Mandatory health impact assessments are long overdue

Controversy surrounding ignored potential health effects of coal transfer facilities in the Lower Mainland has reinvigorated the push for mandatory health impact assessments in BC.

A proposed new coal transfer facility at the Fraser Surrey Docks and an expansion at the Neptune Terminals in North Vancouver would collectively handle 10 million additional tonnes of coal per year. A third-party environmental impact assessment (EIA), required by law to be performed for major industrial projects in BC, was performed for the Fraser Surrey Docks terminal and concluded that “the Project is not likely to cause significant adverse environmental, socioeconomic, or health effect.”[1] The chief medical health officers of Vancouver Coastal and Fraser Health were quick to respond with disappointment that the review did not assess health issues outside of port boundaries, including coal dust pollution in urban areas by movement of coal-carrying trains. They concluded that the review did “not meet even the most basic requirements of a health impact assessment.”[2]

One might assume that an industrial project undergoing a comprehensive environmental assessment would surely be assessed for potential human health impacts as well. Unfortunately, this is not the case. While assessing environmental impacts of major BC projects is mandatory, examining potential human health impacts is optional in practice.[3] Even when included, as with the Fraser Surrey Docks, there are no requirements for the scope and depth with which potential human health impacts must be assessed.

The Environmental Health Committee believes that BC needs to assess potential human health impacts of industrial projects with the same rigor it uses to assess environmental impacts. 

The call for health impact assessments (HIAs) in BC is far from new, but surprisingly BC was once leading the world in HIA development.[3] Following the rise of health promotion in the 1970s and 1980s, a provincial Royal Commission recommended that studies of potential health effects be included in all EIAs.[4] The Ministry of Health one-upped this recommendation by setting a strategy for stand-alone HIAs to be carried out for all new government policies and programs.[5] Through the support of the ministry and premier, policy analysis procedures were changed to include considerations on the “likely positive or negative impact… on the health of individuals, groups, and communities” with a broad scope of “social, economic, and physical factors affecting health.”[3] An HIA implementation guideline was developed,[6] and workshops were held province-wide. Full implementation seemed likely, but a change in political leadership during the mid-1990s resulted in a switch in health strategies. Progress on HIAs got lost in the mix. Now, all that remains is the policy submission guidelines, of which the section pertaining to health is seemingly discretionary.

To get back on track we can look to Europe and Australia, where mandatory HIAs often exist as stand-alone reviews. Closer to home, the Ministry of Health and Ministry of Environment in Quebec work together to screen projects for potential health concerns and require partial or full HIAs as indicated.[3] Given the existing infrastructure for EIAs in BC, an initial step would be to make health assessment a mandatory part of the EIA process, true to the spirit of the existing legislation.

Steps forward are being analyzed by the HIA Working Group of the BC Environmental Health Policy Advisory Committee, a collaboration of health authorities, the Ministry of Health, and the BC Centre for Disease Control.

However, the current provincial government seems to be moving in the opposite direction, becoming adversarial toward impact assessments. In April, new ski resorts and natural gas plants were announced as exempt from EIAs, a decision that was quickly rescinded after public outcry.[7] The long-awaited federal review of the hydraulic fracturing of natural gas concluded that “data about environmental impacts are neither sufficient nor conclusive,”[8] yet the Minister of Natural Gas Development was quick to disregard this nearly 300-page analysis.[9] Clearly, advocacy is needed from physicians to ensure that assessments become more, not less, prevalent and comprehensive.

We must learn from history’s mistakes, and acknowledge the progress will not be quick and interest must last longer than a 4-year political cycle. With projects massive in both scale and controversy being proposed, it is unlikely that the call for HIAs will end soon. The Enbridge Northern Gateway pipeline carrying bitumen across BC to Kitimat for export, the open-pit Ajax mine partly in the city limits of Kamloops, and the continued growth of hydraulic fracturing of natural gas with massive proposed liquefied natural gas exporting are all projects with potential health consequences that need to be assessed in order to mitigate, or less optimistically, treat.
—Mike Benusic, UBC Medical Class of 2014
Environmental Health Committee, Doctors of BC

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This article is the opinion of the Council on Health Promotion and has not been peer reviewed by the BCMJ Editorial Board.

References

1.    Watson T, Ritter L. Environmental impact assessment for the direct transfer coal facility. SNC-Lavalin. 18 November 2013. Accessed 18 April 2014. www.portmetrovancouver.com/en/projects/OngoingProjects/Tenant-Led-Projec....
2.    Van Buynder P, Daly P. Re: October 24 2013 draft of the Fraser Surrey Docks EIA. 13 November 2013. Accessed 18 April 2014. http://portmetrovancouver.com/docs/default-source/PROJECTS-FSD/fsd-eia-a....
3.    Banken R. HIA of policy in Canada. In: Kemm J, Parry J, Palmer S (eds). Health impact assessment: Concepts, theory, techniques, and applications. New York, NY: Oxford University Press; 2004. p. 165-176.
4.    Seaton, PD. Royal commission on health care and costs: Closer to home. Victoria: The Commission; 1991.
5.    Higgins, JW. New directions for a healthy BC: Meeting the challenge, action for a healthy society. Victoria: Ministry of Health; 1993.
6.    Population Health Resource Branch. Health impact assessment guidelines: A resource for program planning and development. Victoria: Ministry of Health; 1994.
7.    CBC News. BC rescinds environmental assessment exemption. 16 April 2014. Accessed 18 April 2014. www.cbc.ca/news/canada/british-columbia/b-c-rescinds-environmental-asses....
8.    Council of Canadian Academics. Environmental impacts of shale gas extraction in Canada. Accessed 10 May 2014. www.scienceadvice.ca/en/assessments/completed/shale-gas.aspx.
9.    O’Neil P, Shaw R. Politicians go on the attack after scientists call for more research into fracking. Vancouver Sun. 1 May 2014. Accessed 10 May 2014. www.vancouversun.com/business/technology/9797868/story.html.