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Environmental Impact Assessment Review 25 (2005) 737 746

www.elsevier.com/locate/eiar

Canadian insights: The challenges of an integrated


environmental assessment framework
Karen McCaig
School of Occupational and Environmental Hygiene, University of British Columbia, Canada

Available online 30 August 2005

Abstract

The paper draws results from a review of literature to examine the strengths and weaknesses of
the integrated environmental assessment framework in Canada with respect to the inclusion of health
impact assessment. Insights include the legislative nature, rigid structure and priority for the natural
environment that may restrict progress and the pool of government agencies that need to be
convinced of the benefits of health impact assessment that may provide a strong structure for
compliance in the long term.
D 2005 Elsevier Inc. All rights reserved.

Keywords: Integrated environmental assessment; Health impact assessment; Environmental impact assessment

1. Introduction

This paper reviews the literature to examine the strengths and weaknesses of the
integrated environmental assessment framework, whose use is mandatory for new
development projects in Canada in order to develop insights that may contribute to the
continued development of health impact assessment (HIA) in Canada and in other
countries where HIA is part of public health policy development.

E-mail address: mccaig@interchange.ubc.ca.

0195-9255/$ - see front matter D 2005 Elsevier Inc. All rights reserved.
doi:10.1016/j.eiar.2005.07.006
738 K. McCaig / Environmental Impact Assessment Review 25 (2005) 737746

2. 1960s to 1970s development of environmental impact assessment

Since its inception environmental impact assessment has predominantly been the
responsibility of government institutions. Health impact assessment which is included in
the integrated environmental assessment framework was formally established within the
1969 US National Environmental Policy Act (NEPA 1969), which constituted the first
environmental assessment legislation implemented on a global scale (Health Canada,
1999a). The objective of the Integrated Environmental Assessment framework was to
ensure that the development of projects with potentially unacceptable outcomes was
prevented by interventions at the planning stage. At its inception, the integrated
environmental assessment framework was designed to incorporate public participation
and consisted of four phases: 1) screening; 2) scoping; 3) determining significance,
mitigation and follow up; and 4) recommendation, to enable decision makers to make
informed decisions regarding the potentially significant environmental and human health
effects of an industrial development. The framework used the WHO (1984) definition of
health that encompasses biophysical health and physical, mental and social wellbeing.
The first Earth Day, held in the US in 1970, helped advance environmental activism
throughout the world (Lewis, 1990). At first concern tended to focus on the need to protect
the natural environment as illustrated in the global environmental policy set out in the
Stockholm Declaration (UNEP, 1972). However the Lalonde report (1974) from Canada
marked a watershed in highlighting non-medical influences on health. As a result, Canada
was one of the first countries to follow the lead of the US and implement an integrated
environmental impact assessment policy (Health Canada, 1999a, Winfield et al., 2000).
Under the Canadian constitution, provincial governments hold primary jurisdiction over
most issues related to environment and health. The Provinces were the first to implement
environmental impact assessment laws, each developing a separate process. In 1975,
Ontario, the most populous province, was the first to implement an integrated assessment
strategy at the policy level. The other provinces followed during the 1980s with project
level assessment frameworks (Health Canada, 1999a; Winfield et al., 2000). Meanwhile
the World Health Organization promoted its dHealth for AllT policy, which raised the
salience of health issues worldwide (Davies and Sadler, 1997).

3. 1980s inclusion of health in environmental impact assessment

In 1982, through the World Health Assembly, WHO endorsed the concept of integrated
environmental assessment and later developed guidelines and methodologies that would
allow assessment of health impacts to be incorporated into any environmental assessment
by non-health sector practitioners (Davies and Sadler, 1997) However, many causeeffect
relationships for biophysical health impacts were unknown or disputed at both the
epidemiological and toxicological level. Assessment was further complicated by the
complex nature of environmental health impacts (Giroult, 1988; Martin, 1986). In
addition, Danida (1989) observed a general reluctance to use WHOs definition of health,
which encompassed physical, mental and social well-being rather than being restricted to
biophysical health. Other problems noted at this time were a lack of involvement of health
K. McCaig / Environmental Impact Assessment Review 25 (2005) 737746 739

