Proceedings of the Standing Senate Committee on
Energy, the Environment and Natural Resources
Issue 11 - Evidence - February 1, 2007
OTTAWA, Thursday, February 1, 2007
The Standing Senate Committee on Energy, the Environment and Natural Resources met this day at 8:37 a.m. to review the Canadian Environmental Protection Act (1999, c. 33) pursuant to section 343(1) of the said act.
Senator Ethel Cochrane (Deputy Chairman) in the chair.
[English]
The Deputy Chairman: Good morning everyone. Today we begin the second part of our study of CEPA, which deals with perfluorocarbons, PFCs.
John Arseneau, Director General, Science and Risk Assessment, Environment Canada: Thank you very much. I will begin by briefly introducing myself and my colleagues.
I am the Director General of Science and Risk Assessment at Environment Canada. Both the New Substances Program and the Existing Substances Assessment Program come within my area of responsibility.
To my right is Dr. Derek Muir, one of Canada's foremost researchers in the area of perfluorinated chemicals. He has been doing extensive work on Arctic contamination, persistent organic pollutants for many years.
To my left is Dr. Steve Clarkson who is with Health Canada and is responsible for the area of Existing Substances Assessments and Management.
Ms. Myriam Hill is with Health Canada and she is a risk assessor in the New Substances Program within that department.
We have tried to provide as much scope as possible in terms of engagement and involvement in this particular issue.
I believe a presentation was emailed to members and perhaps I can take people briefly through that presentation.
Perfluorinated substances have become common in our daily lives. These substances are used in industrial, commercial and consumer applications. Production started in the 1940s with minor applications in the industrial area, and grew rapidly in the years after the Second World War into different types of products.
Perfluorinated substances are used in industrial processes to produce other chemicals such as fluoropolymers and fluorotelomers, which have specific uses in the products we buy today. These substances have a lot of commercial applications. They are used in stain and water repellents for materials such as paper, fabric, leather and carpets. They are used as sizing agents to resist the spreading and penetration of liquids for packaging and paper products, and also as levelling agents to provide an even surface for things such as polishes, floor waxes, et cetera. These materials have an interesting and unique chemistry that is widely applicable for many different types of commercial products.
We think that the release of fluorinated substances to the environment comes from two routes. The first is that they are often left as residuals in the products that we buy and use, and these residuals escape over time and are transformed in the environment into perfluorinated compounds such as perfluorinated carboxylic acids, PFCAs, and perfluorooctane sulfonate, PFOS. We also believe that some polymers degrade over time and release additional perfluorinated alkyl sulfonate compounds, PFAs. That is how these substances emerge into the environment as both acids and sulphonates.
This issue began to grow only in the late 1990s. Prior to this, we did not have reliable test methods to show their presence in the environment. It was only around 1999 and 2000 that we started to see these particular compounds showing up in places where they should not have been. In essence, they were in animals in the High Arctic. Part of this story is about how research has been able to identify an emerging issue for us and the actions that we take as a result.
We also found that these materials are subject to long-range transport. We started to look for them in unique places such as the Arctic, but we also looked for them in homes and in humans. On slide 5, you will see that perfluorinated compounds are now ubiquitous in the human population. There are trace amounts in everyone. We also find them in wildlife in remote areas. The widespread nature of these compounds causes concern and is the reason why the public and the government are calling for action.
We have also been able to use tissues from wildlife tissue banks collected over several decades to go back in time and trace how the concentrations have grown over the past 30 or 40 years. Canada has that unique capacity because we have these banks of tissue samples that were collected in previous decades. Other jurisdictions do not have that particular capacity so they could not do comparisons. Derek Muir can address any questions with respect to how that research emerged.
This area is new and emerging. Science is catching up with an issue and governments are running to catch up as well. Our level of knowledge on perfluorinated substances is uneven. We have a lot of information on certain substances like PFOA and PFOS. These chemicals were the most widely used of these classes, for which there has been a significant amount of testing and toxicological information. For others, we are still at the information gathering stage. For many, we even have difficulty clearly identifying what they are and how to describe them in a chemical way that will allow us to analyze and test them adequately.
We also found through our toxicological research that chemicals such as PFOA and PFOS have some adverse effects in lab animals. That finding has caused us to pose questions of what exactly are the mechanisms for the adverse effects: Why is that happening and how is it happening? There is still a lot to understand in this particular area, including toxicology, the relative contribution from different sources and how humans are exposed.
Part 5 of CEPA is about controlling toxic substances. It provides us with tools to gather information to inform risk assessment and management. It allows us to assess new substances that enter the marketplace and those that are already in commerce. It also allows us to implement risk management measures to protect the health and environment of Canadians.
Much of this work starts with the new substances provisions of the act. The objective there is to take a preventive stance — in essence, not to allow new problems to emerge. These provisions our first line of action.
With new chemicals, we do both a health assessment and an environmental assessment on each new substance as it is introduced into Canada in specific volumes. Based on those tests, we have the authority to take actions to severely restrict, prohibit or apply conditions with respect to the use of those chemicals. On page 8, we show how early action consulted the research, used the new chemical provisions and then moved into an examination of products that already existed in the marketplace.
In 1999, two new substances containing PFOS were assessed under the new substance provisions of CEPA. The conclusion of those assessments led to the imposition of restrictions on those chemicals. We took that action in light of recently emerging science at the time that indicated the presence of these chemicals much more widely than we had expected.
What was the reaction to that finding? In the year 2000, the3M Company, which was the major manufacturer of PFOS, agreed with the U.S. Environmental Protection Agency to phase out PFOS and its precursors voluntarily from the market.
We issued surveys to gather information under provisions of CEPA to understand better the use of those chemicals that already pre-existed. We had already prohibited the new ones proposed to come in. Now we needed to go back and examine the ones already on the market. Based on information we secured from companies, we launched a process to do a thorough risk assessment of perfluorooctane sulfonate, PFOS, in the Canadian context. Recently, we issued a final conclusion with respect to that assessment and proposed regulations.
We also worked internationally. With the long-range transport of these compounds and their attachment to consumer products that are widely traded, international action will be a highly important part of solving the problem. We launched work through the Organisation for Economic Co-operation and Development Chemicals Program and we working within the Stockholm Convention on Persistent Organic Pollutants, POPs, to develop international arrangements on limiting the use of these chemicals.
