Indigenous Communities' Disproportionate Exposure to "Forever Chemicals"

ADDRESSING TOXIC RACISM: BILL C-226 AND INDIGENOUS COMMUNITIES’ DISPROPORTIONATE EXPOSURE TO “FOREVER CHEMICALS”

This blog was written by Lily Farinaccio as part of the Community Research Partnerships in Ethics (TRN407Y1) between Trinity College at the University of Toronto and WHEN under the supervision of Professor Nicole Spiegelaar. For the purposes of this blog post, the term “women” is used to describe those with ovarian reproductive systems. This is not to marginalize bodies that identify as women and do not possess these reproductive systems. Rather, it is intended to highlight how these chemicals differentially interact with certain bodies, creating sex-specific consequences.


Indigenous communities – particularly Indigenous women – face a disproportionate risk of exposure to “forever chemicals” and their health effects. Proposed Bill C-226 offers an important start to tackling cases of environmental racism such as this, but what is needed for its effective implementation?

WHAT IS ENVIRONMENTAL RACISM?

Environmental racism is a form of inequality whereby racialized communities are disproportionately impacted by polluting industries, toxins, and associated health conditions (Waldron, 2018). There are many instances of environmental racism in Canada. One example is the disproportionate exposure to per- and polyfluoroalkyl substances (PFAS), or forever chemicals, faced by Indigenous peoples. 

WHAT ARE PFAS?

PFAS are a group of thousands of synthetic chemicals with grease, heat, and water-resistant properties (Park et al., 2019). They’re used in various industrial applications and consumer products, including non-stick cookware, carpeting, apparel, upholstery, food packaging, firefighting foams, and personal care products (Park et al., 2019; Person and Renfrew, 2024). 

From an environmental health perspective, PFAS are strikingly troublesome. They resist natural processes of degradation and are persistent in the environment and the human body, earning the name forever chemicals (Garcia-Barrios, 2021). They’re also associated with a wide range of health effects, including: 

  • Endocrine, liver, and immunological effects 

  • Thyroid disease

  • Cancers

  • Developmental issues

  • Decreased fertility 

  • Asthma 

  • Decreased vaccine response 

  • Pregnancy-induced hypertension

  • Hypercholesterolemia 

  • (CELA, 2021; Pearson and Renfrew, 2024)

HOW ARE INDIGENOUS COMMUNITIES DISPROPORTIONATELY AFFECTED? 

While all Canadians are routinely exposed to PFAS, several studies have found elevated levels among Indigenous communities (Aker et al., 2023; Caron-Beaudoin et al., 2020; Caron-Beaudoin et al., 2019; Dubeau et al., 2022; Garcia-Barrios et al., 2021). For example, a recent study on First Nations communities in Québec found that concentrations of the forever chemical, perfluorooctanoic acid (PFNA), were 21 times higher than levels in the general Canadian population (Dubeau et al., 2022).

There are a number of potential reasons for these increased PFAS levels. Notably, the consumption of traditional foods such as fish and caribou has been highlighted as a primary exposure pathway for Indigenous communities. This is due to forever chemicals’ ability to bioaccumulate in marine and terrestrial food webs (Aker et al., 2023). 

Given that the consumption of traditional foods has been described as one of the strongest links between Indigenous culture, health, and their environments, the presence of PFAS in traditional food sources is significant: it forces Indigenous communities to make trade-offs between their culture and health. Not only are PFAS harming Indigenous bodies, they’re also forcing Indigenous peoples further from their culture. 

WHAT ARE THE SPECIFIC EFFECTS ON INDIGENOUS WOMEN? 

Forever chemicals are associated with sex-specific health effects. These include fertility complications, such as endometriosis, PCOS, and decreased fertility, as well as the development of melanoma and breast cancer (Cathey et al., 2023; Kim et al., 2020; Mancini et al., 2020; Omoike et al., 2021; Tsai et al., 2015). Given that Indigenous women are at increased risk of exposure to PFAS, they’re at even greater risk of suffering these severe and potentially lethal consequences.  

