Haj Ali |1

Karim Haj Ali Professor Gil Lan Law 534 16t March 2011

Updating the regulatory dialectic: Protection of environment & human health

The US military release of the herbicide Agent Orange exposed the Vietnamese population causing almost 400,000 deaths, harming another 500,000. Subsequently two million were born with defects such as cancer and other illnesses.1 Tong Van Vinh, who worked as a Vietnamese military truck driver at the time, recalls the incident: The whole earth was covered with it We thought they were dropping smoke bombs on us. We didn't know it was a chemical.2 The use of the chemical extended beyond the boundaries of the Asian continent. Countries such as Australia, New Zealand and Canada, all reported the use of the agent by their government and military.3 The Canadian government later on banned the use of the herbicide in 1985, as it acknowledged that the key ingredient found in the agent was a carcinogen and thus detrimental to human health.4 The failure of the federal government to protect its general public from the adverse effects of the agent prior to its 1985 classification indicates that a different regulatory scheme concerning industrial chemicals ought to be adopted. An effective scheme should include empirical analysis of potential environmental contaminants, while also permitting flexibility

Mick, Hayley, and Geoffrey York. "'Last Ghost' of the Vietnam War." The Globe And Mail. 12 July 2008. Web. <http://www.theglobeandmail.com/archives/last-ghost-of-the-vietnam-war/article697346/>.
2

Mick, Hayley, and Geoffrey York .

McMahon, Barbara. "Australia Cancer Deaths Linked to Agent Orange." Gaurdian.co.uk. The Guardian, 19 May 2008. Web. <http://www.guardian.co.uk/world/2008/may/19/australia>.
4

NZPA. "Concern Prompts New Review of Dioxin Study." Nzherald.co.nz. NZ Herald, 25 Nov. 2006. Web. <http://www.nzherald.co.nz/dioxin/news/article.cfm?c_id=675&objectid=10412402>.

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when prosecuting offenders. In 1966, military commanders from CFB Gagetown in New Brunswick decided to clear unwanted vegetation in order to conduct training exercises. They reached a deal with the American government that allowed its hired manufacturers to test out the defoliant in the area (before its use in Vietnam). A military briefing obtained by CBC suggests that more than a thousand barrels of the herbicide were used in Gagetown, at an estimated 3,879 acres.5 Ken Dobie a resident of Oromocto, New Brunswick, recalls a summer job where he was hired to clear brush in the same military base back in the day : I know that I was there with several hundred other kids, I know what I did There's no other reason on this Earth why I would be having about 15 different diseases and ailments that are going to eventually turn into cancer.6 Mr. Dobie's family doctor states that his symptoms point to some kind of chemical exposure. Environmental experts such as Daniel A. Vallero argue that Dioxin has migrated through soil and has been transported through natural processes such as windblown dust and into the aquatic environment Contamination of soil and sediments provides a reservoir source of dioxin for / Exposure pathways for humans and wildlife.7 Levels of the dioxin compounds are still present in the soil and water supply at Gagetown, this contaminant inevitably is found in all those who inhabit the area. New Brunswick is not the only province to have witnessed such incidents. The Ontario government just recently submitted that Agent Orange was widely used in the province around the same time. Ontario Hydro reported the use of the herbicide to clear power lines from

5 6 7

Arsenault, Chris. "Collateral Damage." This Magazine. Mar.-Apr. 2006. Web. <http://www.thismagazine.ca/issues/2006/03/collateral.php>. Elliott, Louise. "Agent Orange and Agent Purple." CBC News. 21 Aug. 2007. Web. <http://www.cbc.ca/news/background/agentorange/>.

Vallero, Daniel A. "Biomedical Ethics for Engineers ..." Google Books. May 2010. Web. <http://books.google.com/books?id=AeT56Pi8LFYC&pg=PA73#v=onepage&q&f=false>.