Slide 10 shows that PFOS and its pre-cursors already on the Canadian market were assessed under the appropriate sections of CEPA. The draft risk assessments were released in 2004 and the final risk assessments were released in 2006. The conclusions were that, from the human health side, based on conservative safety margins, the current exposures that Canadians face do not constitute an immediate danger to human health. However, from the environmental side, we found that these compounds could have immediate or long-term harmful effects on the environment because of the tremendous persistence of these chemicals and the way in which they bioaccumulate in wildlife. We decided that actions should be taken that will prevent the increased risk exposure for humans as well.
The bottom line is that we believe we have caught this particular issue in time. If we can regulate these substances adequately to reduce concentrations in the environment, the consequential effect will be to reduce exposures for humans. We have not hit a critical human health issue yet according to the assessment from Health Canada.
After the assessment was released, risk management measures were proposed. There is a proposal to regulate these substances by way of a prohibition for most of their uses. That prohibition will proceed according to normal regulatory process, including consultations with the public to help in their design. We have strict timelines for putting those regulations in place that were established under CEPA. Within the next year or so, we will see finalized regulations with respect to PFOS. There will be some exceptions for the use of PFOS in certain areas, such as firefighting foams, which will have a phase-out period while we transit to new products.
New polyfluorinated substances continue to be developed. They are continuously coming on the market and they continue to be assessed and managed through our new substances program. An example of this management was in 2004 when four new substances were assessed under the program. The conclusion was that they would be sources of bioaccumulative, persistent and inherently toxic long-chain PFCAs. That means they would be chemicals of high concern for us. Section 84 of CEPA allows us to put temporary prohibitions on these products, which will last for a two-year period. The prohibitions are followed up with a proposal to regulate those substances within that two-year time period to prolong the prohibition of those substances coming to the market. That prohibition happened in June 2006 when the government issued an action plan with respect to PFCAs plus proposed regulations with respect to these four substances.
That left us with a question of what to do with similar kinds of substances that were already on the domestic substances list and in commerce in Canada. We have engaged in research and information-gathering on similar kinds of chemicals to develop a more comprehensive plan. The kinds of actions we take under the new substances program are of a stop-gap nature. They are preventative and lead us to do other work for similar kinds of chemicals.
At page 13 of the presentation, we move to a different branch of this chemical family — perfluorinated carboxylic acids, PFCAs, or the acid form of perfluorinated substances.The most commonly known form is perfluorooctanoic acid, PFOA, which is the eight-carbon-chain length of this acid. In June 2006, Environment Canada published in the Canada Gazette an action plan to address these kinds of chemicals. We have an assessment under development for PFOA and soon, we will have a state-of-the-science report with respect to these chemicals. They are under very strong scrutiny in Europe and through the United States' Environmental Protection Agency, which is taking the international lead on much of the human health toxicology with respect to PFOA. Environment Canada is participating with them in generating results.
The key outstanding questions are reflected at slide 14. We still need to know more about the toxicology of PFCAs, in particular the PFCAs that are not of the eight-carbon-chain-length variety like PFOA and PFOS, which have been more highly tested the others.
We need to know more about the relative contribution of a variety of sources for the kinds of PFCAs that we see in the environment today. We also need to know more about the human health exposure pathways. We are undertaking a great deal of international research and cooperation in this respect. A large international effort has come through the OECD to identify all the various members of the PFCA family of chemicals. Toxicological research is happening in several countries. As well, Environment Canada is participating in research on the following: the concentrations and trends in Canadian water; indoor air and ambient air; urban centres; and wildlife, in particular in the Arctic. Canadian research is truly on the leading edge with respect to understanding what is happening in thelong-range transport issue. We are also looking at developing a common regulatory approach internationally so that the problem can be resolved on an international basis.
At slide 16 we can look at the actions taken by other jurisdictions. PFOS has been most actively assessed by the international community. Assessments have been conducted by the European Union, the United Kingdom and Sweden at the OECD. All of us have identified concerns over persistence and bioaccumulation. Risk management actions that are either currently in place or are emerging are listed on this slide.
The European Union has issued a directive on restricting the marketing and use of PFOS. The U.K. is proposing to restrict supply and use of PFOS and substances that degrade into PFOS. Sweden has proposed a national ban and nominated PFOS for inclusion in the Stockholm Convention on Persistent Organic Pollutants. Australia is taking steps to phase out PFOS.
The situation in the United States is unique. Once 3M agreed to phase out of the business voluntarily and before anyone else stepped in to take up the business, the government imposed a provision through their new chemicals program to preventre-entry of that chemical into their market.
For other PFCAs, many large assessments are underway. The United States Environmental Protection Agency, US EPA, is probably the foremost in terms of looking at PFOA, especially from a human health perspective. The OECD also has assessments underway under their chemicals program, and Germany is the lead country to complete the ecological risk assessment with respect to PFOA. The European Union has a large research effort called Perfluorinated Organic Chemicals in the European Environment, PERFORCE, which is trying to understand better the chemistry and the release of these particular substances.
By way of risk management actions, the U.S. has recently introduced a stewardship program challenging manufacturers in this area to come up with, over time, alternative chemicals or chemicals that have a much lower hazard profile. Canada has also adopted the same principles and has included those principles as part of the action plan in Canada.
The OECD has held many science workshops and discussions leading to common approaches with respect to research needs, assessment and future risk management.
In summary, with this particular case we see a combination of how many provisions within CEPA can work together. Much of this emerged from basic research that is provided for in the act. The strong links between the science research community and the risk assessment and management community are extremely important to understanding the way that this particular issue evolved.
The new substances program has had the ability to take the quickest action on newly introduced chemicals, but the issue of those chemicals already in the marketplace remains.Connections between the new chemicals program and the existing substances program are extremely important to reinforce: How those assessments interact and how we can use the information-gathering provisions in the act to address the larger problems, as opposed to only one specific chemical at a time.
I think what we have learned from this is reflected in the chemicals management plan that was announced in December. We are taking steps now on classes of chemicals like this one to level the playing field with the approaches we use with new chemicals and existing chemicals. We are trying to become more expeditious in the way we address an entire class of compounds that exhibit certain hazard potential, and address them in a systematic way as opposed to piecemeal, one particular chemical at a time.
That is our presentation. A lot of background scientific information is attached to the deck that you may have questions about. We also have some scientific posters for the senators that have been released at a variety of symposia, workshops and conferences. They outline the dimensions of the issue as we saw it at the time and the actions we took.