Indigenous women also bear a disproportionate burden in managing the transmission of PFAS and the related health problems. Mothers can transfer around 40% or more of their PFAS body burden to their infants. Forever chemicals can also be transmitted to children during breastfeeding (Rickard et al., 2022). What’s more, the presence and transmission of PFAS during pregnancy and infancy are associated with various health impacts in children, including suppressed immune responses during childhood, low infant birth weights, and neurotoxic outcomes, such as decreased executive function and lower verbal IQ (Caron-Beaudoin et al., 2020; Rickard et al., 2022).

WHAT IS BILL C-226? 

Bill C-226: An Act Respecting the Development of a National Strategy to Assess, Prevent, and Address Environmental Racism and to Advance Environmental Justice – introduced by Green Party MP Elizabeth May in February 2022 – is legislation targeted at addressing and preventing the unequal environmental harms racialized individuals currently face in Canada. As of October 2023, the bill completed its second reading in the Senate. Once it passes its third reading, it will require the federal government to create a national strategy to address environmental racism. The strategy would include a study investigating the links between race, socioeconomic status, and environmental risk, as well as possible measures to both prevent and address environmental racism. The bill also features a section on consultation, emphasizing that, in formulating the strategy, the Minister of Environment must consult with relevant stakeholders, including Indigenous peoples (Bill C-226). 

Bill C-226 marks an important step towards addressing environmental injustices that cause severe harm among racialized communities across Canada, such as the disproportionate PFAS exposure faced by Indigenous peoples and Indigenous women. Looking forward, it is crucial we think about how it can be implemented effectively. To learn more about WHEN’s recommendations pertaining to the National Strategy, we encourage you to review our submission to the Senate Committee on Energy, the Environment and Natural Resources.

HOW CAN WE EFFECTIVELY IMPLEMENT IT?

MEANINGFUL INDIGENOUS INVOLVEMENT 

To ensure Bill C-226’s efficacy, the involvement of Indigenous communities can’t be performative. When Indigenous peoples aren’t meaningfully involved in decision-making processes, it results in solutions imposed by outsiders that are both inappropriate for and unwelcomed by the community (Black and McBean, 2016). 

Three ways to foster meaningful engagement of Indigenous communities in Bill C-226’s implementation are to:

  • Address the power dynamics in policy making

    • In policy, there’s an inherent power differential between the Canadian government and Indigenous communities. Indigenous peoples are often one of the only Indigenous individuals in the room, working within a colonial government system (Fridkin et al., 2019). When applying Bill C-226, there’s a need to address the power imbalances between the Canadian government and Indigenous communities.

  • Move beyond tokenism

    • Within Canadian policy making, there’s a tendency for Indigenous communities to be involved in tokenistic ways (Fridkin et al., 2019). Meaningful Indigenous involvement in the implementation of Bill C-226 requires moving beyond tokenism and fostering engagement that’s Indigenous-led.

  • Incorporate traditional knowledge

    • Research shows that when traditional knowledge is included in policy development and implementation, it allows for Indigenous participation in decision-making, recognizes the inherent rights of Indigenous peoples, and helps move towards self-determination (Black and McBean, 2016). Traditional knowledge can be used alongside data collection in developing the national strategy, based on what Indigenous peoples consider appropriate.  

CONSIDERING INTERSECTING IDENTITY FACTORS 

In addition to the meaningful involvement of Indigenous communities, Bill C-226 must also consider the impacts of various identity factors, such as sex and gender. These factors intersect with experiences of environmental racism, as highlighted with the case of PFAS exposure among Indigenous women. Because a singular approach doesn’t take into account the disproportionate harm faced by certain individuals, it will limit Bill C-226’s ability to fully address environmental racism.
This can be avoided by applying Gender-Based Analysis Plus (GBA+). GBA+ is a framework used by the Canadian government to understand the potential impacts of a government initiative on a diverse range of individuals by taking sex, gender, age, disability, education, etc. into account (Acharya-Patel, 2022; Women and Gender Equality Canada, 2022). Using GBA+ when implementing Bill C-226 will make sure the national strategy doesn’t neglect how identity factors such as sex complicate experiences of environmental racism. Given the potential of Bill C-226, these recommendations are important to consider as it advances through the legislature.

