Tuesday, August 5, 2003
A serious error occurred when Cabinet approved the addition of “gaseous ammonia” to the list of toxic substances under the Canadian Environmental Protection Act (CEPA). Virtually all nitrogen fertilizers are derived from ammonia. Even natural fertilizers, like manure, contain some ammonia. Ammonia, as a fertilizer product, is applied directly to the soil as a source of nitrogen, or as a building block for other nitrogen products. As such, it is essential to the agriculture industry.
Grain and oilseed farmers want to support the measures to reduce smog and air pollution. They do not want to produce anything that would cause negative health concerns. In fact, they have already contributed to improving air quality by reducing the consumption of fossil fuels.
CEPA regulations must be founded on science-based risk management research done by Canadians. The science presented so far does not justify listing “gaseous ammonia” as toxic under CEPA. There are many questions as to whether proper research was conducted concerning the role of ammonia in smog formation. More research should have been required before “gaseous ammonia” became a listing to CEPA.
Gaseous ammonia fertilizers are currently being managed well by provincial governments, voluntary programs and nutrient management planning. Before a substance is listed as CEPA-toxic, the benefits of regulating the substance must far outweigh the costs. The listing of “gaseous ammonia” as a precursor to particulates has the potential to have a significant negative impact on the industry. For this reason, I believe that at this point in time “gaseous ammonia” should not be added to the CEPA List of Toxic Substances. Canada needs to perform its own research and provide its own evidence as to why “gaseous ammonia” needs to be included.
Please reconsider your decision immediately.