The Honourable Anne McLellan

Minister of Health

Ottawa, Ontario

October 27, 2003

Dear Mme Minister,

I am writing to update you on the findings of the Scientific Advisory Committee to the Peoples’ Health Commission. As you know, Sierra Club of Canada, the International Institute of Concern for Public Health, the Canadian Association of Physicians for the Environment, and the Canadian Auto Workers – Social Justice Fund are co-sponsors of the Peoples’ Health Commission. The mandate of the Peoples’ Health Commission (PHC) is to investigate the poor state of health in Sydney, Nova Scotia, and at the request of community members, explore linkages between ill health and the toxic contamination of the community. The PHC is advised by a distinguished Scientific Advisory Board, whose members assist as volunteers.

There have been four major PHC projects over the last year.

1) One has been to analyze the results of the door to door public health survey. Over 300 homes in the three neighbourhoods of Ashby, Whitney Pier and the North End completed a detailed health and exposure questionnaire. These results are nearing completion under the direction of Prof. Paul Shreenan of St. Mary’s University.

2) Another has been to test for levels of arsenic and lead in household dust in the three neighbourhoods also sampled in the door to door survey. This work was led by chair of the Scientific Advisory Committee, Dr. Tim Lambert of the University of Calgary. This work has been accepted for publication in the peer-reviewed journal, Environmental Health Perspectives.

3) Dr. Lambert conducted a survey assessing “local knowledge” of the contamination caused by the industrial activity over the century. We are currently writing the manuscript that clearly indicates all three communities experienced the pollution from the steel plant and coke ovens. For example, the women from all three communities reported that laundry hanging on the line was frequently stained by the pollution and that windows facing the site have an oil sheen that will not wash off.

4) The third area of concentration has been to continue to assess the validity of the conclusions of the Health Risk Assessment on which Health Canada and the provincial government has relied to deny connections between ill health and levels of contamination. Members of the PHC Scientific Advisory Board, Dr. Barry Thomas and Roger Dixon, with science advisor to Sierra Club of Canada Daniel Green, met with representatives of Health Canada and the consultants who prepared the report in April, 2003. This meeting was made possible through the efforts of you and your staff. Unfortunately, the participation of provincial health staff, which you had anticipated in your letter to us confirming the meeting, did not materialize.

Subsequent to that meeting, new data was made available to the PHC by Health Canada. The “far afield” soil sampling data was provided in hard copy and SCC staff had to enter it by hand into an electronic format. It is still being analyzed by members of the Scientific Advisory Board. Members of the Scientific Advisory Board are preparing a more detailed critique of the Health Risk Assessment.

In the meantime, there are a number of important conclusions about the Health Risk Assessment that emerged in the April meeting, and through subsequent examination of the HRA, new data and the PHC study on the lead and arsenic household dust contamination.

1. The HRA was flawed by utilizing another contaminated community, North Sydney, as its “control” for comparisons. A community where contamination did not exceed CCME guidelines would have been more appropriate. The HRA mistakenly assumed that arsenic was a natural or “background” contaminant in Sydney. The “far afield” soil sampling data provided by Health Canada, as well as our own soil sampling, clearly show that this is not the case. Even if it were, people are at risk from high levels of arsenic, whether natural or anthropogenic. In the soil studies conducted for the PHC by Dr. Lambert, 80% of the background samples were below CCME health risk based guidelines for arsenic. In the communities adjacent to the tar ponds and coke ovens, only 20% of the soil samples were below CCME guidelines for arsenic.

2. The HRA was flawed by choosing an acceptable level for arsenic exposure, which validates a 7-fold increased risk of cancer for this one contaminant alone for people in Sydney.

3. The HRA was flawed in the manner it modeled for contaminants in household dust. The assessment assumed a concentration of contaminants in household dust rather than loading of contaminants. The household dust study conducted by Dr.Lambert for the PHC confirms that arsenic and lead are entering the homes from the outside and predicted the loading of polycyclic aromatic hydrocarbons (PAHs) from correlations of lead and PAH contaminants in residential soils.

4. Dr. Lambert’s study found that the levels of lead, arsenic and PAHs are significantly different in the three neighbourhoods adjacent to the tar ponds and coke ovens and the background levels in Sydney, Nova Scotia.

5. Dr. Lambert’s study found that there is no difference between the three neighbourhoods adjacent to the tar ponds and coke ovens with respect to lead, arsenic and PAHs.

6. Dr. Lambert’s study provides a better estimation of the health risk that children face in the communities adjacent to the tar ponds and coke ovens because the key parameters for the risk assessment were actually measured, i.e. soil and household dust. For example, based on the soil and household dust, a child would have a 1-15% chance of having a blood lead level greater than 10 ug/dL, the current level at which medical intervention is recommended. However, there have been several recent studies showing that children are adversely impacted at blood lead levels as low as 5 ug/dL and that this guideline should be revised.

We believe these conclusions confirm serious flaws in the HRA. We urge you to give reconsider your decision to accept the conclusions of the flawed HRA as those of you and your department.


Elizabeth May

Executive Director

Sierra Club of Canada

Cc: Dr.Tim Lambert

Dr. Barry Thomas

Roger Dixon

Dr. Paul Shreenan

Mark Eyking, M.P.