We have three posters that we will circulate. The first one is a Health Canada poster describing the human health risk assessment under the new substances program. The second is the basis for Canada's decisions to prohibit the four fluorotelomers that were prohibited in 2004. The poster also describes the action plan that Canada announced subsequent to that prohibition. Finally, a poster provides an overview of the assessments of PFOS and PFOA and maps of the path forward with respect to the other similar types of chemicals in the class.
The Deputy Chairman: Will you leave the posters with us,Mr. Arseneau?
Mr. Arseneau: Yes.
The Deputy Chairman: Thank you very much. That was informative and is food for thought: where you have been and where you are headed. I am glad you are involved with the international side of it as well. It gives us a little consolation.
Before we begin questions, I want to ask the first one, if senators do not mind.
With respect to the term PFCs, how many chemicals or compounds fit into this category? Are all these substances mostly used commercially now?
Mr. Arseneau: That question points out how large the gaps are in our knowledge right now.
We still find new similar chemicals that tend to be formed in the environment. When you question how many chemicals this class actually represents, the number is in the many dozens, but we do not have a precise number on exactly how many.
In 2005 we completed a comprehensive survey of the use of PFCAs in Canada. We received information back that indicated many similar forms of these chemicals are in use in Canada. However, that is by no means all of them. We have been able to identify several that are not in commerce but were on our domestic substances list that I think we can take good preventive action on quickly.
In terms of the ones in use, the major ones tend to be theeight-chain-length ones, which are the PFOS and the PFOA. Those substances are used as building blocks for a variety of other compounds. They sometimes degrade into alcohols or other forms.
I will turn to Mr. Muir to explain the chemistry and what goes on there because, frankly, he is more knowledgeable about that than me.
Senator Milne: Perhaps Mr. Muir can start off by telling us exactly what the abbreviations PFOS and PFOA stand for.
Derek M. Muir, Chief, Atmospheric Contaminant Impacts, Environment Canada: When chemists use the word ``perfluoral,'' they use that term because they mean the carbon chain, which is from a hydrocarbon back source originally, and is completely fluorinated. Normally, hydrocarbons such as gasoline and octane that you are familiar with have hydrogen on the carbon. In this case, the fluorine entirely replaces the hydrogen. As a result, the molecule is unique. Fluorine is a chemical that, if you replace hydrogen with fluorine, the chemical becomes volatile.
They say that fluorine gives things wings, and the chemical produced is almost undegradable. In the case of PFOS, there is the eight-carbon chain plus a sulfonic acid, a group that is a strong acid. The end of that chain can bond onto the end of the carbon chain. In the 1940s, researchers discovered that this chemical had unique properties because it had both this incredibly stable chain end and this acid end, so the chemical is a bit like a soap or a surfactant, with the ability to stay at the surface. All these unique properties of the chemicals make them valuable.
Senator Milne: PFOS stands for perfluorinated oxygen?
Mr. Muir: PFOS is perfluorooctane sulphonate. PFOA is perfluorooctanoic acid. In the case of PFOA, there is no sulphur involved. If the compound had only hydrogen on it, it would be a natural product, actually a fatty acid, but they replaced all the hydrogen with fluorine to produce a unique chemical that is extremely stable, a little different from PFOS but with essentially similar properties.
The Deputy Chairman: Can you continue with the other question I asked? How many PFCs are used commercially?
Mr. Muir: I do not know the answer to that. As Mr. Arseneau said, I do not think we have that information. I am sure somebody in new substances or existing substances knows exactly, but the problem is that there are polymers, which are actually the substances involved, so there are only a few starting materials. Most of the substances have eight chain lengths; some have nine and ten. Six to ten is the major range. They are the simple compounds that we measure in the environment. Then there is another class, which are alcohols, because to bond the chemicals onto a polymer, they cannot use the acid. They must use an alcohol. This is Chemistry 101.
You have the acid group, and you have the alcohol group, and all with the same chain length, in the six to ten range. Then you have the actual products that are bonded to polymers. Polymers typically, such as polyethylene and so on, have a carbon backbone, and these fluorines must be bonded to it. It was discovered a long time ago that this bonding can be done to create unique products. You see them when you buy windshield washer fluid, for example, with that is called Teflon. It is not Teflon, but a polymer that includes these eight and ten carbon-chain things bonded to a backbone, which gives the product a unique, streak-free effect on windshields.
I am trying to answer your question by saying that there are a series of products, alcohols and acids, and then the polymer part is the confidential-business-information side of it. Companies can add only a few or many of these perfluoro chemicals with slightly different properties. Many companies are involved, so it is difficult to track down exactly how many compounds are involved.
Mr. Arseneau: If I remember the numbers correctly, on our domestic substances list, when we did our surveys, we identified about 185 compounds that were in this class. The OECD recently conducted a large survey of OECD countries to ask about the use of the entire class or compounds and they came out with a number. I think around 215 compounds were surveyed. In the most recent meeting of the chemicals committee, Australia, who was leading on that particular effort, reported that in addition to the 215 that were surveyed, they had recently identified about another 40 or so that should be added. In other words, we did not even have the capacity to test for this class of chemicals less than ten years ago, so we still find more and more of the subtly changed chemicals that are in use or perhaps that have been generated through the degradation of a product. Roughly, we are now looking at that number in this class now.
The Deputy Chairman: I am interested in the firefighting foam you mentioned. As we know, the lifespan of a firefighter is short. When do you think we can do something on that foam?
Mr. Arseneau: I believe the intention is to allow existing stock to be used but to replace it with new foams that do not have the same characteristics. This kind of product will be more of aphase-out as opposed to an action to require them to be removed and immediately replaced.
The Deputy Chairman: Is that rather soon?
Mr. Arseneau: Yes, it will be rather soon.
Senator Spivak: Thank you very much for your most interesting presentation. Will you refresh my memory before I ask my specific question? There is no reverse onus under this act. In other words, there is no obligation on companies to prove that their products are safe before they bring them on the market. Is that correct? What is their obligation?
Mr. Arseneau: The obligation is different in the way that the programs work with respect to new chemicals and existing ones.
Under the new substances program, we require the companies to provide us with data when they intend to bring a new chemical into use. We assess that data and come to a conclusion with respect to it. There is an onus on the companies to provide data that we assess. That data allows us to be more nimble, shall we say, with respect to new chemicals.
With existing chemicals, in essence, because they were already on the market and were grandfathered, generally the government has assumed the responsibility of trying to find the problems. We are shifting that onus now. Our new approach with high-priority substances is to say, ``Here is what we know. We think we have a problem. Prove to us that we do not have a problem if you want to keep using this chemical.''
