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Child Health and the Environment---Public Policy Perspective



I Introduction



The Canadian Partnership for Children's Health and Environment (CPCHE) is an emerging national partnership of eleven environmental, child-rights, public health, and health organizations with a shared vision of improving children's environmental health in Canada. With decades of collective experience addressing child health and wellbeing from a variety of perspectives, CPCHE partners are working across traditional boundaries to address growing concerns about the impact of harmful environmental contaminants on the health of Canadian children.



Environment is a determinant of health that has, until recently, received relatively little attention. However, a growing body of research indicates that substances in the environment can and do affect child health and development. To raise the public profile of children's environmental health issues among parents, caregivers, service providers who work with children, and decision makers, CPCHE has adopted a multi-pronged approach that includes research, education, and active participation in the public policy process. These strategies complement and support each other. They also create a framework through which to create and promote the public and political pressure needed to bring about meaningful and sustainable change around issues of children's environmental health. The CPCHE website--http://www.healthyenvironmentforkids.ca--provides further information about the partners as well as CPCHE goals and activities.

II Why Focus on Children's Environmental Health?



The phrase "children are not little adults" is found in most texts, reports, presentations, and papers on children's environmental health. It refers to the fact that children are growing and developing in ways and at a pace that makes them more vulnerable than adults to environmental contaminants such as such as metals (e.g., lead, mercury), pesticides, persistent organic pollutants (e.g., dioxins, PCBs), outdoor air pollutants, and environmental tobacco smoke.



This heightened vulnerability is due to several factors: they can have greater opportunities for exposure to environmental contaminants than adults, their rapidly developing bodies can be particularly sensitive to contaminants, and they have more years of life ahead of them and therefore have a longer time period during which an exposure can bring on an illness. Most scientists agree that the time between conception and six months of age represents a period of particular vulnerability to environmental contaminants. But they also believe that older infants, children, and adolescents are at greater risk than adults too because of the huge physiological and developmental changes they are experiencing.



Concern about the impacts of environmental contaminants on child health is rising. This is fuelled, in part, by an increasing awareness of the link between environment and health, unexplained disease trends in children, and a rapidly expanding body of scientific literature on children's environmental health. Evidence is also emerging that highlights the significant costs associated with environment-related illnesses in children. All of this has contributed to the recognition of the importance of children's environmental health as a policy issue.



Public policy that relates to child health and the environment exists at every level of government. Schools, childcare facilities, housing, recreational facilities, and many other entities also contribute to the overall policy framework that affects the interaction of children with their environments, the potential for harmful exposures, and the resulting outcomes. Change is needed at all of these levels if we are to create an environment in which exposure to harmful substances does not limit children in achieving their full potential.



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III Children's Environmental Health Policy--The National Level



As a signatory to the 1997 Declaration of the Environment Leaders of the Eight on Children's Environmental Health, Canada pledged to develop national policies that take into account the unique vulnerabilities of children with respect to potentially harmful environmental exposures. This commitment was reinforced in Health Canada's 1997 Sustainable Development Strategy and through Canada's membership in the Commission for Environmental Cooperation, through which Mexico, the U.S., and Canada have resolved to develop a cooperative children's-health agenda. These public commitments communicate the message that Canada is committed to improving children's environmental health. While commendable, they become meaningless if they are not followed up with improved policies that are protective of child health and the resources required to enforce those policies.



A two significant pieces of federal legislation, which together shape the framework for children's environmental health protection on the national level, are now under review: the proposed Canada Health Protection Act and the Canadian Environmental Protection Act (both described in more detail below). This creates a window of opportunity for the integration of a children's environmental health perspective into Canada's federal legislative framework. In concrete terms, this includes

* addressing the need for more research on exposure to contaminants and their effects,

* determining how to apply the precautionary principle to the assessment and regulation of substances and products, and

* exploring how risk-assessment and risk-management processes can better reflect the unique exposures and vulnerabilities of children.



Recent changes to the federal Pest Control Products Act (passed in 2002 and expected to come into force later on this year) are an encouraging sign that child-health considerations can be included in federal legislation. Increased knowledge and concern about the impact of pesticides on child health prompted requirements for special protection of infants and children, more detailed and realistic exposure assessments to be used in determining risks to children, and an emphasis on public participation in the decision-making process. For more information see http://www.hc-sc.gc.ca/pmra-arla/english/legis/pcpa-e.html.



