By Ellen Sweeney, PhD

Risk factors such as diet and exercise cannot account for the increased incidence in breast cancer, particularly in industrialized countries. Consequently, it is necessary to consider the environmental links to breast cancer, including mammary carcinogens and endocrine disruptors, through everyday exposures to industrial chemicals and toxic substances in consumer products.

Breast Cancer Action Quebec’s recent correspondence from representatives of the Canadian Cosmetic, Toiletry and Fragrance Association (CCTFA) suggests that the association is operating within the federal environmental regulations, including their Look Good, Feel Better campaign. The assessment and management of toxic substances is a joint responsibility of Health Canada and Environment Canada through the Canadian Environmental Protection Act, 1999 (CEPA 1999) and the Chemicals Management Plan (CMP).While the CCTFA may be operating within the existing regulations, it is within a system with gaps that place women’s health at risk.   

The implementation of CEPA 1999 represented a shift from pollution management to pollution prevention in order to protect the environment and human health. It required the categorization of 23,000 existing toxic substances on the Domestic Substances List in order to determine which substances had the highest potential for exposure to citizens, and which were considered to be persistent, bioaccumulative and inherently toxic. This categorization process was completed between 2000-2006 and resulted in 4,300 substances that were identified as priorities for further action.

The CMP was launched by the federal government in 2006 and is implemented under CEPA 1999. It is designed to assess and manage the risk of the toxic substances categorized as harmful to human health or the environment by 2020, including 500 chemicals which have been identified as the highest priorities for immediate action. Three key elements of the CMP include a challenge to industry for immediate action on toxic substances of high concern; the regulation of food, cosmetics, drugs and pesticides; and investment in research and monitoring.

The precautionary principle has not been applied in a meaningful way in CEPA 1999 and the CMP. While the goal of CEPA 1999 and the CMP is to prevent pollution and protect the environment and human health, there are a number of gaps which place women’s health at risk. These gaps include but are not limited to:

Risk vs Hazard– The current practice of risk assessment is inherently reactionary rather than precautionary because it enables widespread environmental contamination and detrimental health outcomes before the risks can be assessed and managed.  The risk assessment process requires exposure to a toxic substance to occur, but this does not adequately account for the possibility of low-dose or cumulative exposure effects from substances such as endocrine disrupting chemicals. Rather than the exposure requirement, a hazard assessment would allow for the use of the precautionary principle in that it includes an assessment of the intrinsic hazard or toxicity of a substance and its potential to cause harm. For example, toluene has inherently toxic properties but was found to be “not toxic” under CEPA because of the exposure requirement. Toluene is used in cosmetics including nail polish and is linked to health concerns such as developmental and reproductive toxicity, neurotoxicity, and organ system toxicity.[i],[ii] It is managed in other jurisdictions including the European Union,[iii] and in California where the law has created incentives for manufacturers to remove toxic substances from their products.[iv]

Individualized Responsibility– Government and mainstream cancer organizations promote the idea that breast cancer is preventable if women participate in a “healthy lifestyle” while dismissing other factors that influence the disease. Similarly, when the potential role of toxic substances is acknowledged, women are still encouraged to take responsibility in order to avoid everyday exposures. This practice is highly problematic as it places responsibility on individuals and creates a gendered and disproportionate burden on women. Public health cannot be protected if responsibility remains at an individual level, without recognizing the role of government and industry in health outcomes as a result of exposures to toxic substances.

Sex and Gender– Despite a formal commitment by the federal government, a report by the Auditor General clearly demonstrates that sex- and gender-based analysis is not adequately integrated into policy development.[v] Both biological and social factors influence the development of breast cancer including the role of estrogen receptors and endocrine disrupting chemicals, as well as the increased exposures women may experience in the workplace and in their roles as caregivers. Women are not considered to be a susceptible population under CEPA 1999 or the CMP; this lack of consideration of sex and gender is inadequate for the protection of women from detrimental health outcomes such as breast cancer.

Ultimately, the federal government is responsible for the assessment and management of toxic substances and the protection of the environment and human health. However, the regulations are not currently capable of being truly protective and, in fact, place women’s health at risk. By recognizing the role of toxic substances in health outcomes, including breast cancer, there are opportunities for companies and organizations like the CCTFA, with its Look Good, Feel Better program, to be proactive in a truly precautionary manner by removing substances from products that may place women’s health at risk.

[See also: Kearns, Patricia. (2011). “From BCAM President: ‘Petition Gets Me Thinking.’” Correspondence between Breast Cancer Action Montreal and the National Network on Environments and Women’s Health. President, BCAM Board of Directors. Accessed 30 August 2013 from, http://www.acsqc.ca/content/bcam-president-petition-gets-me-thinking]


[i] Canadian Environmental Law Association (CELA) and Canadian Institute for Environmental Law and Policy (CIELAP). (1996). It’s Still About Our Health! A Submission on CEPA Review: The Government Response Environmental Protection Legislation Designed for the Future – A Renewed CEPA Proposal. CELA Brief No. 283, CIELAP Brief 96/3. Toronto, Ontario.

[ii]Environmental Working Group. (2013). “Toluene.” Accessed 24 June 2013 from, http://www.ewg.org/skindeep/ingredient/706577/TOLUENE/.

[iii]Armstrong, Josephine and Claire Dupont. (2012). Implementation and Enforcement of Restrictions under Title VIII and Annex XVII to REACH in the Member States: Final Report. Submitted to European Commission, Directorate General Enterprise and Industry. March 7, 2012. Belgium: Milieu Law and Policy Consulting.

[iv]Office of Environmental Health Hazard Assessment. (n/d). Toluene: Chronic Toxicity Summary. (Methyl benzene; methyl benzol; phenyl methane; toluol). Accessed 24 June 2013 from, http://oehha.ca.gov/air/chronic_rels/pdf/108883.pdf.

[v]Minister of Public Works and Government Services Canada. (2009). “Chapter 1: Gender-Based Analysis.” Report of the Auditor General of Canada to the House of Commons. Ottawa: Office of the Auditor General of Canada.