Senator Spivak: That is not the same thing. For example, take Premarin. It is not a pesticide. Think of all the stuff that is out there where companies either repress this information or never had to prove that it was safe. During the discussions when this act was first put forward, the idea of reverse onus was put forward but not approved. That is fine. I understand what you are doing, but it is still not the reverse onus.
I will ask several questions all at once. How many new chemicals are introduced each year? How much staff do you have to look at them? Are any of these polyfluorinated substances in the bottles that bottled water is held in? How many of those persistent organic pollutants, POPs, have been banned here in Canada?
On page ten, I was surprised to read that PFOS and its precursors are not a danger to human health but they are a problem in the environment. How can they be a problem in the environment with the water we drink and the air we breathe, and cumulatively not a problem for human health? I have a ton of questions, but those will do for now.
Mr. Arseneau: Thank you very much for those questions. We also have a ton of questions like that.
With respect to your earlier question about reverse onus, I remind the committee about section 70 of the act, which requires companies, if they are in possession of information, to bring it forward, and that has happened from time to time.
With respect to new chemicals, we receive notifications on average on about 700 to 900 new substances each year. Within the two programs at Health Canada and Environment Canada we probably have a combined staff of about 75 to 100 that deal with the notification process information and also assessors to review this information. Staff also do their work under strict scheduled time lines. The most time that we have is usually about 90 days to review the information and come to a conclusion with respect to risk, and to impose a particular requirement or condition to mitigate any risks involved.
The program is dynamic and we have had to develop new tools as a result. We make extensive use of predictive models and computational toxicology to understand how a new chemical may behave based on similar chemicals of that class. We combine that information with test information that companies are required to bring forward. We have developed advanced models and tools that help us do this kind of assessment. New chemicals tend to be dealt with this way in most advanced jurisdictions.
With respect to whether these perfluorinated chemicals are in bottled water et cetera, these chemicals are often used inplastics-type applications, but I will turn the question over to Health Canada, which does more of the product safety aspect.
Steve Clarkson, Associate Director General, Safe Environments Programme, Health Canada: Usually the bottled water you buy in stores is packaged in the same plastic that is used for soft drinks, commonly referred to as polyethylene terephthalate, and the plastic recycling symbol with either the letters PET or more appropriately PETE indicating they are not perfluorinated substances at all.
Senator Spivak: What about POPs?
Mr. Muir: They are not on the POPs dirty dozen list — presently 12 chemicals internationally — but they are on a list that is proceeding through assessment to be added and it is proposed by Sweden. The dossiers on this substance are still under review.
Senator Spivak: My question was: How many are banned now; how many years ago did this happen; and how many in Canada are banned?
Mr. Muir: Do you mean PFOS-related chemicals?
Senator Spivak: Persistent organic pollutants.
Mr. Muir: All the chemicals on the POPs list were banned in Canada a long time ago or phased out. Not all are commercial chemicals. Some are like dioxins that are produced by burning and so on.
Senator Spivak: So they are gone?
Mr. Muir: They are listed or gone, yes.
Mr. Clarkson: In essence, there are three categories of POPs. There are those that were manufactured and sold as products. Many chemicals in the dirty dozen are pesticides. Canada has ceased allowing their use by deregistering them. One category includes only dicloro-diphenyl-trichloroethane, DDT. This substance is used in limited areas of the world and is still an effective treatment for malaria. The World Health Organization, WHO, came out with a position on DDT use in September or August of last year.
And then there are the categories of dioxins and furans, which are not intended to be produced but are by-products of processes. These substances are identified and controlled, or requirements exist on those substances to limit their production.
In Canada, we have strict rules regarding production of dioxins and furans. We do not allow DDT and most of the others are pesticides that are not allowed. I think PCBs are on the list and we have been phasing them out. We do not allow PCB manufacturing in Canada any more and new regulations are coming out on PCBs now.
Senator Spivak: I have one last question Madam Chairman. It is not to be answered. I wonder if you could respond in writing. I want to know exactly what further measures and differences are contained in this proposed clean air act that are not in CEPA, and can you respond in writing because I am sure that is a big question.
The Deputy Chairman: If you send a letter to the clerk of the committee, she will distribute the answer.
Senator Angus: Thank you very much, especially youMr. Arseneau and Dr. Muir. I think the information you provided is more than Chemistry 101; it is more like Chemistry 404 plus and therefore I will not attempt to show my ignorance in that area.
First, I think we should be interested in two basic things in the context of our study and that is your statement that, based on all the research and everything that has been done both here and elsewhere, there is no immediate risk or danger to human health. I think that was your evidence. I hope you can confirm I understood that correctly because obviously that is number one. I notice that my good friend from Winnipeg may take issue with that. In any event, it surprised me to hear you say it and I was pleased.
You also indicated a lot of activity that you and your colleagues have undertaken within the context of CEPA, which we are reviewing and which PFOS and PFOA are part of. I gather that CEPA, as drafted, and the framework in which you operate are adequate to enable you to do your work on this subject and therefore you are not recommending amendments or changes to us. That is what came across to me, a guy who actually got as far as Chemistry 101 but no further, then moved to the social sciences. Those two preliminary things are of direct interest to this study. Then, I want to pursue one other avenue.
Mr. Arseneau: Health Canada came to the conclusion, with respect to PFOS, that although there was evidence of PFOS in the human population, it had not yet reached a level or concentration that would have an adverse effect. However, studies have shown adverse effects from PFOS in animals that would obviously be comparable to, or would lead to a conclusion that there could be, adverse impacts over time on humans. The assessment concluded that we had not reached those levels yet and that the actions proposed would prevent us from reaching those particular levels.
I will pass the question to Myriam Hill who, from the new substances point of view, has also identified potential risks to human health from a variety of compounds along these lines.
Myriam Hill, Section Head, New Chemical Substances 1, New Substances Assessment and Control Bureau Product Safety Programme, Health and Consumer Safety Branch, Health Canada: From our new substances perspective, given that we are a preventative and pre-market program, our role is more conservative in a way than the role of the existing substances. Based on the information we had on the hazards of some of these perfluorinated compounds, we felt that it would be prudent not to allow these substances into the market. Too many questions are still to be answered. The mode of action has not been established. The way people are exposed to these substances is a question. The fact that the substances were in consumer products, where everyone would have access to them and would be exposed to them, led us to the conclusion that they should not be allowed in the market.
