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Ecosystem health: an example of implications arising from
regulations under the Canadian Environmental Protection Act
(CEPA), and the importance of setting precedent
Peter G. Sly
Rawson Academy of Aquatic Science, Suite 404 1 Nicholas Street,
Ottawa, Ontario K1N 7B7, Canada |
Abstract
Ecosystem health is a key principle which underlies
the Canadian Environmental Protection Act (CEPA). This act is designed
to protect human health and the environment from harmful and/or
irreversible effects by providing a cradle-to-grave regulation of
toxic substances.
As an example of the application of this act, this contribution
considers the most toxic dioxins and furans which are generally
associated with Kraft pulp mill effluents. These are some of the
first substances to come under the CEPA legislation. The proposed
CEPA regulations for dioxins and furans ate based on 'end-of-pipe'
control, which would effectively limit their concentrations in effluent
to something close to measurable levels. Depending on sample matrix
and methodology, however, measurable levels may differ considerably.
Evidence presented at the Alberta-Pacific (ALPAC) pulp
mill hearings in Alberta and the Northwest Territories during 1989
demonstrated that total loadings are particularly important in dealing
with the far-field effects of these extremely toxic, persistent,
and bioaccumulating substances. Further, it was reported that there
might be no threshold of effect for tetrachlorodibenzo-para-dioxin
(2, 3. 7, 8 TCDD) or the companion furan. If such evidence is correct,
the CEPA regulations should be designed to achieve zero discharge
of these contaminants. Measurable levels, as presently defined in
the CEPA regulations, maybe in excess of zero discharge requirements.
Clearly, such in consistency may cause problems and
should be addressed directly. Unfortunately, the first draft of
the CEPA regulations represents a piecemeal approach. In this, it
is unfair to industry, it is scientifically inadequate, and it may
not be enforceable. The application of CEPA regulations for the
pulp and paper industry will set a new precedent for Canada's approach
to ecosystem health. It is therefore essential to base decisions
on a good understanding of the dynamics and effects of chemicals
in ecosystems and to re-evaluate, carefully, the toxicities of key
contaminants. Interim measures are likely appropriate.
Keywords: ecosystem health, Canadian Environmental Protection
Act, Kraft mill effluent, toxic substances
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