Read the full report here

WHAT YOU CAN DO

  1. Sign this petition to get Bill C-226 passed: https://davidsuzuki.org/action/support-a-canadian-environmental-justice-law/

  2. Sign this petition to demand a comprehensive ban on PFAS: https://act.environmentaldefence.ca/page/129061/action/1?ea.tracking.id=homepage

  1. Raise awareness: Share this post and tell your friends and families about Bill C-226, environmental racism, and PFAS exposure among Indigenous communities. Knowledge is power!


References

Acharya-Patel. (2022). Gender-Based Analysis Plus: A Framework for Implementing CEPA

Commitments to Vulnerable Populations. Women’s Healthy Environments Network. 

Aker, Amira, et al. (2023). Plasma concentrations of perfluoroalkyl acids and their 

determinants in youth and adults from Nunavik, Canada. Chemosphere, 310. 

Bill C-226, An Act Respecting the Development of a National Strategy to Assess, Prevent,

and Address Environmental Racism and to Advance Environmental Justice, Second Reading, February 2, 2022, 44th Parliament, 1st session. Retrieved from the Parliament of Canada website: https://www.parl.ca/legisinfo/en/bill/44-1/c-226.

Black, Kerry, and McBean, Edward. (2016). Increased Indigenous Participation in

Environmental Decision-Making: A Policy Analysis for the Improvement of Indigenous Health. The International Indigenous Policy Journal, 7(4).

Canadian Environmental Law Association (CELA). (2021). It’s Raining ‘Forever Chemicals’

Across the Great Lakes: Why PFAS Is Now a Public Priority for Elimination Across Canada. Canadian Environmental Law Association.

Caron-Beaudoin, Élyse, et al. (2020). Perfluoralkyl acids in pregnant women from Nunavik

(Québec, Canada): Trends in exposure and associations with country foods consumption. Environment International, 145. 

Caron-Beaudoin, Élyse, et al. (2019). Exposure to perfluoroalkyl substances (PFAS) and

associations with thyroid parameters in First Nation children and youth from Quebec. Environmental International, 12, 13–23. 

Cathey, Amber, et al. (2023). Exploratory profiles of phenols, parabens, and per- and poly-

fluoroalkyl substances among NHANES study participants in association with previous cancer diagnoses. Journal of Exposure Science and Environmental Epidemiology, 33, 687–698. 

Dubeau, Claudelle, et al. (2022). Perfluoroalkyl acid and bisphenol-A exposure via food

sources in four First Nation communities in Québec, Canada. Public Health Nutrition, 29(1), 106–121. 

Fridkin, Alycia, et al. (2019). The RIPPLES of Meaningful Involvement: A Framework for

Meaningfully Involving Indigenous Peoples in Health Policy Decision-Making. The International Indigenous Policy Journal, 10(3).

Garcia-Barrios, Joshua, et al. (2021). Biomarkers of poly-and perfluoroalkyl substances

(PFAS) in Sub-Arctic and Arctic communities in Canada. International Journal of Hygiene and Environmental Health, 235, 1–9.  

Kim, Young Ran, et al. (2020). Per- and poly-fluoroalkyl substances (PFAS) in follicular fluid

from women experiencing infertility in Australia. Environmental Research, 190. 

Mancini, Francesca, et al. (2020). Perfluorinated alkylated substances serum concentration

and breast cancer risk: Evidence from a nested case-control in the French E3N cohort. International Journal of Cancer, 146, 917–928. 