As Mr. Arseneau explained, we do not have a handle on the mode of action and the routes of exposure. However, our preventative conclusion was that we should not allow these substances into the market. By doing so, we alerted companies that perhaps they should not continue to produce these substances. Now, as a program, we have received notifications of different chemistry, new products that do not have some of those properties. We are following them closely and requiring toxicological testing on these substances to see whether they are preferable to the ones that were carbon-8-and-higher chains.
Mr. Arseneau: Perhaps I can address the second part of that question with respect to CEPA. Is it adequate? We seem to be able to work within the framework of the current act: in broad brush, it seems to work.
This example indicated to us, though, that we need to be much smoother and adapt more quickly to deal with certain types of risks and substances from both a new substance and an existing substance point of view. I think the different provisions and styles of operating within the act will converge somewhat over time. We can do that in the way we operate our program, do our science and perform our job, but it was not done that way in the past.
We are breaking new ground to do that. We do not believe that anything in the act prevents us from doing that.
Senator Angus: We are getting to the heart of my question. If our chairman, Senator Banks, were here, he might use this phrase: Do you have a wish list of things to make it easier for you to do your job? That is where we can be of help to you in our report.
Mr. Arseneau: The department and the minister would probably release a proposed wish list. I believe a review, which has been shared with the committee, has been undertaken also over the past year to address certain areas of the act that could warrant improvement. Those areas were based on not only departmental perceptions, but perceptions from stakeholders as well.
Mr. Clarkson: A paper was done by the departments to identify issues regarding the various stakeholder issues, such as should the Minister of Health have more authority to gather information; and should there be a clearer statement regarding the collecting of information on body burdens and information on surveillance for human exposure to chemicals. I believe that was probably presented to this committee when Assistant Deputy Minister Cécile Cléroux and the others were here at the start of their hearings some time ago.
Senator Angus: The paper dealt with the issue in a more general sense. I was trying to focus on PFCs specifically. It there is nothing specific you want to mention, that is fine.
You made reference to the 3M Company voluntarily agreeing to do some things that you described, which highlighted that — regarding the PFCs — we are dealing with the manmade chemicals that are the problem. We are talking about substances that are made by man for commercial reasons. I cannot believe that the 3M Company is the only one in the game.
I know 3M Company is a massive U.S. public company in the chemical business, but what about Dow Chemical and all these other companies? We could go on and on, as Senator Spivak knows. What is the big deal about 3M? The company has obviously volunteered to give some of their competitors a leg up perhaps. I am sure their motives were much more honourable than that, but you see where I am going here. You are not suggesting that 3M is the only company that makes these potentially dangerous chemicals, are you?
Mr. Arseneau: No, 3M was the major producer of PFOS at the time. Other manufacturers were making other things such as PFOA. Worldwide, a handful of large companies are the major producers of perfluorinated compounds. Those companies were the ones that the challenges of both the USEPA and Canada were addressed to with respect to modifying the chemistry, doing more research and cleaning up product — transiting especially out of the long-chain components of this kind of chemistry.
The 3M Company took a proactive stance at the time, and worked well with governments to move itself out of the PFOS business. Other companies are doing a good job of coming up with alternative chemistry and the new substances notifications are coming to us. However, the market is big and commercially important, and the response has been uneven. Some companies have been more proactive than others, and some have been more reactive and defensive.
Senator Angus: I understand PFOS is used for various industrial businesses. These products are developed for use in the building trades and so forth. Again, listening to your evidence, it seemed to me that one could walk into any Home Depot or big hardware store and buy cans of these substances. For your average layperson, who would know that there is a sleeping danger right there on the shelves? Coming down to the human contact level, are you there and are there big signs saying ``hazardous materials,'' et cetera?
Mr. Arseneau: We try to do it through a variety of approaches. Obviously, labelling hazardous materials and giving good direction on how they should be used and disposed of safely is an important part.
Another important part is what we try to do with respect to some of these classes of chemicals, and that is to stop them from being introduced into the product in the first place. We work at it in both ways.
Some kinds of materials and products are hazardous by their very nature because that is what they do. We try to give preference over time to the less hazardous products and take a preventive approach for some of the particularly harmful, persistent or bioaccumulative ones and restrict their introduction into the products. That effort must be international as well as domestic.
Senator Angus: I can see that the challenge is massive because we have gotten so far along in this.
Senator Milne: Thank you for this information. It has been fascinating, if disturbing. On page 10 of your presentation, you conclude that under section 64 of CEPA, PFOS and its precursors does not constitute a danger to human life or health; and that it meets the criterion set out in section 64(a) but may have an immediate or long-term harmful effect on the environment or its biological diversity. Some of these substances are bioaccumulative in animals, which are part of the environment, and we eat animals. We do not really know. When I hear of a substance that is bioaccumulative, my immediate reaction is that the substance should be banned. I find it disturbing when you say that the POP list has not increased because it is obvious that some of theselong-chain polymers are persistent, and we do not know what they will doing to us or our grandchildren.
Have any studies been done about the accumulation of any of these substances in humans in the North of Canada or humans in the South of Canada? Are the accumulations different in those areas?
Mr. Arseneau: You are right that we need to take a strong view on chemicals that are persistent, bioaccumulative and inherently toxic, which are the ones that we have identified as highest priority. The Chemicals Management Plan that we are implementing currently has identified several hundred highly bioaccumulative and highly persistent chemicals that we will take action on quickly over the next couple of years.
Senator Milne: Are these the proposed regulations that you are developing?
Mr. Arseneau: Yes, absolutely. They are the subject of our highly focused concern. This class of chemicals bioaccumulates in a different way than what we had seen before. Going back to the question from Senator Angus about changes in the act, CEPA requires us to take action with respect to bioaccumulation, which is defined in the regulations. This matter is not a legislative one as we can shift it in the regulations. We have found that this particular class of chemicals bioaccumulates but not in the same way that PCBs bioaccumulate. For that reason, we were taken off guard a bit with our regulatory approach and so we are in the process of preparing an adaptation to that approach.
The POPs list is an internationally negotiated and agreed to list of substances. The Stockholm Convention on Persistent Organic Pollutants came into force only a short while ago, and it started with that list of 12 substances. However, an active science panel is reviewing proposals for five new additions to that list, including PFOS. Canada is strongly represented on that panel and has provided information, oversight and decision-making. We are actively engaged but the process is longer.
With respect to the levels of these materials showing up in wildlife and in humans and the comparisons between North and South, I ask Mr. Muir to respond.
