Explainer: What is Gender-Based Analysis Plus (GBA+)?
This blog post was written by Kanisha Acharya-Patel, WHEN’s Law Reform Specialist, and the views expressed are not intended as legal advice. WHEN advocates for all women, trans, cis, and Assigned Female at Birth (AFAB) individuals. For the purposes of this blog post, the term ‘women’ is used to describe those with ovarian reproductive systems and/or those who identify as women, recognizing that both sex and gender affect one’s vulnerability to environmental harm.
What is GBA+?
GBA+ is an essential analytical tool for developing effective and equitable policies, programs and legislation for diverse populations by identifying direct or indirect impacts of federal government initiatives on different sub-populations and subsequently taking steps to mitigate the negative impacts. GBA+ provides a mandated ‘gender lens’ through which sex and gendered impacts of federal government initiatives are to be evaluated and addressed. The ‘plus’ in GBA+ acknowledges that GBA goes beyond biological (sex) and socio-environmental (gender) differences [1]. GBA+ incorporates a range of intersecting identity factors beyond sex and gender (namely ethnicity, race, religion, age, disability, geography, culture, income, sexual orientation, education, and language) which form and uphold overlapping and interdependent systems of privilege, discrimination and inequality [2]. Therefore, the ‘plus’ in GBA+ essentially expands the ‘gender lens’ of GBA+ into a ‘vulnerability lens’ as it analyzes how a government initiative can have differential impacts on subpopulations based on their identity factors. GBA+ is especially important when considering that historically, federal government initiatives have been informed by a gender-blind approach, where the impact on sex, gender, and other identity factors were not understood or acknowledged in the development of policies, programs and legislation [3]. Women and Gender Equality Canada has released a series of videos intended to increase public understanding of GBA+, including a step by step overview of the GBA+ process.
WHEN’s commitment to GBA+
WHEN is a strong advocate for the use of GBA+ when government initiatives are being developed, implemented or evaluated because GBA+ provides an intersectional feminist lens through which inequities can be identified and addressed. WHEN also believes the federal government should be held accountable for its international and domestic commitments to conduct GBA+ in the development, implementation and evaluation of all federal government initiatives, including legislation, policies and programs.
Why does GBA+ matter in the context of toxic substance management?
The Canadian Environmental Protection Act (CEPA) is the primary piece of federal legislation for protecting environmental and human health, including through the prevention and management of risks posed by toxic substance exposures. In June 2023, CEPA was amended for the first time since 1999 through Bill S-5. GBA+ is mandatory in the development, implementation and evaluation of federal government initiatives, including the approach to managing toxic substances under CEPA.
As explained above, GBA+ analyzes the possible impacts of a government initiative on diverse groups of women, men and gender diverse individuals, by taking into consideration sex, gender, race, income and other intersecting identity factors. Any person’s identity factors, either alone or in tandem, can cause them to be more vulnerable to adverse health impacts from toxic substance exposures. In this context, identity factors can be divided into two categories: physiological determinants of health (such as sex and age) and socio-environmental determinants of health (such as gender, race, socioeconomic status and geographical location).
Health inequity in toxic substance risk assessments
The current risk assessment processes for determining whether a substance is toxic under CEPA fails to consider the significant variability in exposure to toxic substances and susceptibility to adverse health effects from such exposures due to an individual’s or sub-population’s identity factors such as sex, gender, income, or occupation. When assessing the risk of a toxic substance under CEPA, the assumption is that the greater the dose of chemical exposure, the greater the harm to human health. However, this is an oversimplification of the reality: harm to human health from toxic substances varies widely based on physiological determinants of health and socio-environmental determinants of health, which can intersect and negatively impact an individual’s chemical body burden (a measure of a person’s chemical load or a sum of total exposures from all routes of entry (ingestion, absorption, inhalation) and from all sources (air, water food) from all the places we work, live and play in) [4]. The current approach under CEPA narrowly examines the risks of chemicals one at a time, which fails to consider the reality of multiple, cumulative exposures and interactions between multiple chemicals. For example, a risk assessment may conclude that exposure to chemical X in isolation at a low dose will not cause harm to human health, but this assessment does not consider the effects of being exposed to chemical X multiple times during the day, or being exposed to chemical X, Y and Z at the same time.
Physiological determinants of health are not accounted for
Sex, age, disability, and ethnicity are physiological identity factors that impact an individual’s susceptibility to adverse health effects from toxic substances. The safety of a toxic substance is determined using a margin of exposure evaluation, which calculates the difference between the estimated threshold at which a chemical is considered harmful to human health (i.e. toxicity endpoint) and its estimated exposure levels [5]. However, this approach does not consider how sex, age, and other physiological identity factors can influence the margin of exposure. For example, sex and age can intersect and compound a woman’s susceptibility to adverse health effects: in terms of sex, women have a unique susceptibility to chemicals due to sex-specific differences in biochemical pathways, hormone regulation, metabolism, body fat composition, blood chemistry and the size of body tissues [6]. Sex-specific differences can result in women having a lower threshold for toxicity, which means that exposure even at a low dose can have negative impacts. Further, many chemicals have sex-specific impacts, such as endocrine-disrupting chemicals (EDC) which negatively impact metabolic growth and reproductive processes and contribute to the incidence of various diseases such as breast cancer and fibromyalgia [7]. In terms of age, epidemiological evidence demonstrates that women are more biologically vulnerable to toxic substance exposures during critical windows of vulnerability such as puberty, pregnancy, lactation, and menopause [8]. Therefore, a woman in a critical window of vulnerability is inherently more susceptible to adverse health effects from toxic substance exposure.
Socio-environmental determinants of health are not accounted for
Gender, income, education, language, geography, culture and religion are socio-environmental identity factors that impact an individual’s exposure to toxic substances. Exposure to toxic substances can occur through inhalation, ingestion, and skin absorption, and sources of exposure include air, water, food, soil, dust, and through the use of consumer products. To estimate exposure, scientists use standard default values for “receptor characteristics” (i.e. characteristics of a hypothetical person exposed to a substance) such as body weight, drinking water intake, and soil and dust inhalation [9]. These standard default values are supposedly representative of the “Canadian general population”, but the federal government does not provide guidance on who constitutes the “Canadian general population”, and the use of this term dramatically oversimplifies the diversity within Canadian populations and subpopulations. This approach for assessing exposure raises various concerns, including the use of aggregated, outdated data and data from other countries with significantly different demographics. The use of aggregated data (i.e. data representative of the “general population”) conceals health inequities by assuming that exposure will be the same across all subpopulations.
Risk management measures are inadequate for protecting vulnerable populations
Risk management measures place responsibility on the consumer
Currently, industries/producers are not required under CEPA to identify hazardous substances in their labelling [10]. This prevents consumers from being able to make informed purchasing decisions, and the commercial availability of products which contain but do not identify toxic substances suggest to consumers that they are safe to use. The chemicals management approach places the burden on the consumer to ensure that the products they are using are safe, which individualizes responsibility and relies on personal strategies of precautionary consumption and distracts from higher level policy and legislative change [11]. Further, consumers bear the burden of having to scour government publications for information surrounding the risks of toxic substances, which raises access to information concerns, especially for communities with reduced access to the internet, lower literacy rates, or language barriers.
Risk management measures do not promote access to justice
Access to justice is increasingly difficult for victims of toxic exposures, particularly for victims of chronic exposure and vulnerable groups. Obstacles include information asymmetries, power imbalances, limited availability of class actions and legal aid, and financial burden of court processes. Court processes are only a viable option for those with adequate financial resources; those that can’t afford it can’t pursue legal avenues, which further embeds them in vulnerable positions [12].