Omoike, Ogbebor, et al. (2021). A cross-sectional study of the association between

perfluorinated chemical exposure and cancers related to deregulation of estrogen receptors. Environmental Research, 196. 

Park, Kyun et al. (2019). Determinants of per- and polyfluoroalkyl substances (PFAS) in

midlife women: Evidence of racial/ethnic and geographic differences in PFAS exposure. Environmental Research, 175, 186–199. 

Pearson, Thomas, and Renfrew, Daniel. (2024). When Toxic Heritage Is Forever: 

Confronting PFAS Contamination and Toxicity as Lived Experience. In Elizabeth Kryder-Reid & Sarah May, Toxic Heritage: Legacies, Futures, and Environmental Injustice (pp. 50-61). Routledge. 

Tsai, Meng-Shen, et al. (2015). Association between perfluoroalkyl substances and

reproductive hormones in adolescents and young adults. International Journal of Environmental Health, 218(5), 437–443. 

Waldron, Ingrid. (2018). There’s Something in the Water: Environmental Racism in

Indigenous and Black Communities. Fernwood Publishing. 

Women and Gender Equality Canada. (2022). Government of Canada’s Approach on 

Gender-Based Analysis Plus. Government of Canada. https://www.canada.ca/en/women-gender-equality/gender-based-analysis-plus/government-approach.html

The Right to a Healthy Environment: What Does it Mean?

The Right to a Healthy Environment: What Does it Mean?

Blog post 4: The Right to a Healthy Environment: What Does it Mean?

This blog post was written by Kanisha Acharya-Patel, WHEN’s Law Reform Specialist, and the views expressed are not intended as legal advice. 

 The Canadian Environmental Protection Act (CEPA), a federal law dedicated to protecting environmental and human health, was amended in 2023 and now states that everyone has the Right to a Healthy Environment (RTHE): an environment that is clean, healthy and sustainable. However, the substance of this right is still unclear, which raises concerns as to its application and enforceability. The federal government has confirmed that the RTHE will not introduce any new enforcement mechanisms, and will more so be a guiding principle for decision-making under CEPA. This begs the question: if a right can’t be enforced, is it really a right?

Additionally, the RTHE is restricted to CEPA, which means that it will not apply to decisions made under other federal laws or provincial/territorial laws, even though many of those laws have direct impacts on human and environmental health (such as the federal Pest Control Products Act, which regulates pesticides). This restricts the reach of the RTHE, and we urge the government to use the Framework to clarify exactly what the RTHE applies to. 

Compared to the 110+ countries that have enshrined the RTHE in their constitution (which means that it is a fundamental, enforceable right protected by the country’s highest law), Canada’s approach is rather underwhelming. However, despite the limited scope of the RTHE, we are hopeful that its implementation will lead to strengthened decision-making under CEPA that prioritizes people and the planet over profit.

 

HOW WILL THE RTHE BE IMPLEMENTED?

The Minister of Health and Minister of Environment are required to develop an Implementation Framework (Framework) for the RTHE by June 2025. Because the Ministers are required to consult interested parties, grassroots organizations, non-governmental organizations and the public during the Framework development process, this presents a window of opportunity for WHEN to advocate for the RTHE to be implemented in a manner that advances environmental justice for all, including our most vulnerable populations*. 

The requirements for the Framework are set out in s. 5.1 of CEPA. In essence, the Framework must provide a definition of the RTHE, explain how the RTHE will be upheld when making decisions under CEPA (such as deciding whether a toxic substance should be allowed to enter the environment), and outline the mechanisms that will be in place to protect the RTHE (such as avenues for enforcement and studies to monitor the health of the environment). The Framework must also elaborate on how the principles that are meant to inform CEPA decision-making and are key to the RTHE will be applied. These principles include:

  • Environmental justice: the avoidance of adverse health effects that disproportionately affect vulnerable populations

  • Intergenerational equity: meeting the needs of the present generation without compromising the ability of future generations to meet their own needs; and

  • Non-regression: includes the continuous improvement in environmental protection

The federal government’s preliminary discussion document on the Framework was released in February 2024 and included a public comment period until April 8 2024; we encourage you to review WHEN’s detailed comments and recommendations here.

