Canada’s Environtmental Health Initiative: New substances only?

It’s a widely acknowledged fact that many substances found in products humans use every day enter the environment in varying quantities, potentially causing harm. In light of this, and in response to the 1999 Canadian Environmental Protection Act, Health Canada created the Environmental Impact Initiative in 2001. This initiative endeavored to develop regulations guiding the environmental assessment of all new substances subject to the Food and Drugs Act (HC 2011). Health Canada has spent significant resources to ensure public participation and a legitimate process to create these regulations. However, there have been too many cases of in-commerce substances causing significant harm to the environment before being acknowledged as dangerous by Health Canada, which needs to be addressed. And the best junction at which to do so is in the context of the Environmental Impact Initiative.

Two prime examples of in-commerce substances causing harm are bisphenol A (BPA) and triclosan. BPA is a petroleum by-product most often found in plastic water bottles that has been shown to simulate the female reproductive hormone, estrogen, causing serious damage to living organisms (Toppari and Skakkeb’lk 1998). BPA was declared toxic by Health Canada in 2010 (HC 2011), but only after a lengthy battle and mounting evidence of its toxicity to both humans and wildlife (Buka et al. 2009).

Triscolan is an antibiotic chemical used in numerous products around the house, from mouthwash to kitchen disinfectant. It is currently under investigation by Health Canada due to its high level of toxicity, its potential for bioaccumulation, as well as the relatively long period of time that the compound persists in the environment (Chalew & Halden 2009). Neither material would be considered a ‘new substance’ under the Food and Drugs Act, since they have been in use in Canada for many years. Therefore, their environmental impact would not be investigated under the proposed regulations, which in my estimation is a mistake.

Products containing triclosan (Elliott 2011)

I propose broadening the scope of the Environmental Impact Initiative to include not only new substances, but also those already in-commerce. By systematically assessing the environmental impact of all substances currently in-commerce in the country, Health Canada could make Canada a world leader in banning substances harmful to the environment. Some might argue that such measures are too extreme and would be inefficient, but I disagree. The many substances that don’t cause harm to the environment could be eliminated quickly in the screening phase of the assessment, avoiding the inefficiency of examining every substance exhaustively. The time to make amendments to this initiative is now, since it has not been made into law yet. Although assessing not only new substances but also in-commerce substances for their environmental impact seems time-consuming and costly, this is the best option for Canada to avoid preventable future impacts due to toxic substances and also to become a world leader in environmental awareness and protection.


Buka, I., Osornio-Vargas, A. & Walker, R. (2009). Canada declares bisphenol A a ‘dangerous substance’: Questioning the safety of plastics. Paediatrics & Child Health, 14 (1), 11-13.

Chalew, T.E.A. & Halden, R. (2009). Environmental exposure of aquatic and terrestrial biota to triclosan and triclocarban. Journal of the American Water Resources Association, 45 (1), 4-13.

Health Canada (HC). (2011). Environmental Impact Initiative. Retrieved January 19, 2012 from

Toppari, J. & Skakkeb’lk, N.E. (1998). Sexual differentiation and environmental endocrine disrupters. Ballière’s Clinical Endocrinology and Metabolism, 12 (1), 143-156.


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