and design (including finishing) should enable children's sleepwear to meet flammability requirements without flame retardants although presumably cotton often does have flame retardants. Giving parents wrong advice on flammability isn't a very good idea.

Bruce Lourie was one of the keynote speakers at CANECT 2010 May 3-5, 2010. Toronto, Ontario.

GL found that reading this book was a little like another experience we had with a waterfowl. Someone gave us a wild goose which they had shot with pellets. When we were eating this morsel of anticipated delight, the meal turned into more of a bad scene. Although there weren't so very many pellets left, we felt leery about eating due to the risk of breaking a tooth on a pellet or possibly worse, swallowing a pellet. Some of the perspectives we discussed above made us equally leery about swallowing some of the stuff in this book even though it too has some appeal. Although Bruce Lourie's discussion on mercury provided an example of what could be done to better express concern about the "what goes around" concept, there was relatively less in the other chapters about  how pollution from the consumer products affect the community where the raw resources are mined or where the product is manufactured, the workers, the environment, the wildlife and the fish and how this in turn affects health again. Their view that the poor are now no longer adversely affected by poorer health outcomes due to environmental contamination is contradicted by a number of studies not to mention obvious occurrences such as the poor on reserves or disadvantaged neighbourhoods in cities in Norrth America as well as in developing countries exposed to hazards from electronic and other toxic waste shipped from Canada and other industrial countries. GL will discuss the concept of environmental justice in a future issue.
(1) Maud Walsh and others based about Superfund research funded by the US National Institute of Health Sciences write in the April issue of the AWMA em magazine that while thermal treatment of toxic chemicals can be effective, under many conditions, harmful by-products can form. They write, "An increased body burden for virtually every metal and organic chemical contained in incinerator particulate emissions, as well as the majority of known carcinogens and other chronically toxic chemicals has been observed downwind of incinerators."

Walsh, Maud, Stephania Cormier, Kurt Varner and Barry Dellinger. By-products of the thermal treatment of hazardous wastes: formation and health effects. Air and Waste Management Association: em (The Magazine for Environmental Managers). April 2010. [by membership/subscription] A similar web-based article is at
Smith, Rick and Bruce Lourie with Sarah Dopp. Slow Death by Rubber Duck: How the Toxic Chemistry of Everyday Life Affects Our Health.. Alfred A. Knopf Canada. 2009.

Colborn, Theo, Dianne Dumanoski and John Peterson Myers. Our Stolen Future. NY: Dutton, 1996.

Health Canada. Flammability of Textile Products in Canada. 2009.

McKeown,Dr. David. Medical Officer of Health .Air Pollution Burden of Illness from Traffic in Toronto Problems and Solutions. November 2007.


The Waste Management Branch of the City of Edmonton, Alberta won the A&WMA 2010 Waste Management Award. Some of the comments about the Air & Waste Management Association award included:
Air & Waste Management Association. 2010 Honors & Awards Winners. Waste Management Award. Calgary, Alberta: June 2010.                                       


It seems that the CBC thinks that species get their names from Mother Nature or somewhere. A recent CBC News story in Newfoundland reported that 'A team of marine biologists has discovered what it believes to be several new species of underwater creatures.' The news story goes on to conclude 'Many of the species collected are so new to science that they have yet to be named'. Well! If they have only just been discovered, how might they have obtained their names? Maybe the CBC thinks that marine animals have books of baby names from which they assign real Latin names before they are discovered by humans.

Whatever led to such an idea!
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