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1950 to 1979.8 It was also reported that Ontario farmers at the time were using the chemical on their properties. Throughout the 50's 60's and 70's, vast expanse of Crown land was cleared using the agent along with its lesser known but more toxic relative, Agent Purple. These revelations have prompted the recent federal government to take corrective action, and in 2007 it did so by announcing ex-gratia payments of $20,000 to every individual afflicted with diseases stemming from the use of the chemical.9 It is evident that previous governments failed to properly engage in the principles of risk analysis regarding the regulation of the herbicide. A proper dose curve was not established and an estimate of exposure was likely not conducted. It is also possible that multiple scenario planning was not accounted for, as well as proper use of benchmarking techniques. The ability of a substance to exterminate vast amounts of plant life in a matter of hours should have alarmed those who routinely handled it. However, the personnel working with the agent were not cautioned about its adverse effects, and were exposed as a result. Had the government engaged in appropriate use of risk analysis systems, expense of human health and the environment could have been mitigated and even possibly avoided. Since 1978, several lawsuits in the US were filed by Vietnam War veterans who have been exposed to the agent against the manufacturers of the herbicide, primarily Monsanto Corp. and Dow Chemicals. A class action lawsuit followed in 1980 that was eventually settled 4 years later at a sum of $180 million.10 The settlement proved to be unfitting however, as each veteran would receive a maximum sum of $12,000 spread out over 12 years. Also, receiving payment would

Press, The Canadian. "Agent Orange 'widely Used' in Ont. - Toronto - CBC News." CBC.ca - Canadian News Sports Entertainment Kids Docs Radio TV. 28 Feb. 2011. Web. <http://www.cbc.ca/news/canada/toronto/story/2011/02/28/agent-orange-ontario.html>.
9

Press, The Canadian. "Agent Orange 'widely Used' in Ont. - Toronto - CBC News." CBC.ca - Canadian News Sports Entertainment Kids Docs Radio TV. 28 Feb. 2011.
10

"Agent Orange." The Veterans Coalition. Web. <http://www.vvnw.org/educational_material/agent_orange.htm>.

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effectively render the veteran ineligible to receive public assistance and government pension.11 Although these were US proceedings, the Canadian legal body in comparison did not fare well either. As mentioned earlier, the federal government announced payments of $20,000 only to those who could prove that their illnesses were a direct result of exposure to the chemical. This effectively narrows the scope as to who can obtain compensation, as one must provide evidence that they lived and worked near Gagetown, around the same time when the discharge took place.12 Clearly, a more sophisticated legal and administrative scheme ought to be sought to handle these situations in a more efficient manner. Currently, Environment Canada, established in 1971, handles and delegates matters relating to the environment mandated by the Canadian Environmental Protection Act, 1999 (CEPA). Through its enforcement branch, the legislative scheme and its own inspection agents, Environment Canada also oversees the manufacture and use of toxic substances as mandated by CEPA.13 S.66(1) of the act mandates that the minister of environment and/or minister of health maintain a Domestic Substances List (DSL) that categorizes substances deemed toxic, or capable of becoming toxic as defined under the act. 14 Regular assessments of new substances are handled by the New Substances Program (NSP) prior

11

Chambers, John Whiteclay. "The Oxford Companion to American ..." Google Books. Web. <http://books.google.com/books?id=_Rzy_yNMKbcC&pg=PA725#v=onepage&q=$&f=false>.

12

News, Cbc. "CBC News In Depth: Agent Orange." CBC.ca - Canadian News Sports Entertainment Kids Docs Radio TV. 21 Aug. 2007. Web. <http://www.cbc.ca/news/background/agentorange/>.

13

"Environment Canada - Corporate Profile - About EC." Environnement Canada - Environment Canada. Web. <http://www.ec.gc.ca/default.asp?lang=En&n=BD3CE17D-1#X-2010082408212212>.

14

"Existing Substances Evaluation: DSL Categorizatin and Screening Program." Environnement Canada - Environment Canada. 22 Feb. 2007. Web. <http://www.ec.gc.ca/substances/ese/eng/dsl/dslprog.cfm>.

