As a non-profit organization…

As a non-profit organization committed to promoting and protecting health and wellbeing, the Ontario Public Health Association (OPHA) appreciates the opportunity to comment on the above EBR Posting. We are supportive of updating the Sulphur Dioxide (SO2) air standards to bring them in line with the existing body of science regarding the health and ecological impacts of exposure to SO2. We also agree with the Ministry’s use of conversion factors to derive the 1 hour standard from the 10-minute Ambient Air Quality Criteria (AAQC) value, rather than directly applying the 10 minute AAQC as the updated air standard. Public Health views this method to be protective of adverse effects in sensitive populations. Given that adverse effects occur from short-term exposure to SO2, OPHA does not feel that the direct application of the 10 minute AAQC as the proposed one-hour standard would adequately protect sensitive populations.

The Ministry has proposed applying the updated standards on a regional basis. In this situation, the updated standards would apply only to southern Ontario, while the current standards would apply to northern Ontario.
The Ontario Public Health Association strongly opposes the creation of a 2-tiered air standard for SO2 for the following reasons:
• The current SO2 air standards are out of date and do not reflect the existing body of science regarding the health and environmental impacts of exposure to SO2. Toxicological information has been published since the standard was originally developed in 1974 which supports the need for the update.
• The health impacts of exposure to SO2 are clear. As noted in the Science Discussion Document on the Development of Air Standards for Sulphur Dioxide (SO2), short-term exposure to SO2 is associated with respiratory effects, including bronchoconstriction, changes in lung function, airway inflammation, airway hyper-responsiveness and emergency room visits. The creation of a 2-tiered air standard will provide inadequate health protection for the residents of northern Ontario. From a health equity perspective, the residents of northern Ontario deserve the same level of protection as those who live in southern Ontario. In the Ministry’s own words, it focused “on data that will allow for protection to all individuals in the general public, including those who are likely to be susceptible to developing a critical effect”. Asthmatics are one group who are likely to be at risk from adverse health effects from SO2. Asthma is the third-most common chronic disease in Canada and its prevalence is increasing. It is the leading cause of missed school days for children. Ontarians have a 40% risk of developing asthma before they reach 40 years of age(1).
• SO2 emissions are a major precursor to the formation of PM2.5. PM2.5 in air pollution is one of the top 3 environmental carcinogens in Ontario, and is responsible for 290 to 900 for cancer cases in Ontario each year(2). In addition to reducing SO2 in air, the updated standard will result in a reduction in PM2.5. These reductions will improve the health of Ontarians.
• O. Reg 419/05 provides mechanisms for facilities and industries who cannot meet the updated standard, including site-specific and technical standards. Given that these mechanisms exist, it does not appear that there is a justification for the 2-tiered standard being proposed by the MOECC.

The science regarding the health effects of SO2 is clear and supports the need for an updated air standard in both southern and northern Ontario. The health of northern Ontario residents deserves the same level of protection as those who live in southern Ontario.

The Ontario Public Health Association would be happy to meet with the Ministry to discuss this proposal.

Sincerely,

Pegeen Walsh

About OPHA
Created in 1949, the Ontario Public Health Association (OPHA) is a non-partisan, non-profit organization that brings together a broad spectrum of groups and individuals concerned about the health and wellbeing of Ontarians. OPHA’s members come from various backgrounds and sectors - from the various disciplines in public health, health care, academic, non-profit to the private sector. They are united by OPHA’s mission of providing leadership on issues affecting the public’s health and strengthening the impact of people who are active in public and community health throughout Ontario. This mission is achieved through professional development, information and analysis on issues affecting community and public health, access to multidisciplinary networks, advocacy on healthy public policy, and the provision of expertise and consultation.

(1) To, T., Gershon, A., Tassoudjo, M., Guan, J., Wang, C., Estrabillo, E., Cicutto, L. The Burden of Asthma in Ontario. ICES Investigative Report. Toronto: Institute for Clinical Evaluative Sciences; 2006.
(2) Cancer Care Ontario, Ontario Agency for Health Protection and Promotion (Public Health Ontario). Environmental Burden of Cancer in Ontario. Toronto: Queen’s Printer for Ontario; 2016.

[Original Comment ID: 211515]