WANNABE TOXIC FREE 2024: A Reflection

“The fair and its planning provided a transformative experience where we began to reimagine our connection to the environment, ourselves and each other”

Reflection by Lizramona Mwakitwange, originally published by Trinity College

Trinity College’s Integrated Sustainability Initiative hosted Women’s Healthy Environments Network (WHEN) in their largest Wannabe Toxic Free (WTF): Awareness, Agency, and Collective Action fair on January 26, 2024 at the College. Led by Honour Stahl (WHEN Executive Director and Trinity’s Ethics, Society & Law program graduate) and Professor Nicole Spiegelaar (Academic Director of the Integrated Sustainability Initiative), the fair brought together a diverse set of educators, students, activists, and local businesses to raise awareness on the intersectional effects of environmental risk on women’s health, as well as ways to address them.

In her opening remarks, Honour encouraged us to recognize the unfortunate reality that in over 25 years, the environmental health challenges highlighted by WHEN, such as a lack of concrete toxic regulation, have not been acted upon. Despite this, she encouraged us to see this “as an opportunity for us to pick up the torch and move through this challenge together.”

Having volunteered with WHEN for close to a year now, I have had the pleasure of witnessing exactly this. The WTF event marked a culmination of efforts by WHEN’s dedicated staff, volunteers and friends, many of whom are students involved with Trinity’s Integrated Sustainability Initiative and the School of the Environment. The fair and its planning provided a transformative experience where we began to reimagine our connection to the environment, ourselves and each other – not as separate experiences, but as fundamentally connected pursuits of community and holistic health that are informed by intersectional feminist thinking.

These sentiments were especially evident through the panel discussion as well as the unique student art pieces performed and displayed throughout the hall, which invited participants to think about the manifestation of environmental injustice in the lives of our diverse community. These did not serve as merely academic, aesthetic and acoustic achievements, but unapologetic windows into deeply personal interpretations of what it means to truly respect nature: not as a source of material wealth, but as an entity that speaks to our responsibility to care and practice empathy and solidarity with the most vulnerable people in our communities, including the women and gender diverse people who are victims of environmental and social injustice.

In the words of Professor Nicole Spiegelaar: “The toxic environments we are living in are not separate from the toxic patterns of thought and practices of colonization in Canada.” Cultivating this way of thinking about environmental injustices has been an essential part of enriching my educational experience at the University of Toronto, allowing me to occupy space with intentional consideration of my feelings, recognizing the ways in which I react to my environment and how I can transform these into actions toward building a more sustainable future for myself and my community. As a racialized woman, this has been a truly empowering experience for myself, especially having lived in a world where I have witnessed far too many marginalized individuals be shamed for being “too emotional” or “irrational” in circumstances where we seek to be heard, which discredits our lived experiences.

Many of the people involved with WHEN come from diverse cultural, academic and professional backgrounds. My involvement with the organization and the WTF fair has grounded me with a deep reverence for community and leaning into spaces that support and uplift my voice, allowing me to extend this same grace within and beyond WHEN. For myself as well as Alicia Luboch and Nicole Nicola, other incredibly passionate students who I have connected with through WHEN and the Margaret MacMillan Trinity One Program, this has meant founding and leading a WHEN Student Club here at the University of Toronto. With this platform, we seek to mobilize women and gender diverse youth as catalysts for change toward toxic-free and healthier environments for all people. We are excited about the possibility of amplifying the discussions from the WTF fair and transforming these into consistent conversations within our student community.

Visit our Arts & Community Events Page to learn more about WTF.

Lizramona Mwakitwange is a WHEN Volunteer and leader of the WHEN Student Club at UofT. She is an undergraduate student at Trinity College who is double majoring in Health & Disease and Environment & Health, with a Certificate in Sustainability. Lizramona is a graduate of the Butterfield Environment & Sustainability stream of the Margaret MacMillan Trinity One program and involved with the Food Systems Lab and Trinity’s Integrated Sustainability Initiative.

Case study: the mismanagement of Talc under the Canadian Environmental Protection Act

Case study: the mismanagement of Talc under the Canadian Environmental Protection Act

This blog post was written by Kanisha Acharya-Patel, WHEN’s Law Reform Specialist, and Zeina Seaifan, WHEN’s Policy Engagement Researcher, 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.