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to their entry into the Canadian marketplace.15 In order to promote efficiency in regulatory proceedings, a party that is found in violation of CEPA, and in this sense violation of toxic substance provisions, might be entitled to avoid litigation through Environmental Protection Alternative Measures (EPAM).16 After the charges are laid, the Attorney General represented by the Crown prosecution applies several factors located under S.296 (1) of CEPA. If the accused is found to satisfy these factors, he/she will then be required to take corrective action in order to restore compliance. If the accused is in a regulated industry, such corrective measures could include: change of business processes, installation of pollution control techniques, clean up of the damaged site and any other measure agreed upon by the parties.17 Perhaps a more efficient scheme is available and ought to be sought. The legislator in the previous regulatory scheme has clearly engaged in risk assessment and management principles prior to the drafting of the legislation. However, the conditions laid out in S.296 (1) of CEPA ought to be more in tune with general principles and not specific codified standards. Areas such as the environment are too vast, and by their nature not susceptible to precise regulation.18 When given 10 commandments per se, a sophisticated offender is likely to draw up number 11 In reference to Malcolm Sparrow and his classification of harms,19 the type of harm categorized by environmental offences in this sense, is a blend of both Invisible harms & Conscious opponents. Environmental offences, such
15

"Environment Canada - Acts & Regulations - The Canadian Environmental Protection Act, 1999 and the Assessment of New Substances." Environnement Canada - Environment Canada. 24 Jan. 2011. Web. <http://www.ec.gc.ca/lcpe-cepa/default.asp?lang=En&n=84CC4046-1>.

16

"Environment Canada - Acts & Regulations - Environmental Protection Alternative Measures (EPAMs)." Environnement Canada Environment Canada. 28 Jan. 2010. Web. <http://www.ec.gc.ca/lcpe-cepa/default.asp?lang=En&n=101A7C3C-1>.

17

"Environment Canada - Acts & Regulations - Environmental Protection Alternative Measures (EPAMs)." Ontario v. Canadian Pacific Ltd., [1995] 2 S.C.R 1028 sub nom. R. v. Canadian Pacific Ltd. Sparrow, Malcolm. The Character of Harms: Operational Challenges in Control . New York: Cambridge UP, 2008. Print.

18

19

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as a chemical discharge, could be classified as invisible harms in a sense that they could be nonvisible due to lack of reporting. Here, an ex ante system of general principles is likely more effective in combating such harm, possibly through formulation of governmental agencies with the purpose of putting in place reporting mechanisms and ensuring compliance through effective pollution prevention programs. Currently, under S.56 (1), a person (or organization in this sense) is not required to put in place a pollution prevention plan, unless notified by the Minister of Environment/Minister of Health.20 Of course having in place such a plan works in favour of the defendant to show that they are compliant in the first place, but the mere fact that they are not required to is cause for concern. The proposed governmental agency, as well as the provincial governments, ought to ensure that all businesses seeking to enter a regulated industry have some form of pollution prevention model in place. Calstone Inc. perhaps ought to serve as a role model for any businesses contemplating entrance into a regulated field. The incorporation is a Canadian family owned business that creates and manufactures high quality metal furniture products in Scarborough, Ontario.21 The company implemented numerous pollution prevention programs that in turn allowed it to realize multiple environmental, economic and social benefits, and was also granted the Canadian Council of Ministers Pollution Prevention Award.22 Another methodology for enforcement can come through the use of permits, or better yet certificates of approval. Waste disposal systems and regulations (use of landfills) are already in place, and the

20

"Canadian Environmental Protection Act 1999." Department of Justice. Canada. Web. <http://laws.justice.gc.ca/eng/C-15.31/page-4.html>.

21

"Environment Canada - Pollution and Waste - Calstone, Inc." Environnement Canada - Environment Canada. 9 Sept. 2010. Web. <http://www.ec.gc.ca/p2/default.asp?lang=En&n=36EB925F-1>.

22

"Environment Canada - Pollution and Waste - Calstone, Inc." Environnement Canada - Environment Canada.

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jurisdiction is handed to the provincial governments in order to ensure proper compliance23. Perhaps regular agency inspections ought to be in place as well in order to ensure effective compliance with the scheme. As for the conscious opponent elements dealing with environmental discharge, an ex post system of specific prescriptions with limited site-specific assessment is obviously better suited. The judiciary handles countless cases of alleged offences, and not all Triers of fact are well equipped with the expertise to handle complex matters. Therefore, a proposed tribunal consisting of a panel of an un-even amount of members should be taken into consideration. The tribunal would consist of environmental experts ranging from judges with case law experience to scientists with reputable careers. The tribunal would thus be able to handle the most complex of cases dealing with chemical discharge into the environment and determine the appropriate penalties, all while subject to laws and regulations dealing with the matter and itself. Before one attempts to classify the type of offence regarding chemical discharge, one ought to examine the implications of the three types of offences already in place. Designation of such an offence as one of absolute liability might seem efficient in the beginning as the prosecution need not establish any fault elements, however citing Justice Dickson on the matter There is no evidence that a higher standard of care results from absolute liability.24 The underlying reason behind that is that most legislation that eliminates a defence of due diligence usually permits its consideration when assessing an appropriate penalty and thus there is no net gain in efficiency. Individual offences against the environment thus ought to be treated as strict

