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