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. CEPA was recently amended for the first time since 1999, through Bill S-5, which was passed in June 2023 (see more about WHEN’s involvement in the legislative process here). This blog post explores how the regulation of talc under CEPA has failed to protect the health of women and other vulnerable populations by failing to consider how one’s identity factors, such as sex, gender, and socioeconomic status can affect one’s exposure to talc and susceptibility to adverse health effects from exposure.  

What is talc? 

Talc is a naturally occurring mineral and may be used in a variety of products in Canada including paper, plastics, paint, ceramics, putties, drugs, natural health products and cosmetics. Talc is an ingredient in approximately 6,500 cosmetic products in Canada (as of 2017) [1]. 

Is talc toxic?

Yes. In 2021, talc was added to the list of toxic substances under CEPA because the federal government concluded that talc constitutes a risk to human health. Under s. 64 of CEPA, a substance is toxic if it is entering or may enter the environment in a quantity or concentration or under conditions that (a) have or may have an immediate or long-term harmful effect on the environment or its biological diversity; (b) constitute or may constitute a danger to the environment on which life depends; or (c) constitute or may constitute a danger in Canada to human life or health. 

What are the government of Canada’s conclusions for the critical health effects associated with talc?

The risk assessment of talc as a toxic substance describes its critical health effects as:

(1)  Non-cancer lung effects (ex. inflammation, impaired lung function, fibrosis) following inhalation of fine particles of talc when using loose powder products like baby powder, body powder, and loose face powder; and

(2)  Ovarian cancer due to exposure of the female perineal (genital) area to products containing talc such as body powder, diaper and rash creams, baby powder, genital antiperspirants and deodorants, body wipes, bath bombs and bubble bath.

The government of Canada’s proposed human health objective (i.e. quantitative/qualitative statements of what should be achieved to address human health concerns) is to decrease inhalation and perineal exposures from certain talc-containing self-care products to a level which is protective of human health. 

Why does Gender-based Analysis Plus (GBA+) matter in the context of toxic substance management?

The Government of Canada’s approach to regulating talc as a toxic substance demonstrates how the current risk assessment and risk management processes do not adequately consider vulnerable populations (specifically women) and highlights the need to integrate an intersectional analysis (i.e. GBA+) into these processes. Currently, decisions surrounding the permissibility of substances to enter the environment are based on standard default estimates of exposure that are representative of the “general population”, rather than being specific to the threats facing populations that are more vulnerable than the general population [2]. Canada defines a vulnerable population as a group of individuals within the Canadian population who, due to greater susceptibility or greater exposure, may be at an increased risk of experiencing adverse health effects from exposure to substances. One’s identity factors, such as sex, gender, race and socioeconomic status either alone or in tandem (i.e. intersectionality) can impact their susceptibility or exposure and therefore increase their vulnerability. By failing to consider the impact of intersecting identity factors when assessing and managing toxic substances (and therefore failing to apply GBA+), the government risks missing or misreading the experiences of a significant portion of the Canadian population and subsequently developing policies and initiatives that can inadvertently increase inequities [3]. By assuming that everyone is exposed to the same amount of a toxic substance and experiences adverse health effects from the same dose of talc exposure, the risk assessment and management processes do not account for how physiological and socio-environmental differences can impact exposure and susceptibility. This perpetuates health inequities against populations that are more vulnerable than the “general population”.   

Which identity factors can increase the risk of experiencing adverse health effects from exposure to talc? 

Examining an individual’s risk of talc exposure through the lens of GBA+ reveals that exposure and susceptibility to adverse health effects from talc are dependent on various intersecting identity factors including sex, gender, age, and socioeconomic status. If these factors were considered in the risk assessment and risk management approaches for talc, many exposures and health harms from talc could have been prevented. 