 

THE RTHE MUST BE IMPLEMENTED USING AN INTERSECTIONAL APPROACH

WHEN strongly believes that the Framework must be developed using an intersectional approach, to promote environmental justice. An intersectional approach requires consideration of how the Framework may be understood and experienced by diverse populations differently because of their various intersecting identity factors, such as sex, gender, race, and socioeconomic status. 

This intersectional lens is provided by the gender-based analysis plus (GBA+) methodology, because GBA+ is a process for understanding who is impacted by the issue being addressed (i.e. environmental injustice in the form of an unhealthy environment) and how; identifying how the initiative (i.e. RTHE Framework) could be tailored to meet diverse needs of the people directly impacted (specifically vulnerable populations); and discovering, anticipating and mitigating any barriers to accessing or benefiting from the initiative [1]. 

As mentioned in Canada’s Policy on GBA+, GBA+ goes beyond sex and gender to include consideration of other identity factors (i.e. non-exhaustive list including age, disability and economic status), the context within which people live (i.e. systemic/structural factors), and how these factors can intersect and shape one’s legal, social, health and economic opportunities and barriers to accessing systems, programs or services.

Taking an intersectional approach will allow the federal government to meet their responsibility to administer CEPA in a manner that protects the health of vulnerable populations (i.e. 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). 

As the federal government is required to use the GBA+ framework when developing or implementing government initiatives, WHEN is calling on the federal government to use GBA+ when developing Framework. In accordance with Women and Gender Equality Canada’s guidance on GBA+, the federal government must complete the seven steps required to ensure that the full impacts of the new RTHE are considered.

 

BILL C-226, CANADA’S NEW ENVIRONMENTAL JUSTICE LAW, PROVIDES IMPORTANT CONTEXT FOR THE RTHE

Bill C-226, also known as the National Strategy Respecting Environmental Racism and Environmental Justice Act, requires that the federal government develop a National Strategy to promote efforts across Canada to advance environmental justice and to assess, prevent and address environmental racism. 

The notion of environmental racism comes from the fact that environmentally hazardous sites (including landfills and polluting industries) are established in areas inhabited by members of an Indigenous, racialized or other marginalized community. Environmental justice expert Robert Doyle Bullard summarizes environmental racism as:

  • The disproportionate location and greater exposure of Indigenous and racialized communities to contamination and pollution from polluting industries and other environmentally hazardous activities;

  • The lack of political power these communities have for resisting the placement of industrial polluters in their communities;

  • The implementation of policies that sanction the harmful and, in many cases, life-threatening presence of poisons in these communities;

  • The disproportionate negative impacts of environmental policies that result in differential rates of cleanup of environmental contaminants in these communities; and

  • The history of excluding Indigenous and racialized communities from mainstream environmental groups, decision-making boards, commissions and regulatory bodies [2]. 

Environmental racism therefore plays a large role in the health of one’s environment and should be a central consideration in the development of the RTHE Framework. Because the federal government has stated that input received during engagement on the development of the Framework may be used to inform the development of the National Strategy, we hope that the Framework will outline how decision-making under CEPA, in upholding the RTHE, will address the systemic injustices and structural determinants of health that perpetuate inequities against vulnerable populations. 

The inclusion of the RTHE in CEPA coupled with the mandate to develop the National Strategy under Bill C-226 show that the government recognizes that environmental health risks are not uniformly distributed, which is a step in the right direction. However, if the Framework is not developed in collaboration with affected communities or the substance and enforceability of the RTHE is not expanded upon, the RTHE risks simply being a performative amendment to CEPA that will not meaningfully advance environmental justice in Canada.

