A/HRC/45/12/Add.3
We recommend using “Indigenous Services Canada” as opposed to “Indigenous Affairs
Canada”.
Para 9, 1st sentence, recommended language:
In some respects, discussed below, the flexibility for provinces and territories to set standards
more stringent than the federal requirements has reduced actual and potential exposures to
toxic substances.
Para 9, 2nd sentence, comments:
The report has not yet mentioned federal standards, but talks here about ‘more stringent’
provincial measures. We suggest mentioning CAQQS first: The Canadian Ambient Air
Quality Standards (CAAQS), established under CEPA, drive air quality improvements across
the country and are reviewed on a regular basis for their adequacy to protect the environment
and human health. The CAAQS are underpinned by management levels, which require
progressively more stringent action by provinces and territories as air quality approaches the
level of the ambient standard.
Please note that it is unclear what pollution “caps” refers to here. We recommend adding
some references to clarify if this refers to ambient air quality standards in the province, or
emission limits per facility, or caps on total emissions in a province. As currently worded, it
would seem to imply province-wide caps on total emissions.
Para 10, comments:
Please note that the reference is missing for footnote #6.
The reference to “legally binding or enforceable on reserves” is misleading as there are no
federal standards in Canada for drinking water that are legally binding. We recommend that
this be clarified with the following statement: “For example, provincial drinking water
quality standards are not applicable on reserves, and no federal standards have been set yet.”
Para 14, 1st sentence, comments:
We request that that this statement be supported by references to those that have expressed
concern, as the statement suggests that Canada’s implementation of the chemicals and waste
MEAs is not considered relevant by a report focusing on “toxics” management. Under the
Multilateral Environmental Agreements (MEAs)—the Basel, Rotterdam, Stockholm, and
Minamata conventions, and the Montreal Protocol—, it is important to note that Canada
meets its international obligations and is an active participant.
Para 16, comments:
Footnote #11 appears to be an error as it refers to a webpage on parliamentary reviews of the
Canadian Environmental Protection Act (CEPA)—there is no discussion around integrating
human rights protection in our legal framework on that webpage; only factual information
on the most recent and previous parliamentary reviews of CEPA.
Para 18, comments:
Missing text after 1st sentence.
Para 18, 3rd sentence, comments:
We recommend that a reference to Canada’s Multi-Sector Air Pollutants Regulations be
included here as they set mandatory national emissions standards to reduce air pollutant
emissions from industrial boilers and heaters and stationary engines used by a number of
Canadian industries, as well as standards for the cement sector.
Para 18, 4th sentence, comments:
In reference to “recent years”: Please note that Canadian Environmental Sustainability
Indicators have shown an overall reduction of key air pollutants since 1990.
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