Sex

Health Canada’s risk assessment notes there is a “consistent and statistically significant positive association between perineal exposure to talc and ovarian cancer” and concluded that this is a “potential concern for human health” [4]. This means that women/people with ovaries are inherently more susceptible to ovarian cancer from perineal exposure to talc. In addition to perineal exposure, talc particles may translocate to the ovaries following inhalation of fine talc particles [5]. This is a physiological, sex-based difference, as people with ovaries are more vulnerable to harm from talc exposure than the general population. Despite recognizing the link between perineal exposure to talc and ovarian cancer, Health Canada’s risk assessment was restricted to “available information” and did not conduct further research or studies regarding the toxicokinetics of talc particles following perineal exposure. Toxicokinetics refers to how the body processes a chemical, including absorption (how the chemical gets absorbed into the body), distribution (where the chemical goes inside the body), metabolism (how the chemical breaks down in the body), and excretion (how the chemical leaves the body). One’s sex influences toxicokinetics [6], and given the link between perineal exposure and ovarian cancer, limiting the risk assessment to “available information” reduces its comprehensiveness. 

Gender

The distinction between gender and sex speaks to the distinction between exposure and susceptibility [7]. As mentioned above, sex-based differences (such as presence of ovaries) makes one more susceptible to experiencing adverse health effects (i.e. ovarian cancer). Gender, however, affects the presence of exposure: personal care products are disproportionately marketed towards and used by women, many of which contain toxic substances including talc. These products include face makeup, bath bombs, genital antiperspirants and hair removal products, and range in talc concentration from 1% to 100% [8]. A young woman in her teens may feel social pressure from conventional beauty norms to remove hair in her genital area. She could easily find Veet hair removal cream (contains talc) at her local drugstore or online and would not be aware of the dangers of its use because the product is not required to have a cautionary statement indicating the association between perineal exposure to talc and ovarian cancer. She may also feel pressured to purchase face makeup, which increases risk of talc inhalation and related health effects (such as reduced lung function). Further, gender norms regarding which parent is responsible for child-care can exacerbate a woman’s exposure to talc via inhalation if she applies talc-containing baby powders when diapering her children. 

Age 

Baby powder products can contain up to 100% talc and are used in the perineal region of infants during diapering, and talc is permitted as a medicinal ingredient in diaper rash products at concentrations from 45% to 100% [9]. This means that infants and children are at greater risk of exposure to talc, both through inhalation and perineal exposure, and experiencing related adverse health effects. For infants assigned female at birth, this also inherently increases their risk of ovarian cancer, because talc use during diapering can result in talc particles in the ovaries [10]. Infants and children are further embedded in positions of vulnerability by the fact that they do not have their own agency to decide what products they are exposed to. Health Canada acknowledged that inhalation of talc can negatively affect lung health, even after a single exposure event, as reported in a 10-year-old child who was exposed one time at 2 years of age and a 7-year-old child who developed asthma and reduced lung function [11]. Vulnerability to adverse health effects from inhalation or perineal exposure to talc can be compounded if exposure occurs during a critical window of vulnerability, such as infancy, puberty, pregnancy, lactation, and menopause [12]. This demonstrates the importance of considering the intersection of identity factors: a pubescent girl (or person with ovaries) using a hair removal cream on her perineal area (due to gender norms) is even more vulnerable to harm due to her age, sex and gender. 

Socioeconomic status 

Low socioeconomic status can severely impede one’s ability to purchase and use high-quality talc-free products. Cheaper products may fail to use cosmetic-grade talc and instead, their products may carry additional impurities such as asbestos contamination. Canada’s risk assessment of talc only focused on inhalation and perineal exposure to self-care products containing cosmetic or pharmaceutical-grade talc (i.e. pure talc) [13], which fails to consider potential additional impurities such as asbestos (a known carcinogen) which is found naturally near talc. As many talc-containing cosmetic products have tested positive for asbestos including compact powders, eye shadows, contour palettes, and even children’s makeup [14], underestimating the possible contamination of talc undermines the strength and effectiveness of the risk assessment process. 

How does Canada’s approach to talc risk management neglect these considerations?