 

PROTECTING EVERYONE: WHAT’S NEEDED?

Above all, it is crucial that marginalized communities have a seat at the table when the Framework is being developed, and there is a responsibility for the federal government to actively facilitate and fund participation by populations rendered vulnerable, including but not limited to women*, BIPOC communities, young people, and disabled people. Consultation can only be meaningful if done with the goal of receiving feedback and meaningfully taking steps to address concerns [3]. 

WHEN has submitted detailed comments and recommendations to the government regarding the Framework. In summary, WHEN strongly believes that to better protect vulnerable populations and their RTHE, the Framework must provide:

 

A comprehensive description of the RTHE

Canada has defined the RTHE as the right to an environment that is clean, healthy and sustainable, but has said that the substantive meaning of the right in the CEPA context will be elaborated on in the Framework. The definition must clarify what ‘clean, healthy and sustainable’ means and how it will be upheld in CEPA decision-making or enforced by the public or the courts.

 

An explanation of how the RTHE will improve access to justice

As said by MP Elizabeth May, “a non-enforceable [right to a healthy environment] is a bumper sticker. It is good to have in the bill, and people can point to it and say it is improvement; however, it is not a right if we cannot enforce it”. Currently, legal avenues for the public to hold the government accountable under CEPA have too many obstacles (such as lengthy and costly court procedures and unequal access to legal representation), and we hope the Framework will address these issues.

 

An approach to toxic substance regulation that prioritizes the prevention of harm to human and environmental health

Canada’s approach to assessing and managing the risks of a toxic substance assumes that everyone is exposed to the same amount of a toxic substance, and everyone is equally likely to face the same negative health effects from being exposed. This does not account for how physiological identity factors (such as sex and age) and social/environmental identity factors (such as gender, race, income, and physical location) can make someone more likely to be exposed to a substance or more likely to face negative health effects. 

For example, gendered beauty norms result in women using more personal care products than men and therefore being more exposed to toxic substances. Some of these substances also have sex-specific health effects, such as ovarian cancer, that make people with ovaries more likely to get sick than people without ovaries. These differences need to be accounted for. Given that the RTHE is supposed to advance environmental justice (i.e. the avoidance of adverse health effects that disproportionately affect vulnerable populations), we believe the Framework must explain how toxic substance regulation will be strengthened to better protect our health.

 

Effective communication strategies

Communication strategies must ensure that everyone, including our most marginalized populations, has access to information regarding what the RTHE entails, what government actions it applies to, and how it can be enforced. With the RTHE being a guiding principle for decision-making under CEPA rather than an enforceable right, we are concerned that the government will expect the public to simply trust that their decisions are informed by the RTHE. 

The “trust us, we got it right” approach has been widely critiqued for eroding government accountability, and we believe it is important for the government to be transparent by providing accessible, plain language summaries outlining the reasoning behind their decisions made under CEPA and exactly how the decisions uphold the RTHE. Communication strategies must consider the barriers that may exist for certain individuals seeking to enforce their RTHE, including literacy constraints, language barriers, financial constraints, access to the internet, and access to legal advice or representation.

 

GET INVOLVED

Bill C-226 is in its final stage of the legislative process and will hopefully become law in the near future; we encourage you to show your support for environmental justice by signing this petition calling on the Senate to pass Bill C-226 without delay. To learn more about WHEN’s perspective on Bill C-226, please review WHEN’s brief that was submitted to the Senate Committee on Energy, the Environment and Natural Resources for their consideration. 

 One of the primary organizations WHEN is collaborating with on the RTHE is Shake Up The Establishment: a non-partisan, youth-led, registered organization that aims to make credible, evidence-informed information readily available to the Canadian population to promote informed voting, advocacy practices, and political accountability surrounding human and social justice issues that are exacerbated by the climate crisis. Shake Up The Establishment has released an informative blog post regarding opportunities to engage with the federal government’s environmental justice initiatives and continues to provide updates on their website. Check it out!