23

"Environment Canada - Acts & Regulations - Part I: Canada's National Implementation Plan (NIP) under the Stockholm Convention on Persistent Organic Pollutants." Environnement Canada - Environment Canada. Web. 6 Dec. 2010. <http://www.ec.gc.ca/lcpecepa/default.asp?lang=En&n=3EEAC8B8-1&offset=6&toc=show>.

24

Citing Justice Dickson in R. v. Sault Ste. Marie at p. 363

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liability. This will allow, where specified in the relevant legislation, the defendant to mount a defence of due diligence once the prosecution has proven the actus reus. Hence, the reverse onus will allow the defence to explain why such incident (chemical discharge) took place and whether compliance systems were in place, as well as explain whether the offence was reasonably foreseeable. In regards to the due diligence defence, the 14 factors currently used to assess the defence, is perhaps better replaced by a risk management matrix that directs priorities in the taking of preventative steps25. The two competing categories in the matrix compare the 'precautions taken to avoid the event' vs. 'systems to measure potential gravity and likelihood of impact', which is arguably more scientifically valid as opposed to the current 14 factors created by common law. The third 'out of the box' factor so to speak is that relating to officially induced error principles. Since a proposed tribunal would be overseeing environmental issues in regards to industrial chemical discharge, it likely wont be an issue, as the tribunal, as mentioned before, will consist of experts who likely will exercise more discretion in their findings and application of the law. Another probable reason underlying use of strict liability offences for individual offenders could stem from the fact that since the proposed tribunal is in charge of prosecuting environmental offenders, then there is likely a better chance that the individual defendant is not bombarded with multiple charges and only ones that are significant, therefore not having to bear significant cost consequences related with multiple charges being laid as is the current case with crown prosecution. When the matter of discharge concerns corporations, the offence is arguably better suited as one of mens rea. The reason behind that is due to the financial and legal position a corporation enjoys. A corporation participating in a regulated industry is more likely to have

25

"[2010-09-03] - Risk Management Policy." Welcome Page | Page D'accueil. 10 May 2001. Web. <http://www.tbs-sct.gc.ca/pol/doceng.aspx?id=12253ion=text>.

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better access to resources throughout its daily operations than an average individual does. Corporations also are usually held to a higher standard in a professional field, and more likely to deal with the use industrial chemicals than its individual counterpart. The introduction of bill C45 into the Canadian Criminal Code allows prosecution of any organization under criminal proceedings through the introduction of the 'senior officer' element, effectively allowing prosecution of both policy makers and implementers.26 Where the proposed tribunal will have the power to prosecute corporate environmental offenders, the adequacy of enforcement should be higher than it is currently, as the tribunal will consist of experts in the field of environmental law. Thus, the cyclical lag between enforcement and happenings would most likely be reduced. Bill C-45 only goes so far however as to allow criminal prosecution of an organization which benefited from the offensive act as is required by S.22.2.27 Therefore, a senior officer that commits an offence to benefit oneself is likely not sufficient in a sense to allow prosecution of the entire firm. This would thus amount to personal liability and is as such better prosecuted under the strict liability regime mentioned earlier. Critics could argue that the afore mentioned proposals would be ineffective as it is too costly to set up a tribunal to prosecute offenders, and is an inefficient use of taxpayers money. However, the use of The Environmental Damages Fund, a specified purpose account administered by Environment Canada,28 could prove to be an effective way to manage resources from a financial perspective. Environment Canada uses all the proceeds from the result of fines,
26

An Act to amend the Criminal Code (Criminal Liability of Organizations) , 2d Sess., 37th Parl., 2003 (assented to November 7, 2003), S.C. 2003, c. 21.
27

"OSH Answers: Bill C-45 - Overview." CCOHS: Canada's National Centre for Occupational Health and Safety Information. Web. <http://www.ccohs.ca/oshanswers/legisl/billc45.html>.