The risk management actions for talc are measures to help reduce exposures to talc from certain cosmetics, natural health products and non-prescription drugs which may be inhaled or which may result in perineal exposure [15]. Measures to achieve these objectives include reading product labels and follow all safety warnings and directions, avoid inhaling loose talc powder, avoid female genital exposure to talc, and choose a talc-free alternative, all of which emphasize individual responsibility and place the burden of reducing talc exposure on consumers. Additionally, many talc-containing products lack any form of hazard labelling or cautionary statements, making it more difficult to make informed purchases. This is especially true for people with ovaries, as the risk management approach requires powder-based products to include cautionary statements (i.e."Keep out of reach of children" and "Keep powder away from child's face to avoid inhalation which can cause breathing problems" [16,17]), but does not require cautionary statements regarding the risk of ovarian cancer. It is unclear why, despite concluding that perineal exposure to talc can cause ovarian cancer, Health Canada decided that hazard labelling regarding this serious health risk was not required. This may change, however, as Health Canada updated talc restrictions in May 2024: talc is “no longer permitted in products intended solely for use in the genital area of those who have ovaries” and “products that could come in contact with the genital area (for example, diapering products, body powder, bath products)" must include the following cautionary statement: "Do not use in the genital area of those who have ovaries". These new restrictions are a step in the right direction, but they are far from perfect and it’s still unclear when they will come into effect or how they will be enforced, so we are cautious with our optimism. 

Individualizing responsibility can further entrench people in positions of vulnerability as people widely vary in their capacity to engage in precautionary talc consumption due to a variety of identity factors, including education, access to information, language barriers and/or literacy constraints. Failure to develop adequate risk mitigation measures, including hazard labelling specific to ovarian cancer, has likely resulted in many preventable talc exposures. Further, the draft risk management approach for talc identified a third risk management action (“communications to the public to help avoid inhalation and perineal exposure to talc”) but this action was not included in the final risk management approach. Given this action’s emphasis on increasing public awareness, its exclusion from the final risk management approach is problematic and sends the message that it is the responsibility of the individual consumer to scour Health Canada’s publications to learn of the adverse health effects of talc.

WHAT CAN YOU DO?

1. Help us get talc out of our personal care products!

   We continue to urge the federal government to ban talc (specifically in products that can be inhaled or used in the perineal area) or at the very least, require transparent communication of the health risks through hazard labelling. Support our advocacy by signing this petition! 

2. Look out for talc

   or magnesium silicate – on the ingredient list of your personal care products, especially products that can be inhaled or used in the perineal area such as body/facial powders, bath bombs, genital antiperspirants and hair removal creams. Avoid these products if you can! 

3. Use talc alternatives

   when possible, such as cornstarch or arrowroot powder; many companies have released products that use these safer alternatives. 

4. Raise awareness

   Share this post and tell your friends and families about the negative health effects of talc.

   Knowledge is power! 

Can Canada be held accountable for their GBA+ commitments?

Can Canada be held accountable for their GBA+ commitments?

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.

Need a refresher on Gender-based Analysis Plus (GBA+)?

Please check out our Explainer on GBA+! In short, 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. The ‘plus’ in GBA+ acknowledges that the analysis 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 [1]. The government of Canada is currently considering rebranding GBA+ as Gender and Diversity Analysis to reinforce the intersectional purpose of the tool [2,3]. In the context of toxic substance management under the Canadian Environmental Protection Act (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), GBA+ allows us to identify and address inequities faced by women and other vulnerable populations due to their intersecting identity factors.

What are Canada’s GBA+ commitments?

In 1981, the federal government of Canada signed onto the United Nations (“UN”) Convention on the Elimination of All Forms of Discrimination Against Women. At the 4th UN World Conference on Women (1995), Canada signed the Beijing Declaration and Platform for Action and committed to conducting GBA on all future legislation, policies, and programs. GBA has since been expanded to GBA+ to require the consideration of diverse and intersecting identity factors (i.e. not just sex and gender) [4]. Canada’s commitments are outlined in its Policy on GBA+, which makes it clear that GBA+ must be integrated throughout the development of a federal initiative, and during the implementation and monitoring phase, to ensure GBA+ outcomes are achieved. For more information and a timeline on Canada’s GBA+ commitments, please see the following:

• Timeline: WAGE Milestones

• Summary of Government of Canada and Justice Canada GBA+ Commitments

• History of GBA+ 

• GBA+ Roles and Responsibilities

Who is responsible?