We also encourage you to register with the federal government’s website on Advancing Environmental Equity, which provides background information on Canada’s initiatives and will alert you of public engagement opportunities.  

 Finally, we invite you to follow the important environmental justice-focused work being done by our colleagues at Shake Up The Establishment, the ENRICH Project, the David Suzuki Foundation, Environmental Defence, the Canadian Association of Physicians for the Environment, the Coalition for Environmental Rights and the Canadian Coalition for Environmental and Climate Justice.


*Note on language: 

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.

For simplicity and consistency with CEPA language, WHEN uses the term ‘vulnerable population’ to refer to individuals who are at greater risk of experiencing negative health effects from exposure to environmental contaminants than the general population due to their intersecting identity factors and structural conditions. We recognize that the term ‘vulnerable’ can imply an intrinsic deficit, inferiority or inability to protect one’s own best interests, reduce perceived and actual agency of the individual or group, and result in their further stigmatization and exclusion [4]. We appreciate that Environment and Climate Change Canada and Health Canada are exploring using the term “populations who may be disproportionately impacted” interchangeably with “vulnerable populations” to recognize that many of these populations are not inherently vulnerable but rather that their susceptibility is associated with the circumstances of their lives. However, we encourage the government to further specify the factors that make one “inherently vulnerable” as well as the circumstances that make one more susceptible, in order to increase public awareness around the structural and physiological causes of health inequities.

Statement of Solidarity with Palestine: Sharing Resources, Combating Ignorance and Working Towards Collective Liberation

Statement of Solidarity with Palestine: Sharing Resources, Combating Ignorance and Working Towards Collective Liberation

Content warning: The following statement has content on genocide, ongoing violence in Palestine and incitement of violence against Palestinian people.

Justifiably, there are many emotional responses related to this topic that include grief, fear, anger and frustration. Before you engage with this statement, we encourage you to take a moment to regulate your nervous system in any way you know works best for you (here are some suggestions). As many of us continue to struggle with compassion fatigue, burnout and vicarious trauma, we stress the importance of caring for you so you can care for others. While self-care should not be used as an excuse to tune out, we encourage you to consume media intentionally and mindfully and find your balance between staying informed and protecting your emotional wellbeing.  

WHEN’S STATEMENT

As an organization committed to advancing environmental justice and taking an anti-racist, anti-colonial and intersectional approach to environmental and human rights advocacy, it is in alignment with WHEN’s mission to speak out regarding the ongoing genocide against the Palestinian people. We acknowledge so-called Canada’s historical and present-day relationship with settler-colonialism that allows us to operate from the traditional territories of the Mississaugas of the Credit, the Anishnabeg, the Chippewa, the Haudenosaunee, and the Wendat peoples, and thus recognize our duty to stand against settler colonialism in Palestine. While we draw parallels, we also respect the distinct historical, political, and cultural contexts between Turtle Island and Palestine. 

The actions of the settler Israeli apartheid state in Palestine are breaching international humanitarian law, disproportionately impacting women and girls, and causing significant environmental damage. We stand against Islamophobia and anti-Semitism in any form, both of which continue to gain traction due to the dangerous conflation of anti-Zionism with anti-Semitism. We deeply condemn the indiscriminate killing, arbitrary imprisonment, denial of access to basic human necessities, and seizure of Israeli and Palestinian civilian hostages. In denouncing ideals of settler colonialism, we recognize that this violence did not begin on October, 7th, 2023, and that it instead follows 75 years of Israeli settler-colonial dispossession. We support an immediate ceasefire, the return of all Palestinian and Israeli hostages, and an end to the siege on Gaza (by allowing the unrestricted movement of Palestinians, immediate free flow of clean water, food, medicine, fuel, internet, electricity, and humanitarian aid) and to the ongoing colonial occupation of Palestine. We call on Canada to publicly support the provisional ruling by the International Court of Justice (ICJ), ordering Israel to take immediate measures to prevent genocidal acts in Palestine (an order that has not been complied with). Canada must demand that Israel comply with the ICJ’s orders, including its most recent order for Israel to comply with the Genocide Convention and stop its attack on Rafah (a so-called safe zone).