Mr. Muir: The information in this regard is interesting. My colleagues at Health Canada have found that the amounts in people's blood are the same in the North and the South. Perhaps that news is good and the levels are relatively low, being in parts per billion. This finding was a surprise because of the traditional consumption of wildlife in the Arctic that has led to much higher levels of PCBs in people in the North. However, it is not the case for perfluorinates. The tentative conclusion is that the exposure is not through the consumption of traditional foods. The speculation is that the levels are the same because everyone is exposed at a similar rate through consumer products in the home, such as popcorn bags, for example. Such items create a low-level exposure for everyone.
Wildlife in the Arctic have much higher levels than people — up to 1,000 times higher. Wildlife have a different rate of exposure, and polar bears have some of the highest levels in the world of any animal because of the unique way in which these chemicals bioaccumulate. The chemicals are sticky and stay in the livers of polar bears where high concentrations develop.
Senator Milne: I am off liver.
Mr. Muir: People do not eat polar bear liver because it is not good for them.
Senator Milne: These proposed regulations are being developed.
Mr. Arseneau: Yes.
Senator Milne: What is the timeframe?
Mr. Arseneau: The proposed regulations for PFOS were released last summer. The regulations will be concluded within two years of that release, which is the mandate under CEPA. We are trying to conclude in advance of that. I expect that within the next calendar year, we will finalize regulations with respect to PFOS.
Senator Milne: That is good. What about firefighting foams that will be phased out over an extended period of time?
Mr. Arseneau: The extended period for the phase-out means that as the foams are used up, they are replaced with material that does not contain PFOS.
Senator Milne: Are such materials available?
Mr. Arseneau: Yes: In essence, most of the chemistry is going to shorter chains, as opposed to eight-carbon long chains, because they are not as bioaccumulative.
Senator Milne: Dr. Hill, 90 days seems to be an arbitrary length of time for studying and releasing your results. Where did this timeframe come from?
Ms. Hill: It is mandated under CEPA.
Senator Milne: Do you think that is enough time?
Ms. Hill: It does present a challenge at times.
Mr. Arseneau: It allows us to be more protective in a way. The tendency among the assessors and the management in the New Chemical Substances program is to use the tools available under CEPA to head off potential problems.
Senator Milne: You err on the side of caution.
Mr. Arseneau: Yes, it is precautionary.
Senator Milne: Should this committee recommend anything about CEPA that would help you to do your job more easily, other than providing more people?
Mr. Arseneau: I have talked about generating a smoother flow between new chemicals and existing chemicals. One challenge we face in making that transition or convergence of approaches is often the fact that confidentiality of information on a newly notified chemical frequently hampers us in our efforts to get the science out quickly. We go through a long process of cleaning confidential business information out of some of the science reports. More clarity around that issue would help. It involves the administrative rules more than anything else but such clarity would allow us to get the science out more rapidly and effectively that can have a greater influence on the existing substances.
Senator Milne: I have one question about my Teflon frying pan. When considering a compound such as Teflon, whether used as directed, should anything be done about informing the public? Has it been suggested that the producer or the seller of the product inform the public about the proper use and eventual disposal of these products? Disposal is a big question as well.
Mr. Clarkson: My wife recently purchased a small frying pan, and she chose a non-stick pan. Because of my interests, I looked at the product, and there were directions on how to use it. There was no mention of a concern with PFOA, which is used as a processing aid to make that product in many places. There were directions on how to use it and cautions about being careful not to overheat the pan, but nothing about waste disposal.
I must turn to my colleagues in Environment Canada to know whether we have a concern about perfluorinated substances in consumer products in terms of disposal.
Mr. Arseneau: In large measure, we have not addressed disposal so much with respect to pans, but we have looked at the way the materials have been used in other bulk items such as carpets, furniture, et cetera, where much more of this chemical goes than into the pans.
Other things such as paper plates and other kinds of paper products often have these chemicals on them as well because they stop grease or water from penetrating. These kinds of uses can enter waste streams and give us a bit more pause to reflect on than pots and pans.
Mr. Clarkson: If I may add to that comment, as Mr. Arseneau pointed out earlier, this particular type of substance is relatively international in nature. No one makes PFOA in Canada, but they may import it or have imported it in the past for use in making perhaps a non-stick coating or something of that nature.
Because of its international nature, we are dependent on what happens elsewhere. In the United States, the US EPA engaged in a program with DuPont and five or six other manufacturers of PFOA in terms of implementing new processes and seeking alternatives. Part of the new processes were to minimize residuals of PFOA in the products being manufactured as a way of cutting down on potential exposures to the environment and to people through the environment.
In the case of PFOS after 3M made its announcement, there was a lot of migration away from the product almost immediately. Efforts are ongoing, as Mr. Arseneau has stated, to encourage industry: Look for other things, because we are concerned about this. We are looking and will continue to look. If they move to alternatives sooner, that is better.
We are being precautionary to an extent. We do not have solid evidence or a reason to be absolutely concerned regarding human health. You mentioned earlier that slide 10 states we did an assessment on PFOS, which was relatively thorough. The margins of exposure that were found using blood concentrations suggested that we are nowhere near the levels required to cause the effects that have been observed in animal studies.
I want to underline that my colleagues in Environment Canada are concerned about every species of animal up the chain. I am only concerned about humans. Environment Canada must protect a much wider variety of species out there than I do, but I assure you that we make every effort to protect us.
Senator Milne: Maybe I am monopolizing our time, but how does this chemical bioaccumulate? It must get into these animals somehow. Is it from eating grass? Is it coming from vegetative-eating animals up the food chain? We as humans consume meat.
Mr. Muir: That is right. The roots are the same as you have heard about for other chemicals, and we have already banned chemicals such as PCBs.
The reason for it, ultimately, is because these chemicals are not metabolized. They are stable. What goes in sort of stays in and is slowly released but not as fast as they might be consumed. They are going in through the diet, mostly.
There are special characteristics to these chemicals in which mammals handle them differently. The chemicals tend to recycle in the animal. You may have heard of PCBs residing in fat. They are not in our fat but more in our blood and liver. They tend to recycle because they are not released. They are mimicking things like bile acids, which are part of our normal digestive process, and going back into the animal. They are tending to stick.
If a polar bear consumes a seal, there are two levels in the food chain there of mammals that have both accumulated a lot of it. Humans, on the other hand, tend to eat a more diverse diet. We do not consume much animal meat that is high on the food chain. Yes, we consume meat, but from a grazing animal, not from fish or the like. We tend to be lower on the food chain than a polar bear or a seal most of the time.