Women and Gender Equality Canada (federal department) is the “centre for expertise for advancing gender equality and supporting the application of GBA+ across government decision-making processes” [5]. That being said, all federal departments share the responsibility of implementing GBA+ and GBA+ must be conducted for all federal government initiatives; even if there is no obvious connection between the initiative and identity factors such as sex, gender or race, it is important to conduct GBA+ regardless because there may be unexpected impacts on vulnerable populations [6]. It’s important to note that these commitments do not extend to the provincial or territorial governments, which means that many decisions impacting Canadians are not required to be analyzed through the GBA+ lens. 

Are the commitments legally binding? 

Many of Canada’s GBA+ commitments are stated in policy documents, which are not legally binding and therefore not enforceable [7]. Canada’s international GBA+ commitments (i.e. the commitments made by signing onto the UN Convention on the Elimination of All Forms of Discrimination Against Women) are only enforceable if they are codified in a domestic legal instrument, such as a federal law. For example, GBA+ is a required consideration for decision-making under key federal legislation, including the Canadian Gender Budgeting Act, the Impact Assessment Act, the Immigration and Refugee Protection Act, and the Accessible Canada Act, but these obligations fall outside the scope of this blog post. GBA+ is not currently a required consideration for decision-making under the Canadian Environmental Protection Act, which means that an intersectional approach is not legally required when the federal government is assessing and managing the risks associated with toxic substances. 

There are also a few legally binding GBA+ requirements that the federal government must comply with when developing legislation, policies and programs. Specifically, federal departments and agencies are required to integrate GBA+ into all budget proposals, regulations, Treasury Board (TB) submissions and Memoranda to Cabinet (MC). These documents are used to seek approval from various government oversight bodies when developing and implementing proposed laws, policies and programs, and are tangible documents that can prove whether the government is following through on their GBA+ commitments.

Can Canada be held accountable for the legally binding commitments? 

On paper, all federal departments are required to “apply GBA+ in the decisions [they] make and consider public policies through an intersectional lens in order to address systemic inequities” [8]. However, in practice, government decision-making is often shielded from public scrutiny and there are limited avenues for the public to attempt to hold Canada accountable. Even where the requirement to conduct GBA+ is stated in a federal law and thus legally binding, enforcement by members of the public is difficult because of the many obstacles inherent in our legal processes, such as the cost of hiring legal representation, and the fact that decision-makers are granted a level of discretion in their decision-making. Decision-makers have been criticized for treating GBA+ as an afterthought or “box-checking exercise” [9], but checking the box is sufficient for the decision-maker to technically meet their legal obligations. Performative GBA+ does not accomplish its purpose in “ensuring that none of the diverse people encountering Canadian federal policies and programs are unintentionally harmed by them or excluded from them” [10], but is often sufficient to protect decision-makers from accountability. 

Members of the public are also limited in their ability to hold decision-makers accountable because of the difficulties associated with accessing information (ex. documents that show how GBA+ was conducted). Under the Access to Information Act and the Privacy Act, you have the legal right to obtain information that is under the control of a government institution. The purpose of these acts is to make government more open and transparent, and make sure citizens have the information required to participate meaningfully in the democratic process and that decision-makers remain accountable to the public [11]. However, accessing government documents through these acts is a long and tedious process, and many documents are inaccessible due to a concept called Cabinet Confidentiality. 

The idea behind Cabinet Confidentiality is that all Cabinet Ministers (i.e. people appointed by the Prime Minister to manage a specific government department) are collectively responsible for actions taken by the Cabinet (i.e. political forum in which ministers meet to establish consensus on government action) and must publicly support all Cabinet decisions. To reach final decisions, Ministers must be able to express their views freely and know that these discussions will be protected, and allowing these views and opinions to be disclosed publicly would result in the erosion of the collective responsibility of ministers (i.e. would disrupt the image of a united front) [12]. Documents protected by Cabinet Confidentiality are called Cabinet Confidences. MCs and TB submissions are two examples of Cabinet Confidences [13], meaning that the public does not have the right to obtain access to them and therefore can generally not use them to assess the government’s compliance with its GBA+ commitments. There are ways for the government to be more transparent about their application of GBA+ while respecting Cabinet Confidentiality, such as publishing GBA+ analysis after the decision on the proposed initiative has been made [14], and we encourage the federal government to explore these options. 