professionals and health authorities (Go, 1987) and a shortage of resources (Giroult, 1988;
Martin, 1986). Together these factors led to indirect impacts of industrial developments on
human health remaining largely unconsidered in the environmental policy world (Danida,
1989; Davies and Sadler, 1997; Ortolano and Shepherd, 1995). A number of other
approaches appeared in the literature (Davies and Sadler, 1997) but as the underlying
scientific knowledge remained deficient these did little to clarify the situation.
In 1986 the relationship between the biophysical environment and human health was
given further emphasis in the Ottawa Charter for Health Promotion (WHO, 1986; Davies
and Sadler, 1997; Health Canada, 1999a). In 1987, the Brundtland Report from the World
Commission on Environment and Development introduced the concept of sustainable
development (WHO, 1987). Human health became one of the key issues in discussion of
global economic development and sustainable development strategy, further confirming
the need for a more integrated environmental policy (Davies and Sadler, 1997; Sadler and
Jacobs, 1990).

4. 1990s rapid development of health impact assessment

In 1992, the Earth Summit in Rio focused on sustainable development (UNEP, 1992),
which by this time was attracting interest worldwide. While principle one of the Rio
declaration referred to human beings as bentitled to a health and productive life in
harmony with natureQ the main emphasis of the declaration was on the natural
environment. In Canada, the Advisory Committee on Population Health (1994) published
the determinants of population health model, which was consistent with research in other
countries, and provided a conceptual framework for considering health impact assessment
by presenting definitive categories of impacts that could be used in the assessment of
projects. The determinants of health model was increasingly used in the scientific literature
further building the theoretical base for impact assessment. Advances in epidemiology and
other disciplines led to improved knowledge of health impacts and exposure pathways.
In 1992 WHO published bOur Planet, Our HealthQ which focused on the critical
relationship between environment and health (WHO, 1992) raising awareness yet again. By
the mid-1990s, a number of HIAs had been reported and several tools to aid the integration of
health issues in environmental assessment had been published in different countries. In
Canada, the Deputy Ministers of Health from federal, provincial and territorial levels of
government formally adopted the Determinants of Health framework (Health Canada,
1999a). In 1995, Environment Canada enacted the federal Canadian Environmental
Assessment Act and created the Canadian Environmental Assessment Agency to oversee
assessments. However, the emergence of a federal act created discrepancies between federal
and provincial jurisdiction (Health Canada, 1999a). The newly formed Canadian
Environmental Assessment Agency worked on developing an approach that could meet
the requirements of both federal and provincial legislation (Health Canada, 1999a). In other
countries, awareness of HIA was growing and many governments and international agencies
became interested in including HIA as a component of environmental assessment.
However, HIA was not often undertaken even where legislation appeared to require it
(Davies and Sadler, 1997; Health Canada, 1999a; Sloof, 1995). It is evident that some
740 K. McCaig / Environmental Impact Assessment Review 25 (2005) 737746

governments were not convinced that health impact assessment was an effective tool and
in many cases the practicality of the process was challenged. In 1997, under the direction
of Health Canada and International Association of Health Impact Assessment, Davis and
Sadler (1997) examined the effectiveness of HIA globally. This study drew attention to the
potential benefits of HIA but found that the work required to reap these benefits was not
being done. The study identified difficulties in finding an entry point for HIA in
environmental assessment. Incorporation of social, community and psychological
dimensions of health and well-being into environmental impact assessment was noted
as a particular challenge. The inclusion of a health impact component in environmental
assessment was found to be ad hoc. It was dependant on the willingness of environmental
assessment practitioners who frequently had to be persuaded that inclusion of health was
desirable (Davies and Sadler, 1997) of health was desirable (Davis and Sadler, 1997).
Meanwhile, a federalprovincialterritorial process that led to a joint declaration by the
provincial and federal ministers of Health and Environment (CCME, 1996). This
declaration recognised the relationship between economic development and human health,
and laid the foundations for close collaboration in relevant processes, including
environmental impact assessment.
After the introduction of the determinants of health model, publications from academia
started to appear in the general body of literature. Examples include the collaborative effort
of the Canadian Handbook on Health Impact Assessment (Health Canada, 1999a,b,c)
intended to give practical guidance to health professionals and non-health sector
practitioners involved in integrated environmental assessment and Spiegel and Yassi
(1998) who illustrated how indicators could be developed for use in environmental
assessments. Procedures for HIA were also being developed at this time. In countries such
as UK (Kemm, 2003) and Australia (Department of Health and Human Services,
Tasmania, 2002) which had not adopted mandatory integrated environmental assessment
processes, public health agencies concerned to prevent harmful health impacts and
maximise beneficial ones began to develop HIA as a tool for healthy public policy. The
processes developed were based on the determinants of health framework (Kemm, 2003)
and, as would be expected, tended to focus on assessment of policies rather than the more
traditional application of assessing industrial projects which had been the focus of the
integrated environmental assessment process.