28

"Environment Canada - Funding - Environmental Damages Fund." Environnement Canada - Environment Canada. 23 July 2007. Web. <http://www.ec.gc.ca/edf-fde/default.asp?lang=En&n=C5BAD261-1>.

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court orders and voluntary payments as a mechanism to direct payments towards the fund, and use them towards the restoration of the environment, R&D as well as education and awareness. An independent evaluation of the EDF by the agency found that its use in the Atlantic region was effective and consistent with the terms outlined in the original submission.29 Other areas, with the exception of the Pacific Yukon region, were found to be unfamiliar with the use of the fund and its full potential as they hand little to no experience with the underlying mechanism at hand.30 This could be linked to the lack of cases, or precedent, within areas outside the Atlantic region. As more cases dealing with environmental offences came about, more experience developed as a result of frequent use of the fund.31 The report evaluation concludes with the main recommendation that use and knowledge of the EDF ought to be communicated to the entire community in order to ensure a relevant, successful and effective fund.32 Another broader argument can be drawn from environmental health expert John Wargo in his most recent book Green Intelligence (Yale, 2009). When addressing another significant environmental contaminant:

Consider what the world might have done with the $5.5 trillion expended by the government to create, store, and deploy nearly 65,000 nuclear weapons held by both the United States and the Soviets during the 1980s. Imagine the improvements in health,
29

"Environment Canada - Acts & Regulations - Environmental Damages Fund Evaluation." Environnement Canada - Environment Canada. 28 Jan. 2010. Web. <http://www.ec.gc.ca/lcpe-cepa/default.asp?lang=En&n=387E02BA-1&offset=1&toc=show>.
30

"Environment Canada - Acts & Regulations - Environmental Damages Fund Evaluation." Environnement Canada - Environment Canada.

31

"Environment Canada - Acts & Regulations - Environmental Damages Fund Evaluation." Environnement Canada - Environment Canada. 28 Jan. 2010. Web. <http://www.ec.gc.ca/lcpe-cepa/default.asp?lang=En&n=387E02BA-1&offset=5&toc=show>.

32

"Environment Canada - Acts & Regulations - Environmental Damages Fund Evaluation." Environnement Canada - Environment Canada. 28 Jan. 2010. Web. <http://www.ec.gc.ca/lcpe-cepa/default.asp?lang=En&n=387E02BA-1&offset=6&toc=show>.

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education, environmental protection, parks, transit, technology, sustainable development, and foreign aid that might have changed the course of civilization if these resources had been directed for the greater good.(Wargo 248).33

33

Wargo, John. Green Intelligence: Creating Environments That Protect Human Health . New Haven, CT: Yale UP, 2009. Print.

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Bibliography:
"Agent Orange." The Veterans Coalition. Web. <http://www.vvnw.org/educational_material/agent_orange.htm>. An Act to amend the Criminal Code (Criminal Liability of Organizations) , 2d Sess., 37th Parl., 2003 (assented to November 7, 2003), S.C. 2003, c. 21. Arsenault, Chris. "Collateral Damage." This Magazine. Mar.-Apr. 2006. Web. <http://www.thismagazine.ca/issues/2006/03/collateral.php>. "Canadian Environmental Protection Act 1999." Department of Justice. Canada. Web. <http://laws.justice.gc.ca/eng/C-15.31/page-4.html>. Chambers, John Whiteclay. "The Oxford Companion to American ..." Google Books. Web. <http://books.google.com/books?id=_Rzy_yNMKbcC&pg=PA725#v=onepage&q=$&f=false>. Citing Justice Dickson in R. v. Sault Ste. Marie at p. 363 Elliott, Louise. "Agent Orange and Agent Purple." CBC News. 21 Aug. 2007. Web. <http://www.cbc.ca/news/background/agentorange/>. "Environment Canada - Corporate Profile - About EC." Environnement Canada - Environment Canada. Web. <http://www.ec.gc.ca/default.asp?lang=En&n=BD3CE17D-1#X-2010082408212212>. "Environment Canada - Acts & Regulations - The Canadian Environmental Protection Act, 1999 and the Assessment of New Substances." Environnement Canada - Environment Canada. 24 Jan. 2011. Web. <http://www.ec.gc.ca/lcpe-cepa/default.asp?lang=En&n=84CC4046-1>. "Environment Canada - Acts & Regulations - Environmental Protection Alternative Measures (EPAMs)." Environnement Canada - Environment Canada. 28 Jan. 2010. Web. <http://www.ec.gc.ca/lcpecepa/default.asp?lang=En&n=101A7C3C-1>. "Environment Canada - Acts & Regulations - Environmental Protection Alternative Measures (EPAMs)." "Environment Canada - Pollution and Waste - Calstone, Inc." Environnement Canada - Environment Canada. 9 Sept. 2010. Web. <http://www.ec.gc.ca/p2/default.asp?lang=En&n=36EB925F-1>. "Environment Canada - Pollution and Waste - Calstone, Inc." Environnement Canada - Environment Canada. "Environment Canada - Acts & Regulations - Part I: Canada's National Implementation Plan (NIP) under the Stockholm Convention on Persistent Organic Pollutants." Environnement Canada - Environment Canada. Web. 6 Dec. 2010. <http://www.ec.gc.ca/lcpe-cepa/default.asp?lang=En&n=3EEAC8B8-1&offset=6&toc=show>. "Environment Canada - Funding - Environmental Damages Fund." Environnement Canada - Environment Canada. 23 July 2007. Web. <http://www.ec.gc.ca/edf-fde/default.asp?lang=En&n=C5BAD261-1>. "Environment Canada - Acts & Regulations - Environmental Damages Fund Evaluation." Environnement Canada Environment Canada. 28 Jan. 2010. Web. <http://www.ec.gc.ca/lcpe-cepa/default.asp?lang=En&n=387E02BA1&offset=1&toc=show>.

