Montreal, April 11, 2019
TRANSMISSION BY EMAIL
Mr. Benoit Charette, Minister
Ministry of the Environment and the Fight against Climate Change
Marie-Guyart Building
675, boulevard René-Lévesque Est, 30e floor
Quebec (Quebec) G1R 5V7
Subject: Environment-Beach Program
Minister,
The Environment-Beach Program aims to inform the public about the bacteriological quality of bathing water on a voluntary basis, which allows some to avoid any control. It has numerous flaws that endanger the safety of users who cannot access an adequate assessment of water quality. A Radio-Canada report broadcast in 2014 summarizes certain aspects of the case well. It is important to correct this situation which persists. We offer you pragmatic improvements.
Firstly, this Program is based solely on the results of bacteriological analyzes which, due to laboratory analysis delays, are systematically out of date by several days after taking the samples. The same goes for the reopening of beaches, the waters of which could potentially have become contaminated again during the analysis times! Second, the frequency of sampling only every 2 to 5 weeks adds to the danger. In fact, the ratings assigned (A, B, C or D) to the bacteriological quality of the water should never be considered valid at the time of the visit to the beach, because the analyzes are a few days old. However, the wording of the Environnement-Plage website indicates that the Program aims to “ allow the population to enjoy these places, fully and peacefully ". This wording induces a false sense of security and it should be revised to reflect the limitations of the Program.
There are now technologies that allow bacteriological analyzes to be carried out much more quickly than the current method, between 15 minutes and a few hours rather than the usual 24-72 hours. Unfortunately these are still not considered in the regulations. The authorities (INSPQ, DSP, MELCC) are slow to develop new approaches that would more effectively control the risk factors for swimming.
One of these would consist of following the recommendation proposed by Health Canada, there USEPA. and theWHO, which requires operators to carry out a Environmental safety and health survey before each swimming season. Such evaluations take into account in particular the presence of overflow structures upstream, the history of contamination, use by animals, the presence or absence of a warning system during overflows, etc. and would allow:
- to identify the fundamental characteristics of recreational waters;
- to detect any possible source of fecal contamination;
- to highlight any other potential danger to water quality, whether physical, chemical or biological in nature;
- evaluate the effectiveness of monitoring programs and risk management measures in force.
Such indicators additional should be introduced into the Environment-Beach Program in order to better assess risks and ensure safer monitoring for the public.
Wastewater overflows are among the sources of pollution which affect the bacteriological quality of bathing water. We know that their total number in Quebec was 62,000 in 2017 while there were 43,000 in 2013. However, it is possible to alert users threatened by contamination, as the city of Kingston in Ontario which deployed an immediate alert system during overflows using telemetry devices. Preventive beach closures could then be made to reduce the risks. Municipalities should be systematically required to notify downstream users of any wastewater overflow.
Finally, the voluntary nature of the program raises important questions. Articles 83 of the Environmental Quality Act and 53 of Regulations on safety in public baths However, both mention the obligation for the operator to close a bathing place if a threat to public health is noted. However, there is no regulatory clause in these two documents concerning water quality. A beach can thus be opened without monitoring of bacteriological quality ever being carried out. Operators can also choose, at any time, to cease their participation in the Program if the bacteriological quality is doubtful and they do not wish to have bad press. This is how the number of beaches participating in the Program increased from 513 beaches in 1991 to 242 in 2018. Important beaches such as those in the city of Longueuil and Trois-Rivières, although located in risky areas, are not not participate in the Program. A new, improved Beach Environment Program should be mandatory for all public beaches.
The current Program therefore appears of little use because of its very limited effectiveness in preventing public exposure to potentially contaminated bathing water, as well as its analysis times which are too long and costly for the Ministry. A new Program should apply to all beaches and not just new ones, such as that of Verdun, which is one of the only ones that has had to meet specific requirements from the Public Health Department.
We remain available for any collaboration you may wish in this matter. Please accept, Mr. Minister, the expression of our distinguished feelings.
Alain Saladzius, FIC, Eng.,
President, Fondation Rivières
Photo: Anastasios Agathangelou/Unsplash
