Interventions in Committee
 
 
 
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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.
Kelley Bush
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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 Wladyslaw Lizon Profile
CPC (ON)
I understand—and I don't know, so correct me if I'm wrong—that the radon gas we get at home would probably have different levels of radioactivity. How does this unit refer to the level of radioactivity in a gas? As I understand it, it's not only the level of the gas itself, but there's also the time of exposure. I would assume that the level of radioactivity plays a very important role here as well.
Tom Kosatsky
View Tom Kosatsky Profile
Tom Kosatsky
2015-06-18 17:23
It's slightly complicated, but I'll get onto one of my other hobby horses, for what it's worth. It's not the radon itself that causes the lung cancer; it's the so-called degradation products of the radon. Radon is an inert gas, so it doesn't attach itself to lung linings. It's when radon transforms itself by atomic degradation into a radioactive metal that the problem occurs, because that attaches to your lungs. That attaches to dust, so more dust in your house is a bad thing if you also have radon. That's really what causes the damage.
A becquerel is a unit of disintegration. One becquerel per metre cubed is one disintegration per cubic metre of space, so that 750 becquerels per metre cubed is 750 disintegrations per cubic metre of space.
Sarah Henderson
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Sarah Henderson
2015-06-18 17:24
That's disintegrations per second.
Tom Kosatsky
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Tom Kosatsky
2015-06-18 17:24
Yes, per second per cubic metre. Pardon me.
Each one of those alpha particles that either the radon itself or the metals it produces or releases causes a packet of energy to get into any cell it's next to. Radon gas itself, because it doesn't react—it's inert chemically—tends to be farther away. The radon-related metals that it produces tend to be very close to the cell linings. When they also release these alpha particles, it's the alpha particles themselves that wreck the nucleus of the cell and that ultimately cause lung cancer.
View Cheryl Gallant Profile
CPC (ON)
Okay. Then let's talk about government being a customer of science.
You had mentioned September 11 and the anthrax attack, but in addition to kinetic and chemical threats, we also have radioactive threats, situations that are not meant for peaceful use. In what way has CNL contributed to tracking and detecting radioactive material for the purpose of keeping our country and its citizens safe and secure?
Robert Walker
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Robert Walker
2015-06-16 11:59
Thank you for that question here.
This plays a bit to the theme I've tried to pull on. Disruptive technologies have, ideally, very positive effects on societies. Much of what we try to do, governments with industry, is to maximize proactively the potential for that constructive benefit. It's also the case that technologies can have a downside that has public safety and security consequences. How is it that we're able to get the early indicators of what the downside could be and engage, as opposed to reactively, rather proactively, how we can better address that issue? I would suggest that Dr. Gupta's comments around the Internet of things highlighted a number of the areas where we know there are likely to be security implications emerging. How can science be simultaneously helping us understand the upside and the downside, and address them both at the same time?
At CNL, for example, Canadian Nuclear Laboratories, we're heavily engaged with the security apparatus of government to help understand, for example, the illicit tracking of nuclear materials around the world, to make early detections of that material, for example in containers, and then to be able to provide a fingerprinting of that material to trace it back to source of origin, which allows the security community to intervene and deal with the criminal aspects of that particular activity. These are all technologies, of course, that were spun out of the civil application of nuclear technology for nuclear energy, the upside of it. But at the same time as being conscious of the negative side, and helping the security apparatus of government be ready for that, we're helping that technology be a net contributor to society.
Steven Wilson
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Steven Wilson
2014-02-13 9:14
I'm pleased to be able to talk to you a little bit about some of the unique processing and production challenges associated with rare earths. I'm a process engineer and a metallurgist by background. I've spent many years in the Canadian mining industry working on technology development, and more specifically on the application of technology development.
Rare earth projects, from one perspective, are like any other mine. You have to identify a resource, you have to dig the stuff out of the ground, you have to find a way to concentrate the valuable minerals and to sustainably and environmentally dispose of the material that is not in your value chain, and you have to go through and refine and purify.
Rare earths go through all of those same common steps, but the steps have to be applied a little bit differently. We're still, in many ways, at the stage where that front-end conventional mineral processing, which would be a size reduction and a physical separation, has to be developed for the unique minerals that are associated with the rare earth elements in their atomic matrixes. That's the kind of conventional development that a mining company would have to go through to produce a concentrate of some kind that could be further purified and refined.