Explainer: What is Gender-Based Analysis Plus (GBA+)?

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].

Those scented candles you love are not healthy

Those scented candles you love are not healthy

By WHEN Team Members: Anuja Purohit & Zeina Seaifan  Opinion | October 24th 2023

As October brings with it Breast Cancer Awareness Month, many of us are thinking about ways to embrace the season by engaging with overall wellness. Scented candles frequently find their way into our homes this time of year, but could be leading us down a path of potential adverse health effects.

Over the past few years, consumers' interest in scented candles has exploded with an emphasized shift from candles for décor to wellness purposes. Categorized with other “wellness” trends such as supplements and chia seeds, it is worth wondering at what point the fixation with the “clean girl esthetic” and wellness practices is rooted in this notion of being “unwell.”

In the 1950s, Dr. Halbert L. Dunn coined the term wellness, from which terms of health, well-being and wellness have distinctly been drawn. However, through the now estimated over $4-trillion industry, this image-conscious version of health has transformed into something that likely surpassed its originator’s initial vision.

Scented candles can have adverse effects on health, particularly for AFAB (assigned female at birth) or those with ovarian reproductive systems. Scented candles are comprised of chemicals, including volatile organic compounds (VOCs) and phthalates, which are used to prolong the fragrance’s longevity. Phthalates are known endocrine disruptors that can disrupt hormone balance and lead to conditions like breast cancer, endometriosis miscarriage and reproductive harm. Gender norms and “wellness” marketing put women at higher risk of chemical exposure from wellness items, personal care products and markedly, scented candles.

Scented candles can also have a wide-reaching environmental impact. Most conventional candles are made from paraffin wax. This is a petroleum waste product that is chemically bleached and derived from crude oil, which creates highly toxic benzene and toluene when burned (both are known carcinogens on the list of toxic substances managed by the Canadian Environmental Protection Act).

Robert Crawford in the 1980s devised the term healthism at a time when illness was regarded as a personal responsibility. Cancer, diabetes and heart attacks were typically attributed to individual responsibility, rather than any potential environmental factors. As such, you did not have to worry about falling ill due to external factors beyond your personal control.

Healthism questioned this presumption of individualism, through everyday products such as scented candles, as a remedy for being “unwell.” It is worth noting, however, that many environmental factors are presently still not explored and considered in the majority of health cases. By illuminating the health risks associated with candles, we draw attention to the broader issue of environmental factors frequently overlooked in health care.

Unfortunately, the burden of purity politics is on the consumer to recognize the harmful effects of scented candles. Calls to opt for natural alternatives, such as beeswax or soy candles, can significantly reduce the negative impact on women's health and the environment, but often come with higher price tags, positioning them as items of indulgence rather than necessity and further perpetuating existing inequalities.

Here, classist ideals emerge through exclusivity. The luxury attached to esthetic candles reinforces the idea that certain sensory experiences are reserved for those who can afford them. The cultural value placed on creating a specific atmosphere or lifestyle through esthetics contributes to an environment where the ability to curate such experiences is perceived as a mark of higher social standing.

Governments and regulatory authorities have a crucial role to play in safeguarding the environment and public health. In Canada, one in eight women will be diagnosed with breast cancer in their lifetime. Preventing toxic exposures starts with stringent regulations on toxic substances to remove the burden of prevention from the consumer.

With the recent passing of Bill S-5, an act to amend CEPA and strengthen toxics regulations, this may be possible sooner rather than later. But there is still a long way to go before toxic fragrances and candles get swiped off the shelves.

While “wellness” practices have their place, it is important to critically reflect on how much of this is driven by profit, and, ironically, identify the potential health risks of “wellness culture” and the risks it poses on particular populations. Health, healthism, well-being and wellness are not synonyms. As the “dose makes the poison,” a glut of wellness may eventually lead to unwell practices.

Anuja Purohit is a law student at the University of Ottawa Faculty of Law / Common Law. She has completed her Honours Bachelor of Arts in Political Science with a minor in Environmental Studies (Wilfrid Laurier University) and a Masters of Environment and Sustainability (University of Toronto).

Zeina Seaifan is a recent master's graduate at the University of Toronto, where she specialized in environmental and social sustainability.