5. 2000s: a continuing search for improvements

The Malmo Declaration (UNEP, 2000) in 2000 explicitly acknowledged human health
thereby improving the status of health impact in global assessment policy. In the absence
of a blueprint for HIA (Douglas et al., 2001) exploration and trial and the publication of
new tools continued alongside repeated demand for better evidence relating to potential
health impacts. While some countries institutionalised HIA processes, its utility and
effectiveness continued to be questioned. Problems with practicality (Ison, 2001),
robustness (Lock, 2000; Mindell et al., 2001; Parry and Stevens, 2001), equity (Liverpool
Public Health Observatory, 2000), appropriateness (Douglas et al., 2001) and explicitness
(Douglas and Scott-Samuel, 2001; Frankish, 2002) of the HIA methods were questioned.
K. McCaig / Environmental Impact Assessment Review 25 (2005) 737746 741

Canada had meanwhile embraced HIA and continued to work towards increased
provisions in the Canadian Environmental Assessment Act throughout the late 1990s
and 2000s. As a result, the protection of human health as an objective of
environmental assessment is more explicit within the 2003 amendment of Canadian
Environmental Assessment Act (CEAA, 2003b). Health Canada continues to seek
better tools that will enable HIA to be carried out as a component of environmental
assessments in Canada.

6. The different frameworks in Canada

Canada has eleven separate environmental assessment frameworks (Marbek Resource


Consultants, 1998). Although all frameworks generally follow the established process (see
Fig. 1) they differ in two distinct ways. First the follow-up stage is required in some but
not in other provinces (Health Canada, 1999). Secondly, there are differences in the
definitions of scope between jurisdictions. Health effects to be considered are either
classified as biophysical, socio-economic and technical, direct and indirect; or else
classified as biophysical and related socio-economic and other effects (Marbek Resource
Consultants, 1998).
The 1995 Canadian Environmental Assessment Act places the overall responsibility for
ensuring integrated environmental assessment for matters lying within the federal domain

Phase Responsibility

Proponent Responsible Authority Minister of the Independent


Environment
Inclusion List, Law List
Project and Exclusion List Environmental
description regulations assessment not
SCREENING required

Comprehensive Study List

Comprehensive Screening Panel Mediation


Study Review
SCOPING
Decision: is
Define scope of mediation or Define
assessment panel review scope
warranted?

DETERMINING
SIGNIFICANCE Comprehensive
Study Report Review Screening Mediator report
or Comp. Report
MITIGATION Environmental Study
or
Impact Report
AND Environmental
Statement Assessment Report
FOLLOW-UP (Panel Review) (Panel Review)

EA decision

Fig. 1. The federal integrated assessment framework and process in Canada within the context of impact
assessment methodology, showing relevant responsibilities.
742 K. McCaig / Environmental Impact Assessment Review 25 (2005) 737746

with the federal Minister of the Environment (CEAA, 2003a). The independent Canadian
Environmental Assessment Agency coordinates the many assessments taking place at any
one time under federal jurisdiction. Normally, one federal ministry will assume
responsibility and authority for the assessment of a project. In some cases, two agencies
may take on joint roles as the responsible authority. These roles and how they relate to the
federal integrated environmental assessment framework and process are illustrated in Fig.
1. Opportunities for public participation are available throughout the process (CEAA,
1994; CEAA, 2003a,b).