Senator Spivak: I have a supplemental question. Since this is our chance to help you, through amendments, would it be helpful to you if manufacturers took on more responsibility for proving their products are safe? I would go for reverse onus, but I am not sure it will fly. Surely, that is the route to go when you have 700 substances and 70 people to assess them in 90 days.
One more thing: Have any of you read Cradle to Cradle by William McDonough? I rest my case.
Mr. Arseneau: It is a good point that we are in the midst of a legislative review, and I am sure proposals will emerge from the government on the kinds of amendments that would make our job more effective.
However, in a sense, we have moved our overall chemical work beyond just CEPA. We have introduced a Chemicals Management Plan that tries to link what we do in CEPA with what we do in pesticides and the Hazardous Products Act. The plan tries to link with a variety of pieces of legislation that, when brought together, create a much more comprehensive and powerful approach with respect to chemicals management. We may not necessarily have to do it all within CEPA if we use these other tools as well.
In terms of the responsibilities of the manufacturers of these chemicals for their safe use, in essence, we have started to pose that challenge. We are going out now with profiles of what we know about chemicals that are of concern to us and that came through our categorization process.
We are at a new stage because of the work we did in categorization. That work equips us with information now to pose exactly that question or challenge. We are preparing the science and putting it out there and saying, ``Show us how you can use this chemical in a safe way, because if you cannot, we have to take action.''
Senator Spivak: I want to emphasize that it is not only the government who can make amendments.
Senator Peterson: Most of the issues have been dealt with. I ask you, though, if you have a sense of how industry is doing in finding alternative substances to make these products that are used every day. I am not sure about the size and the level. Have the substances been banned, or are you waiting? Do you have a collaborative approach with industry, or is the relationship difficult? It seems that you need to work together to work in everyone's best interest.
Mr. Arseneau: Results have been mixed, let us say. This area of concern is newly but rapidly emerging. It has provoked a flurry of new research and inquiry. Only in the last few years, since we imposed the prohibition on four new fluorotelomer chemicals back in 2004, has industry started to pay attention to some aspects of this issue. We see encouraging signs now where some companies come forward and inform us of new products that they want to bring onto the market that have changed the chemistry and use a shorter chain-length. We see notifications of a changed chemistry, but that change takes a bit of time. Companies have actually responded unevenly, and I will leave it at that.
Senator Peterson: As you approach a ban on a substance, do you advise industry that the ban is coming down the pike? If so, how much advance notice is provided?
Mr. Arseneau: Absolutely: Under the New Substances Program, we provide the notifier with our conclusions as soon as we reach them. There is quite a bit of exchange with respect to scientific information, possible management approaches and all those kinds of things.
Following on the government actions in 2004, we go to international meetings, to conferences, to a wide variety of venues, including meetings with individual companies, to outline our concerns to induce them to do more research on the type of products that they put on the market, and also to try to develop greener chemistry around some of these particular classes of products.
Yes, we give early information or notice to the notifiers. We work hard to get the science out to the more general public as soon as possible and to continue pressing for improvements in the way that this particular chemistry is used. The process is long and slow.
Senator Sibbeston: I am interested in the effects of pollutants on the North. We think we live in a pristine area, but invariably there is pollution in the North. I am always interested to know the extent of pollution there. In this case, there seems to be some contamination from the polyfluorinated substances. Do you have scientists that go up north and check polar bears and people every summer? While you are talking about the rise in this chemical in polar bears, do you also test caribou? There are probably more caribou and these animals are more widely eaten throughout the North.
Mr. Muir: First, I do not go after the polar bear. It is an interesting topic, though I will not go too far into it. A collection program of samples is associated with the hunting of bears, because each community receives a quota, and that program has enabled wildlife scientists with both the Nunavut Renewable Resources department and also the Canadian Wildlife Service and Environment Canada to obtain samples over the years. Not only are samples collected annually, more or less, but a tissue bank here in Ottawa has tissues going back to the late 1960s. Some key scientists, such as Ian Stirling, started work in the 1970s and put the samples in the tissue bank, which allows us to do what we did in that graph. In general, Environment Canada, and also Fisheries and Oceans Canada to some extent with whales, have a program to look at contaminants in the North. It is coordinated by the Northern Contaminants Program run by Indian and Northern Affairs Canada. The program is ongoing. Environment Canada's main role as scientists is measuring things and collecting air samples, so I am looking at that side of it.
We have done less work on the caribou, but recently Health Canada scientists looked at caribou amongst other foods that people were eating in the communities. They took food off the dinner plate. They found low levels of these fluorinated chemicals in the caribou. They were very low. However, when they calculated exposure, people eat a lot of caribou, so it turned out that caribou was the main route in the food. I am not implying the exposure is huge at all because, as I said before, we think the exposure route is from indoor consumer products or something like that, not from caribou. That was the actual conclusion of the study. It is not a peer reviewed study, but it is a study that was reported only last fall. We are concluding that, yes, if you look at the wildlife, the caribou have low levels, but if you multiply the low levels times consumption, people are getting the perfluoros in their diet through caribou.
Senator Sibbeston: On page two, you talk about the polyfluorinated substances used in industrial, commercial and consumer applications. These substances are found in rugs. I could not help but think that rugs are in every house in the whole country. When a new rug is put down, there is a stench or smell. Is that the contamination? Is that where the substances are used, either to make the rug more stain resistant, more durable and so forth? Through rugs, the chemicals are brought into every home throughout our country. Is that the stuff we smell from a new rug, and through time, it becomes less? You do not smell the rug in this room but, in a new house, you would have the smell and stench of rug.
Mr. Muir: I can try to answer that. I do not think we know all the components of that odour, but I would say it is not the fluorinated chemical that you smell, because other glues and so on are found in the rug as well which come off as soon as the rug is unrolled and sitting there. There is a certain off-gassing of things from rugs. That is the process by which some of these fluorinated residuals, as we call them, in the carpet, in the coating to make it stain resistant, come off as gases. I do not think you can smell them, because they are probably odourless. The process is the same, though, where a certain small percentage comes out, less than one per cent probably, of that coating making it stain resistant.
Senator Sibbeston: You say it appears in the blood and liver. What is the worst effect that one can have from the substance? Do you know?
Ms. Hill: We do not know the relevance in humans of the results of studies on experimental animals.
