Canada’s Chemicals Management Plan

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By Anne Rochon Ford and Dolon Chakavartty

One would expect that the thousands of chemicals in daily use – in our homes, in industry, and elsewhere – have been through a formal review process by our governments to ensure that they are safe for human exposure. In fact, however, most chemicals in current use haven’t been fully assessed and can really only  be considered “safe” until it’s proven otherwise.

Fortunately, there is a possibility that this far-from-reassuring situation may change. In December 2006, the Government of Canada announced a new process for assessing and managing the potential health and environmental risks from over 23,000 chemicals that are widely used in Canada.  Included in this “Chemicals Management Plan” (CMP) is a “Challenge” to industry: unless industry provides information that suggests otherwise, 200 of these chemicals will be considered toxic (as defined by the Canadian Environmental Protection Act or CEPA). In other words, the ground has shifted – in the case of some chemicals, at least – from “safe until proven otherwise” to “toxic until proven otherwise.” Given the increasing evidence linking exposure to even trace amounts of chemicals in our air, water, soil, food, and homes with chronic illnesses including cancer, this is a step in the right direction.

Over a three-year period, Health Canada and Environment Canada have been releasing the names of fifteen of the 200 chemicals in question every three months. These chemicals will be re-evaluated based on four factors, namely persistence, bioaccumulation, inherent toxicity, and greatest potential for exposure. 

This re-evaluation is currently underway and individuals and groups in the general public – not just scientists and industry – are being encouraged to become knowledgeable about what is going on and to get involved. Funding was provided to the Canadian Environmental Network / Réseau canadien de l’environnement (RCEN), in collaboration with the environmental NGO, Environmental Defence, to coordinate a process of civil society engagement. When the names of chemicals are released, the RCEN notifies a network of individuals and groups about them and explains what the government has concluded (based on existing research).  The RCEN then provides its own  “plain language” assessment of the literature and encourages citizen groups to learn more about these chemicals, many of which can be found in personal care products, household cleaners, cosmetics, and other products with which humans have regular contact.

There will be opportunities for public input both when the quarterly releases of the names of chemicals occur (this process is now complete) and at the later stages when Health Canada and Environment Canada deliberate about how these chemicals will be “managed.”

These deliberations will go on until some time in 2011.

Why should women be concerned?

There are both sex- (e.g., biological) and gender-based (e.g.,social) reasons why women should be aware of these issues.  In particular, women are known to have different experiences with and exposures to many of these chemicals. To take the most obvious: only women get pregnant and give birth, and their exposures can affect the embryo and fetus. One particular concern is based in the substantial body of scientific literature demonstrating the unique vulnerability of the fetus to endocrine-disrupting chemicals found in daily environmental exposures to several chemical substances (e.g. pharmaceuticals in the water;  Bisphenol A [BPA] found in plastic and food products; etc.).

However, women’s special concerns go beyond their reproductive roles. Women and girls have other sex- and gender-based vulnerabilities to being exposed and to being harmed by the exposures that need to be considered in discussions about the control of chemicals. Sandra Steingraber’s work on the falling age of puberty provides compelling evidence to suggest that myriad factors, including exposures to endocrine-disrupting chemicals, play a role in accelerating puberty in girls.

The social and caretaking roles carried out by many women, the nature of much of their paid employment in the service sector, and their greater use of personal care products (cosmetics, lotions, specialized cleansers, etc.) can all lead to daily exposure to certain chemicals, which put women at higher risk for health-related problems. Additionally, medical or health conditions that have been attributed to chemical exposures, even though these associations are often deemed controversial in the medical community (e.g. fibromyalgia, Multiple Chemical Sensitivity Syndrome), tend to be diagnosed at much higher rates in women than men.

Fitting sex and gender into the Chemicals Management Plan

In response to this important initiative underway at Health Canada and Environment Canada, and recognizing the importance of attention to sex- and gender-based aspects of it, the National Network on Environments and Women’s Health (NNEWH) has undertaken a project to foster citizen engagement among women and women’s groups in the CMP. Janelle Witzel from Environmental Defence supports this engagement. “Women’s involvement and interest in the case of BPA was instrumental in prompting government action”, she said. “There is a large potential for women’s voice and participation in the CMP process ... that could lead to policy change.”

The project, which the Canadian Women’s Health Network is consulting on, will involve a public forum slated for February 2010, following a web-based survey seeking input from a broad range of women across Canada. For more information on these initiatives, check the websites of NNEWH ( and CWHN ( for updates.

Anne Rochon Ford is the Co-Director of the National Network on Environments and Women`s Health and Coordinator of the national working group  Women and Health Protection.  

Dolon Chakravartty is a graduate student in Public Health Sciences and Collaborative Program in Environment & Health at the University of Toronto.  She is the Graduate Fellow working with the National Network on Environments and Women’s Health from the Fall 2009 - Spring 2010.


Altman, R.G., R. Morello-Frosch, J.G. Brody, R. Rudel, P. Brown, and M. Averick. (2008). Pollution comes home and gets personal: Women’s experience of household chemical exposure. Journal of Health and Social Behavior, 49(4): 417-435. Available on line through

Steingraber, Sandra. (2007, August).The falling age of puberty in girls: What we know, what we need to know. San Francisco, CA: Breast Cancer Fund. Available on line at Steingraber is careful to point out that a myriad of factors seem to be contributing to this trend, environmental exposures being one significant one.

O’Grady, Kathleen. (2008/2009, Fall-Winter). Early puberty for girls. The new ‘normal’ and why we need to be concerned. Network, 11(1): 11-13. Available on line at


The Canadian Environmental Law Association (CELA) is a community-based environmental law clinic funded by Legal Aid Ontario, and has advocated for improvement and reform of the Canadian Environmental Protection Act for many years. For a collection of submissions, media releases and other commentary, see

The Canadian Environmental Network/ Réseau canadien de l’environnement (RCEN) has funding from Environment Canada to coordinate civil society participation in chemicals management in Canada:

Environmental Defence is an environmental group that is a member of the RCEN that “gathers, reviews, and analyses evidence related to the CMP on behalf of civil society”  and makes this information available through the RCEN website. They have also mounted a campaign to encourage the federal government to designate the chemical 1,4-Dioxane as toxic.

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