7. The federal integrated environmental assessment process

7.1. Screening

In the Canadian integrated environmental assessment framework the identification of


projects requiring impact assessment is determined by regulation under the Canadian
Environmental Assessment Act. Projects potentially requiring assessment are defined as
those involving physical work or those not involving physical work but having potential
significant impacts as defined by the Inclusion List regulations. Project activities known
not to have significant effects are listed in the Exclusion List regulation and are exempted
from assessment (CEAA, 1994). Projects concerning transboundary issues and those that
are subject to federal statutory and regulatory approvals including federal permits,
certificates, licenses and authorizations that are set out in the Law List regulation and are
all subject to an environment assessment under federal jurisdiction (CEAA, 1994). The
Law List also states the range of ministries that must be involved in the assessment and
determination of a responsible authority (CEAA, 2003a,b). Health Canada has little
involvement at the screening stage.

7.2. Scoping

The intensity of the scoping exercise is also determined by legislation. The


Comprehensive Study List regulation describes projects and classes of projects that are
likely to have significant adverse environmental effects (CEAA, 1994). These are
predominantly large projects or projects that may generate public concern such as
large oil and gas projects. Those projects requiring environmental assessment but
because they do not feature in the Comprehensive Study List regulations are subject to
a less intensive screening study. Some projects allocated by screening for study may
be subject to a predetermined scope and are class screened. In all other cases, the
information previously provided by the proponent is used to scope the areas of
potentially significant impact. The definition of environmental effects as written in the
2003 amendment of the Canadian Environmental Assessment Act 1995 (CEAA, 1995)
includes changes in health and socio-economic conditions and should therefore feature
in the scope if necessary. Under the appointed responsible authority, all relevant
federal authorities identified in the screening stage and relevant health agencies are
involved in the scoping phase (CEAA, 2003a,b). If it is later determined that an
K. McCaig / Environmental Impact Assessment Review 25 (2005) 737746 743

independent assessment (mediation or panel review) is required, the scoping phase is


revisited.

7.3. Determining significance, mitigation and follow-up

In this phase, the significance of the impacts outlined in the scope needs to be
determined and any significant impacts addressed with appropriate mitigation and follow-
up measures (CEAA, 1994; CEAA, 2003a; Health Canada, 1999). This phase is carried
out under the responsible authority supported where appropriate by the proponent, the
panel or the Ministry of the Environment. For projects subject to class screening, the
significance of impacts, mitigation measures and follow-up measures are predetermined
and evaluated against model projects by the responsible authority using a check list
(CEAA, 2003a). Early in the comprehensive study process the concerns are reviewed and
if their investigation exceeds the capabilities of the authority the process maybe converted
to mediation or panel review (CEAA, 1994). Also, if significant impacts are unknown or if
public concern is deemed too high for a project to be reviewed at a screening level, the
projects are passed to the Minister of the Environment with a recommendation, who may
decide to proceed with mediation or panel review (CEAA, 2003b). The Minister of the
Environment assesses all comprehensive study reports (CEAA, 2003a,b). Final reports are
approved by the Canadian Environmental Assessment Agency and made available for
review by interested parties, including other government agencies and the general public
(CEAA, 1994). In the case of class screenings, comments are requested prior to screening
(CEAA, 1994).