If you ask me what effects have been seen in experimental animals I can answer that question. Recent studies show some developmental effects and some systemic effects, but we do not know the mode of action. One of these substances was categorized in the United States as a possible human carcinogen. However it is still being debated.
Some effects deal with metabolism and transport of lipids and that may have some relevance to humans. We have seen some effects in worker studies that have lowered cholesterol as opposed to what is seen in some animals. The mode of action of these chemicals is not well categorized so we cannot tell you what the relevance is.
Senator Adams: My question concerns polar bear livers. Some Inuit up North in Nunavut still eat polar bear meat. It is typical to cook it; the meat is not like any other mammal. There are many layers between the meat. We usually change the water three or four times because there is so much fat.
We mostly eat caribou, but we are more concerned about the age of the polar bear. Do you think the liver in a polar bear is more toxic the older it gets? I think people in Nunavut need to know more about the polar bear. Years ago we would never touch the liver in a polar bear. Then, we discovered that the dogs, which usually ate the stomachs and livers, were very strong.
We do not eat the livers. We eat the liver of seals, but we never eat caribou liver either. Now more people are changing.People can buy liver in the store and they find that caribou liver is better than beef liver. My question is about the polar bear studies. I think you are monitoring a big area in Nunavut and most of the studies I have seen are about polar bears and their ages, especially around Churchill, Manitoba. The monitoring was there in 1960s. Polar bears usually only eat seals, but they will eat whales too that have been dead for two or three months. Is the polar bear liver more affected than other mammals?
Mr. Muir: Of course we are aware that people do not eat polar bear liver, but then it makes it easy for us to get samples. A lot of people do not like to give up their seal liver we discovered. We included a map where we show the amounts of the chemical in the livers of polar bears, because you asked if the amount was the same across Nunavut. It is not. We tend to see higher amounts in polar bears in Hudson Bay. We think that is because the chemical is delivered to a remote place like Hudson Bay through the atmosphere. We think the chemical mostly goes into the atmosphere and then into the food chain through melting snow and ice and into the seals. The polar bears in Hudson Bay are closer to urban society and the South, which delivers chemicals, so we think that is the reason why we see higher amounts there: plus, the circulation of the bay is a bit different from the larger Ocean.
I do not think we have analyzed polar bear muscle — I am looking around the room to see if anyone is nodding from Health Canada — but it could be done easily. The focus has been on the main foods that people eat. Caribou, char and seal meat are at the top of the list. Polar bear is further down so I do not think it has been looked at yet. We should look at it because it will have higher amounts than some other animals; we are sure of that.
Senator Adams: You did not mention if the age of a polar bear makes a difference.
Mr. Muir: There is a small age effect. In other words, the older animals have higher amounts than the younger animals, but the effect is not huge; it may be two-fold or something. The older animals have been eating longer and this stuff is retained in the body so levels tend to be higher. We do not see a sharp effect as we do for mercury. We do not see that with PFOS.
Senator Adams: Has there been any chance to test for chemicals if the meat is not cooked? In the old days we did not always have a stove and used to eat some of the meat raw because there was no way to cook it. We ate frozen char, seal meat and caribou. Is there a difference between cooking it and eating it raw?
Mr. Muir: That is a good question and I do not have an answer, but I can look it up afterwards to see if anyone has looked at the difference in these fluorinated chemicals between cooked and uncooked meat. I do not think that question has been answered for perfluorinated chemicals, but other chemicals, such as PCBs, are lower in the cooked food because of cooking out some of the fat. However, some people like to eat the broth so they eat less meat, but the broth is where the chemical goes. It is tricky to assess whether people receive lower amounts through cooked foods when we think of how foods can be traditionally cooked.
The Deputy Chairman: Does Canada have a sufficiently rigorous bio-monitoring program to determine what PFC levels are in the blood of Canadians? Maybe we should add PFC to CEPA.
Mr. Clarkson: Nothing specifically mentions bio-monitoring or surveillance of humans in CEPA. However, in section 55 or another section, there is the ability for the minister to collect information on the impacts of chemicals and other substances on humans, which, if interpreted broadly, can refer to monitoring or surveillance. We have an arrangement with Statistics Canada to begin a pilot later in February to test the procedures for a Canadian Human Measures Survey. This survey will cover a number of analytes in blood and urine, and measure other physical characteristics. Included in the analytes will be PFOS and PFOA, along with some metals and other organic chemicals.
That survey starts this year through the Chemicals Management Plan that the government announced. We anticipate that we will be able to make the survey a regular event — perhaps not annually, but every three or four years. I do not know the actual time but that plan is within the department.
The Deputy Chairman: How about testing children?
Mr. Clarkson: The age group for the Canadian human measures survey is from the ages of six to 75, I believe. We have also initiated an effort to obtain data on children less than six. There are ethical issues on how to design experiments and so on, but we realize the information in that area can be important and we are making efforts to obtain data in that area. Ms. Hill, do you have anything to add?
Ms. Hill: We are starting collaboration research with some universities. We will look at pregnant women and the effects of the levels of perfluorinated substances in their blood, and then, when the babies are born, in their cord blood. Together with that, we will look at the levels in the house. We have an exhaustive questionnaire where we ask about people's habits — what they have in their houses — carpets, textiles, et cetera — and what kind of houses they have. We will measure the perfluorinated substances in the air, in the dust and in the lint of the dryers to see if we can tease out the exposure pathways for humans.
Senator Adams: We will translate these things for Nunavut. Some of the names of these chemicals will be difficult to translate into the Inuit language. Is there some way to make them easier to understand, perhaps give more pictures or visual images to make it easier to translate?
Mr. Arseneau: That is a good point because, frankly, I cannot pronounce half the chemical names myself; it is pretty tough.
Mr. Muir: Maybe I can answer that because we face this challenge every year working with our Northern Health program. When we obtain samples, we first consult with the communities and translating is a real issue. The only word we have come up with that makes a lot of sense to people is to use the word ``contaminant.'' Sometimes we talk about the stain repellents or something like that, as well. It is difficult to communicate about a lot of these chemical issues, and particularly this one.
The Deputy Chairman: It is difficult for us as well. I have one more request, Mr. Arseneau. Our staff has prepared several questions and a lot of them are important. If I give you the questions, can you respond to them?
Mr. Arseneau: Certainly.
The Deputy Chairman: Okay, I will give them to you and you can send the answers to our clerk, please.
We appreciate your coming. You have been informative and I think you have eased a lot of our minds because we know things are being done.
The committee adjourned.