Health Canada's Response to Urban Agriculture Concerns

Posted by Stop Ajax Mine on June 25th, 2015 11:45am

On April 25, Elaine Sedgman, who is involved with Kamloops Food Policy Council, wrote to Amanda Jane Preece, Director General, Safe Environments Directorate, Healthy Environments and Consumer Safety Branch, Health Canada.  Her letter said, in part:

On April 25, Elaine Sedgman, who is involved with Kamloops Food Policy Council, wrote to Amanda Jane Preece, Director General, Safe Environments Directorate, Healthy Environments and Consumer Safety Branch, Health Canada.  Her letter said, in part:

“I find it quite astonishing that everything to do with eating, food etc in association with the proposed Ajax mine seems to be stuck on the Country Foods model as do your own agency's comments which makes reference to consumption of traditional foods that are hunted, fished & gathered.

I find this confounding because this proposed mine is going to be built beside a city of 90, 000 people, many of whom grow their own food, where there are a number of SPIN urban farms, where there are a number of operating ranches, where there are a number of organic farms and a thriving Farmers' Market.

I cannot understand why your agency as well as the BC Environmental Office will not recognize the importance of agriculture and urban agriculture, especially backyard gardens, to the citizens of Kamloops.

I feel more & more like a second class citizen- that berry gathering and hunting takes precedence over the need to grow my own food.”

Here is the response from Health Canada’s A.J.Preece, received May 28.

“As you are aware, Health Canada is the federal department responsible for helping Canadians maintain and improve their health. As a federal authority under the Canadian Environmental Assessment Act (CEAA 2012), Health Canada assists in the evaluation of potential human health impacts of environmental effects of proposed projects by providing specialist or expert information or knowledge on issues related to air pollution, drinking and recreational water pollution, the contamination of country foods and exposure to noise and radiation.

In order to respond to your concerns, within the environmental assessment process, Health Canada defines country foods, also known as traditional foods, as comprising all those foodstuffs which are obtained outside of the commercial supply chain. While this includes fish and game meat or food that is wild-harvested (berries, seeds, roots, leaves, bark and lichen), it also includes food grown for subsistence or medicinal purposes, such as fruit, vegetables and fungi grown in home gardens and orchards, as well aquatic and terrestrial fauna such as ducks and chickens (and their eggs), in addition to livestock such as goats, sheep and cows raised for personal meat or dairy consumption.

Health Canada has restricted its comments on the Ajax Mine project to country foods as defined above because the safety of commercial foods, including those sold at farmers’ markets, are the responsibility of the Canadian Food Inspection Agency (CFIA) and the province’s Interior Health Authority. Levels of chemicals in food are monitored by the CFIA through its National Chemical Residue Monitoring Program. The monitoring program is used to determine the need for directed sampling which focuses on identified chemical contamination issues and compliance sampling to support the removal of food in violation of standards from the marketplace.  Additional information about the National Chemical Residue Monitoring Program can be found at:

Health Canada takes its commitment to protecting the health of Canadians, as well as its obligations under CEAA 2012, very seriously. The importance of urban agriculture to the citizens of Kamloops, especially backyard gardens, has been recognized from the beginning of the assessment of the proposed Ajax Mine, and will continue throughout the process. One of Health Canada’s initial concerns, noted in the draft Application Information Requirements submitted on September 28, 2011, indicated that non-commercial farming or food production should be included in a country foods assessment, and should include “hunting, fishing, traplines, and non-commercial farming or food production (e.g. country gardens)”. The full comment can be viewed here:

As was stated in the April 9, 2015, Letter to the Editor in Kamloops This Week, it remains the department’s intent to make Health Canada advice related to this project publicly available to ensure an open and transparent process. Comments from the public and government agencies can be requested through directly and are also posted on the British Columbia Environmental Assessment Office website at:

For reference, the most recent Health Canada comments can be found under the Federal Comments and Submissions section.

I hope that my comments help in addressing your concerns. We have also shared your letter with the Canadian Environmental Assessment Agency so that they too are aware of your comments, and I would encourage you to participate in future community consultation opportunities to identify outstanding concerns and suggest potential mitigation measures.”


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