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"Environment Canada - Acts & Regulations - Environmental Damages Fund Evaluation." Environnement Canada Environment Canada. "Existing Substances Evaluation: DSL Categorizatin and Screening Program." Environnement Canada Environment Canada. 22 Feb. 2007. Web. <http://www.ec.gc.ca/substances/ese/eng/dsl/dslprog.cfm>. McMahon, Barbara. "Australia Cancer Deaths Linked to Agent Orange." Gaurdian.co.uk. The Guardian, 19 May 2008. Web. <http://www.guardian.co.uk/world/2008/may/19/australia>. Mick, Hayley, and Geoffrey York. "'Last Ghost' of the Vietnam War." The Globe And Mail. 12 July 2008. Web. <http://www.theglobeandmail.com/archives/last-ghost-of-the-vietnam-war/article697346/>. News, Cbc. "CBC News In Depth: Agent Orange." CBC.ca - Canadian News Sports Entertainment Kids Docs Radio TV. 21 Aug. 2007. Web. <http://www.cbc.ca/news/background/agentorange/>. NZPA. "Concern Prompts New Review of Dioxin Study." Nzherald.co.nz. NZ Herald, 25 Nov. 2006. Web. <http://www.nzherald.co.nz/dioxin/news/article.cfm?c_id=675&objectid=10412402>. "OSH Answers: Bill C-45 - Overview." CCOHS: Canada's National Centre for Occupational Health and Safety Information. Web. <http://www.ccohs.ca/oshanswers/legisl/billc45.html>. Ontario v. Canadian Pacific Ltd., [1995] 2 S.C.R 1028 sub nom. R. v. Canadian Pacific Ltd. Press, The Canadian. "Agent Orange 'widely Used' in Ont. - Toronto - CBC News." CBC.ca - Canadian News Sports Entertainment Kids Docs Radio TV. 28 Feb. 2011. Web. <http://www.cbc.ca/news/canada/toronto/story/2011/02/28/agent-orange-ontario.html>. "[2010-09-03] - Risk Management Policy." Welcome Page | Page D'accueil. 10 May 2001. Web. <http://www.tbssct.gc.ca/pol/doc-eng.aspx?id=12253ion=text>. Sparrow, Malcolm. The Character of Harms: Operational Challenges in Control. New York: Cambridge UP, 2008. Print. Vallero, Daniel A. "Biomedical Ethics for Engineers ..." Google Books. May 2010. Web. <http://books.google.com/books?id=AeT56Pi8LFYC&pg=PA73#v=onepage&q&f=false>. Wargo, John. Green Intelligence: Creating Environments That Protect Human Health . New Haven, CT: Yale UP, 2009. Print.

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