8. Challenges of health impact assessment in integrated environmental assessment in


Canada today

In order that health issues are properly incorporated in integrated environmental


assessments the legislation must make explicit provisions to ensure adequate consideration
of health issues. Sufficient guidance and expertise must be available. The responsible
authorities and the proponents must systematically incorporate the health component into
their studies. Health professionals from local, regional and national health authorities must
also be involved (Health Canada, 1999b).
On an institutional level, the Canadian Environmental Assessment Agency (under the
Minister of the Environment) is the owner of the process while Health Canada retains an
advisory role. Other ministries, which each have different values and different issues at
stake, have a similar advisory role and are equally accountable for the process.
Consequently changing the process is very much a team effort. Health Canada needs to
gain the support of all other ministries involved in order to ensure that effective HIA is
included in the process. For this to happen, ministries have to be convinced of the benefits
of HIA and so must be given the information that will convince them of this.
Four main areas of knowledge based challenges can be identified from the Canadian
Handbook on Health Impact Assessment (Health Canada, 1999a,b,c): equity and
knowledge of risk; data acquisition, assessment tools and analysis or synthesis of results.
744 K. McCaig / Environmental Impact Assessment Review 25 (2005) 737746

The lack of scientific information both generally and on specific determinants of health
currently prohibits a full understanding of the potential impacts, sources of impacts, impact
pathways and their likelihood of occurrence. It is still unsure to what extent similar
economic activities can be assumed to have similar impacts in assessing health impacts.
One source of information previously untapped is the traditional knowledge from peoples
who have lived and worked on a land for generations, but its non-scientific format makes it
difficult to integrate with information from other sources. Methods to facilitate the use of
traditional knowledge still need to be identified (Health Canada, 1999a).
Challenges regarding data acquisition include the difficulties in finding suitable
indicators for inclusion in the baseline data and the assessment of future impacts. In some
instances, baseline data are not available and resource restrictions preclude the
development of new indicators and the collection of relevant data. Health Canada
(1999a) suggests that prospective data should not be dependent on baseline availability
and should be collected in all cases.
Health Canada has also argued that some of the tools used by non-health practitioners
to process information for HIA are inappropriate. For example, traditional social impact
assessments have limited application to HIA without the input of health professionals to
help define research objectives and translate results (Health Canada, 1999a,b,c). The
challenge is therefore to identify adequate tools or to adapt currently inadequate tools to
suit the needs of HIA. Discussions in the draft Canadian Handbook of Health Impact
Assessment (Health Canada, 1999a,b,c) relate to various tools including technological risk
assessment, epidemiological studies and predictive social impact assessment.
Other knowledge based challenges lay in the judgement of significance. Where
legislation, guidelines or even scientific information is available it is possible to judge the
level of significance, but alternative means need to be found in areas where these are lacking.
Judgement of significance is particularly difficult for social impacts though traditional
knowledge may be especially relevant in this context (Health Canada, 1999a).

9. Strengths and weaknesses of an integrated assessment framework

Government policy requiring environmental assessment has predominantly been


applied at the project level in Canada and evidence suggests that if health impact
assessment is fully integrated into an environmental assessment framework, impacts to
human health will be considered at this level. However, HIA has only rarely been applied
at a policy level, which indicates that impacts to human health are less likely to be
considered at this level. The incorporation of HIA into legislated integrated environmental
assessment framework requires compliance by practitioners and proponents. As these
become more familiar with HIA they will become more supportive of its inclusion in
assessment processes.
Rigid structures and the priority given to the natural environment by the
Environmental Agency may restrict development of HIA in the integrated environmental
assessment process. Health Canada normally retains an advisory role in the process and
has to convince the other ministries involved of the benefits of HIA. Voluntary HIAs are
popular in the countries, where it is done in the framework of public health policy but it
K. McCaig / Environmental Impact Assessment Review 25 (2005) 737746 745

is not appropriate in countries where there is a legislative framework such as Canada.


While methods and processes for assessing the health component within the framework
of environmental impact assessment are developing, Health Canada must prove the
effectiveness of HIA and produce a track record of credible results. Due to the many
agencies involved in the assessment, uptake is slow but continual discussion between
health and non-health agencies should ensure the continued developments of HIA and
lay solid foundations for its future.

10. Conclusions

An established framework of integrated environmental assessment draws in a pool of


government agencies that need to be convinced of the benefits of HIA. The legislative
nature, rigid structure and priority for the natural development can restrict development
but once support from other agencies is gained, the legislative structure can be used as a
lever to ensure compliance for all projects covered by the legislation. A wider focus
could be achieved if HIA was extended beyond the current project focussed framework
and applied more frequently at a policy level.

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