A/HRC/45/12/Add.3
Para 25, 3rd sentence, comments:
It should be noted that Canada’s Chemistry industry has committed to responsible, ethical,
safe and sustainable manufacturing for the past 30 years under the Responsible Care
initiative, which is U.N.-recognized. Canadian chemistry companies adhere to the
Responsible Care Ethic and Principles for Sustainability and the Responsible Care Codes,
which cover all business elements and the lifecycle of produced products. Companies are
evaluated every three years to ensure compliance.
Para 26, 3rd sentence, comments:
This sentence should read: “For example, concerning the oil sands industry, between 2010
and 2014, some substances were present in the air in concentrations exceeding health
thresholds, elevating the likelihood of adverse health impacts”. As per p.15 of the report
being quoted “An odour complaint does not represent a noncompliance because odours are
not a specific regulatory requirement within EPEA approvals”. When thresholds are
compared in the report, it is to thresholds from other jurisdictions as a comparison.
Para 29, last sentence, comments:
The study referenced was for metal mines only, and did not address oil sands mining, which
have different regulatory criteria (oil sands mines are not allowed to release effluent, whereas
metal mines are allowed within limits). By not including the word “metal”, it implies that
these results apply to oil sands mining since reference was made to the massive tailings ponds
in Alberta.
Para 39, 3rd sentence, comments:
Initial 2009 study on Fort Chipewyan Cancer rates:
https://www.albertahealthservices.ca/assets/news/rls/ne-rls-2009-02-06-fort-chipewyanstudy.pdf. Cancer incidence in a 2014 Fort Chipewyan follow-up report found that the total
number of cancers and most types of cancers in the Fort Chipewyan area were the same as
rates in the rest of Alberta. As indicated, different cancers can be result of a variety of risk
factors. No childhood cancer cases were diagnosed in Fort Chipewyan between 1992 and
2011. The absence of childhood cancer rates is reassuring, as children are more vulnerable
than adults to carcinogens and environmental exposures.
https://www.albertahealthservices.ca/assets/healthinfo/poph/hi-poph-surv-cancer-overviewfort-chip-2014-03-24.pdf
https://www.albertahealthservices.ca/assets/healthinfo/poph/hi-poph-surv-cancer-appendixi-fort-chip-2014-02-07.pdf
Para 39, 4th sentence, comments:
This statement is not substantiated, as it is not evident there is a link between TMX and health
risks. If the concern is oil sands growth, without pipelines, such as TMX, crude oil would
still be shipped via other means such as rail. It is recommended that the sentence be deleted.
While opposed by some Indigenous groups, TMX is supported by the majority of the groups
along the right of way, including 56 groups with signed impact benefit agreements. Potential
health risks from the project have been thoroughly analyzed through the review process by
expert administrative agencies. Mitigation measures are in place for potential risks of air land
and water and multi-billion-dollar plans are in place for baseline studies, species recovery,
studying and mitigating cumulative impacts and Indigenous capacity building.
Para 45, first sentence, comments:
The Trans Mountain Expansion project was subject to a five-year review process and a
lengthy consultation and accommodation process with Indigenous groups. The majority of
groups along the right of way supports the project.
14
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