The challenge in rare earths, as I know you have heard, is that after you get to that primary concentration of minerals, the challenge is that you don't actually have a rare earth mineral yet, you have a mineral that has a little atomic component of rare earths that then has to be separated by a process called hydrometallurgy. Dr. Papangelakis is going to talk a little bit more about some of those details.
Even after that, in rare earths you have a challenge because the testing that's required to do that hydrometallurgical flow sheet development, and then the actual separation and production of metals, still requires a sufficient sample to be able to test. What that means is that instead of having a couple of kilograms of sample that you might get from a drill core for a copper mine, or a gold mine, or a nickel mine, you have to take hundreds and hundreds of kilograms of material so that you can get a kilogram of concentrate to do the next testing. What that means is for the producers and for the potential operators of these projects, the development costs might be an order of magnitude larger than they would be for a conventional base metal or precious metal mine.
As we look at those things, specifically in those separation technologies, it's that production of an intermediate concentrate, which you can do further testing and development on, that creates the unique challenge to rare earth elements. Then as you do that test work, each of those heavy and light rare earths are very close on the periodic table and they are very difficult to separate. The final separation and refining stage is tremendously more complicated or complex than a typical gold mine might be, where you're just smelting and pouring off a doré bar.
As I mentioned earlier, Canada has some tremendous leadership in expertise around that science and technology and about applying those technologies into the mining industry. We are uniquely placed in the world, with some competition in South Africa, some competition in Australia, around being able to deliver those services effectively.
Similarly, on the environmental side, we have challenges around the often radioactive nature of minerals associated with the rare earths. There is an effective treatment requirement for uranium, for thorium, for some of the aluminiums that are associated with rare earth deposits. There are challenges there and issues around developing and understanding the toxicity. We have some significant efforts still to go through to be sure that we can produce these metals in an environmentally sustainable and appropriate manner.
The metal production piece, as I mentioned, the difficulty in that final separation and producing something that's available for your customer, is really the key to realizing the overall economic benefit to the industry in Canada.
There are no rare earth refining facilities in Canada, and no real research or development facilities to do that last step in the development process. Most of our Canadian companies are forced to go to Mintek in South Africa or to ANSTO to be able to find that capacity at the moment. Part of the objective of the network is to be able to pull some of that together effectively to be able to deliver those things where we have experience and expertise, to be able to provide an infrastructure and a joint capability to deliver that final stage of the process.
In the short term, our objectives are to look at very focused, industry-driven project work that will apply existing technologies that will get us to that early stage production with what we know now. But the longer-term need that we have as an industry is actually to develop better technologies, to develop more appropriate solutions, and to focus on the downstream opportunities there.
There are conversations in the marketplace about substitutions. At the same time, we have an opportunity as an industry in Canada to develop new applications and to look for new opportunities to take advantage of those things. As I mentioned earlier, the long-term true benefit to our science and technology community is the development of those highly qualified persons who are capable of carrying the industry forward to the next generation.
Dr. Papangelakis.
View Geoff Regan Profile
Lib. (NS)
Professor Papangelakis, in terms of the byproducts and wastes that are involved in mining and processing rare earth elements, my understanding is that thorium, which normally is produced in that process, is radioactive. Although it has a considerably shorter half-life than, say, uranium, it's still a challenge and an issue.
How much of a problem is it for the development of processing facilities here in Canada, and what research and development is being done to address this challenge?
View Ryan Cleary Profile
NDP (NL)
Another question is in terms of how rare earth mining compares to other mines in terms of safety, such as, for example, the safety of handling tailings and that sort of thing. Where does rare earth mining rank? In other words, iron ore might be the safest, all the way down...where would rare earth rank?
Christiane Villemure
View Christiane Villemure Profile
Christiane Villemure
2013-11-25 16:37
Mr. Chairman, it's a difficult question to answer. I can risk an answer.
The major concern we hear about rare earth mines is associated with radioactivity, mainly thorium. It's sometimes uranium, but most of the time it's thorium. Thorium is less nasty and less radioactive than uranium.
So far, the data we have indicate that most Canadian deposits do not have high concentrations of radioactivity. They are at levels that need to be managed in any case, and the environmental assessment process normally helps to identify what's in the deposit and how to manage it. It's the company that will have to develop a plan to be able to do that.
Magdi Habib
View Magdi Habib Profile
Magdi Habib
2013-11-25 17:15
Mr. Chairman, the only elements associated with the rare earth elements could be the radioactive elements, like thorium and uranium. If that could be of any value to extract and stabilize, that could be an added value, as would tantalum too.
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