What we heard: Defining vulnerable populations
A summary of feedback from the consultation: Defining vulnerable populations - A first step toward a policy framework on vulnerable populations
On November 22, 2018, Health Canada and Environment and Climate Change Canada launched a 60-day online consultation, inviting interested stakeholders and the general public to provide comments on the Government of Canada’s proposed definition of vulnerable populations in the context of federal chemicals management activities.
The online consultation provided Canadians with an opportunity to review a proposed definition and illustrative examples as a first step towards the development of a policy framework focused on enhancing the protection of vulnerable populations through the assessment and management of risks associated with certain chemicals.
Comments were received from 55 individual stakeholders and organizations. In general, stakeholders were supportive of the Government’s intention to seek opportunities to strengthen the approach when considering vulnerable Canadians in chemicals management and of the definition proposed in the consultation paper. Input was also received expressing ideas on how the definition for vulnerable populations could be adjusted to highlight related issues, such as occupational exposure, and how a definition could be operationalized in the implementation of a chemicals management program.
The Government of Canada is committed to continuously improving how vulnerable populations are considered in the assessment and management of chemicals. Chemicals are an integral part of everyday life, essential to our health and well-being, the economy, our communities, and our homes. While chemical substances do provide many benefits, they may also have harmful effects on human health, and some Canadians may be more vulnerable than others to those harmful effects.
Stakeholders have identified the enhanced consideration of vulnerable populations in chemicals management as a key area of interest. Furthermore, in June 2017, the House of Commons Standing Committee on Environment and Sustainable Development (the Committee) submitted its report on the review of the Canadian Environmental Protection Act, 1999 (CEPA 1999). The report contained 87 recommendations to improve the administration of CEPA 1999, some of which included a re-examination of how vulnerable populations are considered. In June 2018, the Government submitted a follow-up report to the Committee, outlining its commitments to the recommendations. The response included a commitment “to develop, engage on, and publish under CEPA 1999, a policy on vulnerable populations, which will include a definition of vulnerable populations and the objectives of the program, including a framework for how the Government of Canada considers vulnerable populations as part of risk assessments.”
Overview of consultation
Given the important role chemicals play in Canadians’ lives and the economy, engagement with stakeholders is essential in chemicals managment. As a first step, a 60-day online consultation was launched on November 22, 2018, which closed on January 21, 2019, to seek input from Canadians on a proposed definition of vulnerable populations in the context of chemicals management. The following definition for vulnerable populations was proposed: “a group of individuals within the general Canadian population who, due to either greater susceptibility and/or greater exposure, may be at greater risk than the general population of experiencing adverse health effects from exposure to chemicals.” The consultation document was also distributed among members of the Chemicals Management Plan (CMP) Stakeholder Advisory Council (SAC; a multi-stakeholder group that contributes to the implementation of the program) and the CMP Science Committee (SC ; a group of experts who contribute expertise pertaining to scientific considerations in the delivery of the CMP).
Feedback received through this consultation process will help define the scope for subsequent consultations on how the Government of Canada will address vulnerable populations in a more comprehensive and transparent manner.
The consultation generated 55 sets of comments from Canadians. These represented the views of stakeholders, as well as consolidated feedback from specific groups of stakeholders, , industry associations, Indigenous organizations, academic institutions, health and environmental non-profit organizations, and those familiar with the CMP (Government of Canada employees; SAC/SC members).
What we heard about the definition
Canadian stakeholders expressed generally favourable views on the proposed definition of vulnerable populations, and offered suggested adjustments to make specific reference to issues of interest (for example, life stage, diet, gender, the environment). A number of stakeholders suggested that specific reference to cumulative exposures should be included in the proposed definition. Some stakeholders also suggested that a detailed list of sub-populations be included in order to provide clarity on the scope of the definition.
Suggestions to include the proposed definition in CEPA 1999 were received, with justification that defining the term in legislation would ensure that appropriate protections for vulnerable Canadians remain a priority. However, concerns were also expressed that inclusion in CEPA 1999 would limit the flexibility for the definition to be modified as scientific knowledge and understanding of the issues evolve.
We also heard that the Government must use the term “vulnerable” carefully and be aware of potential unintended consequences such as stigmatization. The factors leading to vulnerability such as age, culture, and socio-economic factors should be central to all discussions.
Respondents identified a number of related issues and subpopulations of concern. The majority of comments were related to the consideration of workers and occupational safety. Some stakeholders expressed the view that occupational and behavioural factors could increase the risk of work-related exposure to chemicals of concern for some subpopulations, and that a policy framework should address this topic. Others identified possible challenges with that approach, noting the importance of avoiding duplication with areas of provincial responsibility and questioning how risks stemming primarily from occupational exposures would be addressed following a chemical risk assessment.
Socioeconomic factors were high on stakeholders’ minds. A number of poverty-related issues were identified as important factors contributing to subpopulations’ susceptibility and exposure to chemicals of concerns (for example, substandard housing, homelessness, poor nourishment, contaminated neighbourhoods, and limited consumer choice). Stakeholders expressed the desire to see these factors incorporated into the definition and/or encompassed by a future policy framework that would guide the application in addressing populations at increased risk from chemicals.
Stakeholders identified the impacts of geographical location in affecting the vulnerabilities of those living in the vicinity of commercial or industrial facilities. More generally, a number of respondents noted the relationship between a healthy environment and human health. In addition, cumulative exposures, endocrine-disrupting chemicals, and multiple chemicals sensitivities were also identified as issues of interest. Stakeholders expect the Government of Canada to take an evidence-based approach to the development of a policy framework based on firm scientific evidence.
The unique exposure risks of Indigenous communities were also highlighted, particularly as they pertain to drinking water and country or traditional foods. Furthermore, stakeholders identified the importance of considering Indigenous populations (on and off reserve) in the development of a policy framework to protect vulnerable populations in the context of chemicals management.
Though comments received from stakeholders offered a diverse range of perspectives, some consultation gaps were noted such as groups representing New Canadians. Additional efforts will seek to more fully capture the views and concerns of others with regards to the proposed definition.
The Government of Canada would like to thank all those who submitted their valuable feedback on the proposed definition. All comments will be taken into consideration and will help inform the activities related to chemicals assessment and management, including the development of a policy framework to address vulnerable populations.
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