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IV National Legislation Under Review



1. The proposed Canada Health Protection Act (CHPA)



Health Canada has just completed its second round of consultations on the proposed Canada Health Protection Act. The intent is to replace the Food and Drugs Act, the Hazardous Products Act, the Quarantine Act, and the Radiation Emitting Devices Act with a health protection regime based on a new Canada Health Protection Act. These changes will have significant implications for children's environmental health. Canada's existing health protection law is piecemeal and in need of updating. The opportunity to modernize the Hazardous Products Act is particularly important with respect to children's environmental health as children are increasingly exposed to toxic substances through consumer products. (One example of this is the lead that can be found in some art supplies, PVC plastics, candlewicks, and inexpensive jewellery.) However, as written, the current proposal does not directly or adequately address children's unique vulnerabilities and specific needs with respect to environment and health.



The CPCHE response to the proposal outlined Canada's national and international commitments to children's environmental health, emphasized the need for the integration of a children's environmental health perspective in the proposal, and made a number of recommendations as to how this could be accomplished. Individual CPCHE partners also submitted comments that reflected similar comments and concerns. After analysing the comments it received, Health Canada plans to draft a Bill that will eventually go before Parliament. No timeline is set for this process. However as the proposed Act makes its way through the parliamentary process there will be additional opportunities to comment on and inform its development. Visit Health Canada's Legislative Renewal web page at http://renewal.hc-sc.gc.ca for more information about this proposed Act.



2. The Canadian Environmental Protection Act (CEPA)



The CEPA regulates hazardous substances, making it a powerful tool with which to prevent and/or reduce childhood exposures to potentially toxic substances. The 2004 five-year review of this Act creates a valuable opportunity to ensure that greater consideration is given to the assessment and management of risks posed by toxic substances to children.



Under CEPA, all substances used in Canada must be assessed with respect to their impact on the environment and on human health. Those deemed CEPA-toxic are subject to regulatory control and may be restricted or prohibited. Substances are considered either "new" or "existing" (those with a history of use in Canada). The 23,000 existing substances make up what is known as the Domestic Substances List (DSL). While new substances are assessed as they enter the market, existing substances are currently being prioritized to determine the order in which they will be assessed (to be completed by September 2006) The incorporation of a child health perspective into this categorization process would allow for earlier assessment and regulation of many substances known and suspected to be toxic to children.



In March of 2004, Health Canada received public comments on the first of three proposals regarding the categorization of the DSL. It outlined an approach for identifying priorities in categorizing substances for their potential for human exposure. Later this year a second proposal will be released on the categorization of substances with respect to their inherent toxicity to humans. In the fall of 2005, a third proposal will integrate the results of the first two proposals to develop a final categorization strategy. The last two proposals are important and will provide key opportunities to reinforce the message that child health must be considered at all stages of the process. For more information on DSL existing substances and the categorization process visit Health Canada's Existing Substances Division web page at http://www.hc-sc.gc.ca/hecs-sesc/exsd/categorization_dsl_human_exposure.htm.



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V Participation in the Policy Process



Participation in the public policy process related to children's environmental health can take many forms. Here are a few ways to get involved:

* Provide direct input to the national legislative processes described above by visiting their websites, staying informed, and making use of every opportunity offered to send a message regarding the importance of protecting children from environmental hazards.

* Develop and promote a children's environmental health "lens" through which to consider and address workplace, local, and other policies and frameworks that might impact on child health and development.

* Join and/or support organizations working on issues of children's environmental health. The eleven CPCHE partners represent a sample of the types of organizations interested and active in promoting a healthier environment for children and there are many more.

* Join the CPCHE network by signing on to our mailing lists at http://www.healthyenvironmentforkids.ca/english/mailing_lists/.

* Visit the CPCHE website regularly (http://www.healthyenvironmentforkids.ca). As it develops, we plan to facilitate public participation in the policy process by providing access to information on specific topics and issues and updates on and links to policy initiatives taking place as well as promoting connections between people interested in and working on the same issues.