WHEN is deeply concerned about the trend of censoring those who speak out against the ethnic cleansing, collective punishment and dehumanization of the Palestinian people, as facilitated by the Canadian government. We reject the culture of fear that is keeping individuals and organizations from taking a stance, and regret not releasing this statement sooner. 

ENDORSEMENTS

WHEN endorses the following statement by Shake Up The Establishment: 

“We are against the massacre of Palestinian and Israeli people, and against genocide in all its forms. We support an immediate ceasefire; a return of all hostages, both Palestinian and Jewish– unharmed. The ongoing genocide of the Palestinian peoples necessitates a true end to the violent colonial occupation of Palestine by the settler Israeli government (as enabled by the Canadian government – which we as an organization that supports political accountability work in what is currently Canada, have an obligation to hold accountable). Importantly, we also support carving out space to promote cross-cultural and interfaith dialogues as an antidote towards the anti-Semitism and Islamophobia that continue to polarize us– particularly during a time when we need unity to ensure the safety and wellbeing of all people. A divided people cannot effectively hold governments or power structures accountable for failing to represent them, or their values.”

WHEN also endorses Environmental Defence’s statement regarding Canada’s obligation to uphold the International Court of Justice’s ruling, and statements made by Indigenous Climate Action.


RESOURCES 

In a time of grief, polarization, and deep collective harm, we are amplifying Palestinian and Jewish voices, supporting interfaith discussions, and promoting resource sharing and learning so we can combat ignorance and work towards collective liberation. Below you will find a list of resources intended to increase understanding of what’s happening in Palestine, including links to petitions, donations, social media accounts, podcasts, and articles. 

Please note that this is a working document and we will continue to update it as information becomes available. We welcome any constructive feedback or suggestions on how to improve the comprehensiveness of our list of resources and encourage you to reach out if you come across any problematic resources or organizations. 

Take action

Show your solidarity with the Palestinian people:

Donate to any of the following relief organizations that are on the ground in Gaza:

Background on the occupation of Palestine 

Censorship and discrimination 

Violations of international humanitarian law 

Disproportionate impacts on women and girls 

Environmental degradation 

Instagram accounts to follow

Palestinian Voices

  •  Outside Canada

Jewish voices 

  • In Canada

  • Outside Canada

Palestinian Journalists & perspectives on the Ground

Recent updates, current facts and information

Community organizers 

  • @bdsnationalcommittee – Official page of the Palestinian-led Boycott, Divestment & Sanctions movement

  • @canadians4rpalestine – Canadian advocacy group against anti-Palestinian racism

  • @ceasefirenowca – Ad-hoc coalition of over 200 pan-Canadian labour, faith, Arab, Jewish, and civil society organizations organizing for a permanent ceasefire. 

  • @climate4palestine –Climate organizers in solidarity with Palestinians

  • @labourforpalestine – pan-Canadian network of labour activists working in solidarity with Palestinian workers & people

  • @pymtoronto – Organizing movements in the Greater Toronto Area (GTA) and Kitchener-Waterloo Regions

  • @roads2liberation – Car rally chapters in Durham and Peel

  • @toronto4palestine –  Organizing movements that support Palestinian access to dignity, opportunity, and freedom in Toronto

  • @torontostudentsforpalestine – A coalition of organizing students at the University of Toronto in solidarity with Palestine

Organizations to follow 

Human Rights Watch 

Amnesty International 

Jewish Voices for Peace 

Independent Jewish Voices Canada 

Canadians for Justice and Peace in the Middle East

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!