Policy and Political Action

Policy & Political Action

Response to Bill 132 to the Standing Committee on General Government

Good morning, my name is Hilda Swirsky and with me this morning is Susan Munro.  We are registered nurses and are here on behalf of the Registered Nurses’ Association of Ontario.  RNAO represents 43,500 thousand registered nurses, nurse practitioners and nursing students across this province.  We speak out for nurses and we speak out for health.  

Susan and I are both members of the Ontario Nurses for the Environment Interest Group of RNAO. We support the work of RNAO through our special interest and expertise in the connection between the environment and the health of persons and the planet. 

RNAO’s Senior Economist Kim Jarvi is also joining us.
On behalf of RNAO, thank you for the opportunity to speak to you this morning.  


We are here to urge you to withdraw those elements of Bill 132 that deal with environmental legislation – in particular schedules 9 and 16.  

On matters of human life and health, we as nurses always use the precautionary principle. Because the environmental legislation affected by Bill 132 is so intimately connected with human life and human health, we advise you to proceed with caution.   

In the view of RNAO, the inclusion of environmental legislation in an omnibus bill that impacts over eighty pieces of legislation suggests that the government is not proceeding with caution. 

The inclusion of environmental legislation vital to health in an omnibus bill that deals with “red tape” also tells us that the government is not proceeding with caution.

The inadequate public consultation, the minimal posting period on the ERO and the rush of Bill 132 through the legislature under time allocation is a long way from cautious conduct.   

Let us provide a couple of examples of our concern by pointing to the proposed amendments to the Pesticides Act and to the Aggregate Resources Act, just two of the more than one dozen environmental laws amended by Bill 132.


Our view on the Pesticides Act is informed by our role the in lengthy consultations shaping current pesticide legislation. RNs and other health organizations backed much stronger protections against pesticides for a number of reasons:

1. Many epidemiological and laboratory studies link a range of health problems to pesticide exposure, including cancer, dermatological effects, birth defects, other reproductive damage, neurological and developmental toxicity, genetic damage, immunotoxicity, and endocrine disruption.
2. The risk to health comes not only from active ingredients, but also from untested so-called inert substances.
3. As nurses, we particularly know that extra precaution is needed for children:

  • Children tend to get greater exposure whenever pesticides are released because of their behaviour and play
  • Their developing organs and tissues are more vulnerable to harm.
  • Children are even exposed to pesticides in utero, when crucial physiological development occurs.
  • Children have a longer time ahead of them for exposure to pesticides and to develop resulting health problems

4. Synergistic and cumulative effects can heighten the damage due to pesticides. 
5. Detection of pesticide damage in individuals is difficult, as physicians are not generally well trained in recognizing pesticide poisoning.  Furthermore, the effects of pesticide damage are often only apparent after many years.  Thus, people do not receive early warning signs that would allow them to take action in time.

We are very concerned about the potential for Schedule 9 to weaken protections against pesticides.

We also have grave concerns about the impact of the proposed legislative amendments on pollinators.  On the basis of unimpeachable evidence about the devastating effects of neonicotinoid pesticides on, in particular, bees, health and environment organizations like RNAO fought hard for the legislated restrictions on the use of neonics that were brought into effect in 2015. Beekeepers still face high winter bee mortality, and continued use of neonics is a contributing factor.  More needs to be done to restrict the use of neonics, not, as Bill 132 proposes, less. Bill 132 would remove essential oversight over neonic use.


Much like pollination, water is critical for health and ultimately life. The World Health Organization (2003) declared that, “Domestic water supplies are one of the fundamental requirements for human life. Without water, life cannot be sustained beyond a few days and the lack of adequate access to water supplies leads to the spread of disease.”  

We want to underscore to the Committee that 18% of Ontario’s population rely on private wells for access to safe drinking water.  In this context, the precautionary principle dictates that one ensures that the proposed changes to the ARA do not negatively impact an already delicate ecology of rural water supply and impose unacceptable environmental or health risks to communities that rely on wells for safe drinking water and agricultural use.

The last review of the ARA strengthened protection of Ontario’s water supply for Ontarians outside the jurisdiction of municipal water supply.  Section 12 (1) (e), for example, was revised to stipulate that the Minister or Local Planning Appeal Tribunal shall  have regard to “any possible effects on ground and surface water resources including on drinking water sources” when considering an aggregate license. The proposed amendments to Bill 132 re-create risks to water supply and drinking water in rural Ontario.

The proposed changes in Bill 132 affect the food we eat, the water we drink, but also the air that we breathe. Air pollution with fine particulate matter directly impacts the health of the population, provoking breathing emergencies, exacerbating asthma, and leading to lung cancer and cardiovascular disease. Through both the dust produced by heavy trucks transporting aggregate and the process of mining itself, particulate matter is released at the health expense of those around the area. The risks of mining on community air quality in Ontario are great, and regulations must be both cautious and protective. 

To mitigate such risks, and proceed with caution, RNAO recommends that the ARA must:  

  1. Consider the impacts of aggregate mining on air quality both through the mining and the increased particulate matter produced through transportation. The health impacts can be severe and far-reaching. 
  2. Subject any applications to extract aggregate from below the water table to a full environmental assessment and dismiss outright those that necessitate “pumping in perpetuity”.  Applications that necessitate extraction of aggregate from below the water table have long-term implications for both water supply and water quality and ecosystem integrity. 
  3. Take into account the implications of climate change for water availability in determining license approvals.  Approximately 2.7 million mostly rural Ontarians are reliant upon source water, often on low yield aquifers that are vulnerable to low water conditions. Many areas of Ontario had low water conditions declared by Conservation Authorities in three of the past four years, including this past summer. 
  4. Take into account local circumstances and unique needs of communities – as the government’s own “Made-in-Ontario Environment Plan” suggests.  The proposed removal of municipal authority over their own groundwater resources through zoning by-law restrictions on the depth of extraction weakens groundwater protection and conflicts with municipal responsibilities to protect ecological systems and the supply, efficient use and conservation of water as per the Planning Act. 
  5. Hold all new ARA licenses pending an inventory of need for new licenses assessment and a review of the health and safety risks of quarrying in the context of emerging research.
  6. In its “Made-in-Ontario Environment Plan”, government states that Ontario’s water is part of the province’s life support system and declared that it will take strong action to protect water sources. This plan also commits to protecting air and human health through strong environmental standards. These commitments require thoughtful consideration and consultation with respect to of all of these issues and many more.

We want to ensure that the Aggregate Resource Act strengthens, rather than weakens, protections to Ontarians’ access to clean and safe water and air.


As nurses, we are advising you that the environmental legislation that is amended by this Bill is intimately tied to matters of human health – even survival.  We urge you to remove the environmental legislation from Bill 132 and provide this province with the opportunity to fully understand and examine the consequences of what is proposed.  We urge you to move forward on the basis of the precautionary principle and insist on proof of safety rather than await proof of harm.  

Thank you for allowing us to present to you today.  



See RNAO's letter to the Standing Committee on General Government for more information.

Resource Type: 
Speaking Notes