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Notice of Objection to the Proposed Order to add respirable particulate matter less than or equal to 10 microns (PM10) to Schedule 1 of the Canadian Environmental Protection Act, 1999 (CEPA, 1999)

Minister's Response to Concerns Raised by Canadian Trucking Alliance

April 09, 2001

Mr. David H. Bradley
Chief Executive Officer
Canadian Trucking Alliance
130 Stater Street, Suite 1025
Ottawa, ON
K1P 6E2

Dear Mr. Bradley:

This is in response to your letters of July 12, 2000 addressed to Roy Brooke and August 8, 2000 to Danie Dube and Arthur Sheffield concerning the proposed Order to add respirable particulate matter less than or equal to 10 microns (PM 10) to the List of Toxic Substances in Schedule I of the Canadian Environmental Protection Act, 1999 (CEPA, 1999). Although it is unclear to me whether your letters constitute a formal request for the establishment of a Board of Review under subsection 332 of the Act, I have treated them as if they were.

I have fully and carefully considered your submissions. Although there are uncertainties in the database, the weight of the evidence supports the association of PM 10 with adverse human health effects, including mortality, and continues to support the declaration of PM 10 as toxic under CEPA. The Canadian Trucking Alliance has not raised any points which change our understanding of the nature and extent of the danger posed by particulate matter which would thus warrant the establishment of a Board of Review. Therefore. I will not establish a Board of Review.

In Health Effects Institute's 1999 Diesel Emissions and Lung Cancer: Epidemiology and Ouantitative Risk Assessment, A Special Report of the Institure's Diesel Epidemiology Expert Panel, the expert panel did not argue whether or not diesel exhaust is carcinogenic. The Executive Summary of the report clearly states that "state, national, and international agencies have all reviewed the broader animal and human evidence for carcinogenicity and, in either their draft or final reports, have all identified diesel exhaust as a probable human carcinogen or placed it in a comparable category." Several researchers, have overcome the limited exposure data in epidemiology studies, by showing a good correlation between data from personal exposure and fixed ambient monitors (FAMs), and an association between particle concentration obtained from FAMs and mortality was measured in one city.

You should note that once a substance is added to the List of Toxic Substances in Schedule 1, preventive or control actions in relation to the substance are not limited to regulations. The addition of PM 10 to the List of Toxic Substances does not, in itself, control the substance in any way. With respect to PM 10, I will consider a broad range of possible control measures.

I appreciate your bringing the Canadian Trucking Alliance's concerns to my attention. I look forward to working with you in the future on matters of environmental interest to the Alliance.

Yours sincerely,
David Anderson, P.C., M.P.

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