We writing on behalf of Lake Ontario Waterkeeper, Fraser Riverkeeper and Ottawa
Riverkeeper regarding Health Canada's draft Guidelines for Canadian Recreational
Water Quality, Third Edition prepared by the Federal-Provincial-Territorial Working
Group on Recreational Water Quality of the Federal-Provincial-Territorial Committee on
Health and the Environment and dated September 2009.
We are independent, federally registered charitable organizations that work to restore
and protect swimmable, drinkable, fishable water for every community in our
watersheds. Over the years, we have had many opportunities to observe, monitor, and
offer advice regarding water quality and beach postings in our communities. We have
also reviewed the document for public comment in its entirety. Our comments and
recommendations below are based on this experience.
We commend the Working Group and the Committee for their study of recreational
water use in Canada. Interacting with the water is an important, culturally and socially
significant activity for many Canadians and for many visitors to our country. Staff at
Lake Ontario Waterkeeper and/or Ottawa Riverkeeper would be very pleased to meet
with you to discuss our recommendations in detail and to discuss alternatives to the
area of the document that poses the greatest threat to water quality and the health of
our communities: the "guidelines" described in Section 4.2 for secondary recreational
contact. In our view, this section of the document is seriously flawed and requires
Four recommendations are made to the working group:
Recommendation #1: Compare the proposed guidelines to guidelines established for the potection of human health and the natural environment - such as Ontario's Provincial Water Quality Objectives. Where stricter standards are required to protect both, stricter standards should be used. Speciﬁcally, recommendations for E. coli in freshwater should be no higher than 100 cfu/100 mL, Ontario's water quality objective that protects both human and aquatic life.
Recommendation #2: Where chronic poor water quality conditions are found, surveys should be completed to identify the source of the contamination. Actions should be taken by the appropriate federal, provincial or territorial government to address the contamination and/or enforce the applicable environmental legislation. The entire process should be transparent to the public.
Recommendation #3: Lower the risk to the public by employing an already accepted, stricter standard for E. coli: 100 cfu/100 mL. If the Committee is unwilling to adopt this standard, all signage or materials informing the public that an area is "suitable" for recreational contact should contain a qualiﬁer to the effect that there is a statistical likelihood that some individuals may still experience health effects as a result of low levels of pollution in the environment.
Recommendation #4: The entire section regarding "secondary contact recreational activities" should be removed from the document. Failing that, the limit should be the same as the primary contact standard until a science-based, defensible alternative can be proposed.
Read the full submission in PDF form here.