Consultation on CEPA Right to a Healthy Environment Draft Implementation Framework

A joint statement by five environmental and health organizations providing recommendations to the Government of Canada to strengthen the draft Implementation Framework for the Right to a Healthy Environment under the Canadian Environmental Protection Act, 1999 (CEPA).

• The draft framework lacks a rights-based approach and fails to reference international standards, such as United Nations Human Rights Council and General Assembly resolutions or the Canadian Charter of Rights and Freedoms. The authors argue that the framework should move beyond cataloguing existing activities and instead articulate a conceptual understanding of the right to a healthy environment to fulfill Canada's human rights obligations.
• The authors recommend the implementation of 'quick-start actions' to protect the right to a healthy environment, specifically prioritizing the reduction of cumulative exposures to toxic chemicals and pollution in equity-deserving communities that have historically faced disproportionate burdens.
• The definition of environmental justice in the draft framework is criticized for omitting the role of social inequities—such as racialization, income, and disability—and for failing to include sex and gender. The authors highlight that women, girls, and people assigned female at birth (AFAB) are at increased risk from endocrine disrupting chemicals like PFAS and phthalates due to reproductive systems and social roles in care work and cleaning.
• The authors call for a stronger application of the principle of non-regression, stating that the government should not weaken environmental or human rights standards without compelling constitutional justification. They argue that the current draft's suggestion to merely 'consider' the potential for regression is insufficient and should instead compel decision-makers to reject regressive risk management options.
• The statement identifies significant gaps in accountability and access to remedies, noting that public request for investigation tools under CEPA are rarely used due to procedural barriers. They recommend requiring a 'Statement of Consideration' in public decision documents to explicitly show how the right to a healthy environment was considered.
• The authors express concern over the lack of engagement with Inuit organizations and leaders during the development of the discussion paper that preceded the draft framework, citing the disproportionate burden of plastic pollution and climate change effects in the North.
• Regarding intergenerational equity, the authors recommend a special focus on substances contributing to climate change and the establishment of service standards for assessments and management actions where the Act does not specify clear timelines.

APA

Canadian Association of Physicians for the Environment (2024). Consultation on CEPA Right to a Healthy Environment Draft Implementation Framework. https://cape.ca/wp-content/uploads/2024/12/Comments-on-CEPA-Right-to-a-Healthy-Environment-Draft-Implementation-Framework-Dec-4-2024.pdf

Chicago

Canadian Association of Physicians for the Environment. Consultation on CEPA Right to a Healthy Environment Draft Implementation Framework. 2024. https://cape.ca/wp-content/uploads/2024/12/Comments-on-CEPA-Right-to-a-Healthy-Environment-Draft-Implementation-Framework-Dec-4-2024.pdf.

Wikipedia

{{cite press release |author=Canadian Association of Physicians for the Environment |title=Consultation on CEPA Right to a Healthy Environment Draft Implementation Framework |date=4 December 2024 |url=https://cape.ca/wp-content/uploads/2024/12/Comments-on-CEPA-Right-to-a-Healthy-Environment-Draft-Implementation-Framework-Dec-4-2024.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{canadianassociationofphysiciansfortheenvironment2024consultation, author = {{Canadian Association of Physicians for the Environment}}, title = {{Consultation on CEPA Right to a Healthy Environment Draft Implementation Framework}}, publisher = {Canadian Association of Physicians for the Environment}, year = {2024}, month = dec, url = {https://cape.ca/wp-content/uploads/2024/12/Comments-on-CEPA-Right-to-a-Healthy-Environment-Draft-Implementation-Framework-Dec-4-2024.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }