Please find below, in black, the Government of Manitoba's Reply to the Complaint of Discrimination of Glenda Whiteman under section 13 of The Human Rights Code (Manitoba), File No. 05 EN 260.
(NB. Manitoba's response was transcribed exactly as written.)

In green, please find Glenda Whiteman's rebuttal to the respondent's reply.

  1. The Government of Manitoba has reviewed the Complaint of Discrimination of Glenda Whiteman and makes this reply in response.
    Please consider this complaint to be on behalf of those persons considered by the Government of Canada's Standing Committee on Environment and Sustainable Development (1) to be the most vulnerable groups to pesticides: “fetuses, children, seniors, women, Aboriginal people, persons suffering from multiple chemical sensitivity or in poor health, and professional users of pesticides.”

     Narrowed down to purposes of applying section 13 of the Human Rights Code, you must consider that  
     this complaint is then on behalf of identifiable groups based on age, pregnancy and disability.

  1. Manitoba denies the allegations in paragraph 1 of the Complaint except as expressly admitted herein.
    It is not clear exactly what Manitoba is denying?

  2. Manitoba denies the allegations in paragraph 2 of the Complaint except as expressly admitted herein, and except for the allegations of the Complainant having special needs due to disability to which allegations Manitoba has no knowledge and therefore puts the Complainant to the proof thereof.
    Again, what is Manitoba denying, exactly?

  3. Further with respect to paragraph 1 of the Complaint, the Permit under which the City of Winnipeg conducts spraying of insecticide for nuisance mosquitoes requires notice and an opportunity for those individuals opposed to the use of insecticides to individually register their objections and that “buffer zones” be provided for objectors. The situation in which Manitoba, through the Minister of Conservation, makes an Order to spray is based upon an imminent health emergency and not a nuisance to the public.
    What is the significance of the use of italics here?

  4. Manitoba states with respect to the Complaint as a whole that the action complained about is not a service as defined in section 13 of The Human Rights Code, nor is it covered in any other manner by section 13, and Manitoba denies that the Commission has jurisdiction to review this matter.
    Saskatchewan Chief Human Rights Commissioner Donna Scott writes, “Municipalities considering the use of chemical agents to control mosquitoes are obligated to consider the impact of any plan to use chemical agents for the control of mosquitoes on persons protected by the     Code.” (2)

    Ontario Chief Human Rights Commissioner Keith Norton states, “The Code provides that every person has a right to equal treatment with respect to services without discrimination because of disability. It is the Commission's policy position...that environmental sensitivity is a disability and is thus protected under the Code. As such...any municipality responsible for implementing the use of chemical insecticides, has a duty to provide accomodation to persons with environmental sensitivity. Failure to do so may contravene the Code.” (3)

    The Canadian Human Rights Commission also reminds those who may be considering the use of chemical agents to control oubreaks of West Nile virus that they have a duty to accommodate those with environmental sensitivities under the     Code. (4)

    There appears to be no reason that the Manitoba Human Rights Commission would not also have jurisdiction in this matter. Furthermore, is it appropriate for Manitoba to deny the Commission jurisdiction?

  5. In the alternative Manitoba states the following:

a) Manitoba denies the allegation that malathion is a toxin dangerous to the general public or specific groups when applied in the manner ordered by the Minister of Conservation.
Malathion is neurotoxic (5), immunotoxic (6), and genotoxic. (7)

Malathion has been shown to contain contaminants and break down into products, such as malaoxon and isomalathion, which are known to be far more toxic than malathion itself. (8)

Please refer to the quotation from the Canada Gazette demonstrating the federal government's acknowledgment that contaminants are a serious issue. (9)

b) Manitoba has no knowledge that the Complainant has any special needs due to disability, and no knowledge that she has a disability and puts the Complainant to the proof thereof.
The complainant would be happy to see a doctor who can diagnose environmental sensitivities, also known as Multiple Chemical Sensitivities or MCS. That currently seems impossible in Manitoba. In fact, during my search on behalf of clients last summer for a doctor capable of/willing to diagnose overexposure to pesticides, one physician confided to me that I would not likely find any in Manitoba because they fear retribution from the chemical/pharmaceutical industry.

If Manitoba requires a diagnosis, the Complainant would be happy to travel to the Ottawa Environmental Health Centre or to Women's College/Sunnybrook Hospital in Toronto (at Manitoba's expense) to see a doctor who is capable of making that diagnosis. However, again please bear in mind that these complaints are on behalf of all Manitobans with MCS, as well as other affected groups. It seems unlikely that Manitoba would be willing to send every patient in the province who is negatively impacted to some degree by pesticide exposure. Incidentally, Keith Norton, Ontario Chief Human Rights Commissioner, quotes Dalhousie University statistics which estimate that between 15 and 30% of the population suffer from MCS. (10)

c) Manitoba states in the alternative that if the Complainant has a disability and has special needs as a result, that there would be no discriminatory effect from the use of malathion on the terms mandated by the Order made and described further below.
“In particular, the use of these chemicals (fogging agents) would likely have an adverse impact on those with environmental sensitivity.” Keith Norton, Ontario Chief Human Rights Commissioner (3)

  1. Manitoba states that there is no discrimination as that term is defined under The Human Rights Code.
    “Discrimination includes a failure to reasonably accommodate special needs.” Saskatchewan Chief Humans Rights Commissioner Donna Scott, on the subject of fogging for West Nile virus. (2)

  2. In the further alternative Manitoba states that is has made reasonable accommodation, if same should be required, by various steps including the specific provision of notification as to when spraying will occur.
    Accommodating children, pregnant women, and the disabled by telling them in advance that they are going to be poisoned is no real accommodation at all. Research from the University of British Columbia shows that remaining indoors does not protect us from pesticides for very long; within 5-6 hours after spraying indoor concentrations of pesticides exceeded those outdoors. (11) If the provision of notification is intended to facilitate evacuating, most of us don't make $280,000 a year like our Chief Medical Officer of Health, Dr. Joel Kettner, who last year advised, “People who don't want to be exposed to malathion can leave their homes for a few days...” (12)

  3. Manitoba states that the elimination of the buffer zones was done in order to maximize the effectiveness of the malathion spraying, and that allowing buffer zones in these circumstances would not be a reasonable accommodation.
    Manitoba must stop using a nerve and immuno-toxin as a defence against a virus known to attack immune and nervous systems; this is counter-effective. The best defense against West Nile virus is a healthy immune system. If Manitoba continues to be unwilling to use safer alternatives to a toxin known to be harmful to specific subgroups of the population (as every other province has been able to do) and unwilling to allow the buffer zones, it must provide alternative accommodation including food, housing and expenses during the period of evacuation, as suggested by Saskatchewan's Chief Human Rights Commissioner (2), to the point of undue hardship, “a very high standard to meet”, according to Ontario's Chief Human Rights Commissioner. (10)

    Even if it denies that buffer zones are reasonable, under Section 12 of the     Code, the Province is clearly under the obligation to provide alternative accommodation:

    12 For the purpose of interpreting and applying sections 13 to18, the right to discriminate where bona fide and reasonable cause exists for the discrimination, or where the discrimination is based upon bona fide and reasonable requirements or qualifications, does not extend to the failure to make reasonable accommodation within the meaning of clause 9(1)(d).

  4. Below is a more detailed submission on the component of Manitoba's West Nile virus control program that is the subject of this Complaint. Manitoba reserves the right to respond further.
    The Complainant reserves the right to reply.

  5. The City of Winnipeg mosquito adulticiding program is for nuisance mosquitoes. It is not mandated by a health emergency. The City of Winnipeg uses the pesticide malathion in their mosquito program. The City is issued a permit, in accordance with Manitoba Regulation 94/88R under The Environment Act. The permit requires in part, that the City place public notification in the Winnipeg Free Press and Winnipeg Sun providing opportunity for any individual opposed to the use of these insecticides on, or adjacent to their property to individually register their objections in writing. The City is also to provide a 48 hour public notice prior to the commencement of mosquito adulticiding, and is to turn off adulticiding equipment 100 metres on each side of an objector's property in the front street, side street, and rear lane.
    Agreed.

  6. Since the buffer zone in the Complaint is not particularized we have assumed for the purposes of this Reply that the buffer zone in the City of Winnipeg permit is what is referred to.
    It is my understanding that all persons in Manitoba have a right to a buffer zone if their municipality is undertaking adulticiding. Again, please bear in mind that I am making these complaints on behalf of many other people.

    Can the Province please be held to at least the same standard of protection for the public through buffer zones as is required of the City?

  7. The situation about which this Complaint is filed is an entirely separate matter from the spraying for nuisance mosquitoes.
    It is agreed that the nuisance mosquito program is under the mandate of the City of Winnipeg, not the Province. In my opinion, anyone's use of toxic pesticides infringes on human rights.

  8. Manitoba, through a process involving numerous departments and agencies including both the Departments of Health and Conservation, has implemented a West Nile Virus Program (the Program) to deal with the emergence of the health threat posed by the West Nile virus, which can cause serious illness and death in humans.
    Pesticide exposures also cause serious illness and death in humans. (13) Furthermore, pesticides interfere with nervous and immune system functioning, thereby making all of us more susceptible to more severe forms of West Nile virus. (14)

  9. West Nile Virus can be transmitted to humans by mosquitoes, in particular Culex tarsalis mosquitoes. The goal of the Program is to assess risk and take appropriate measures to limit the adverse impact on human health of West Nile virus. The strategy includes: public education, surveillance – including corvid, equine, human, larval and adult mosquito surveillance, mapping of standing water where mosquitoes may lay their eggs, risk assessment, and mosquito control.
    Yes, as they say colloquially, Manitoba has covered its ass. It was pointed out to the Executive Director of Manitoba Health, as well as other representatives from Manitoba Departments of Health and Conservation in a meeting on July 19, 2005, that indeed Manitoba has done all that is required of it. It made intensive efforts to advertise the threat of West Nile virus, including telling the public how to safely protect themselves from mosquitoes (but not from pesticides). No other province takes steps beyond larviciding and Manitoba doesn't need to either. In fact, other provinces acknowledge that pesticides put human health at risk. (15)

  10. There are regional teams set up involving the Provincial Government, Regional Health Authorities and some municipalities. The educational component of the Program involves radio and news paper ads, pamphlets and posters. It includes information on West Nile virus self-protection measures to reduce exposure to mosquitoes and measures that individuals can take to reduce sources of standing water on their property. Information is also available through Health Links/Info Sante and on the Manitoba Health website, or by calling the local public health office. The website includes a schedule of adult mosquito control activities, as well as links to a fact sheet on malathion. There are also public presentations on these issues as requested.
    I repeat, the Province has done an exceptional job of advertising West Nile virus.

  11. The basic mosquito control plan involves several components: 1) source reduction, 2) larviciding and 3) adult mosquito control. The application of malathion by Ultra Low Volume (ULV) ground based spraying is but one component of the mosquito control program and it is important to note that it is employed as a last resort only when the other measures have not been successful in adequately reducing the risk to human health in any given mosquito season as was the case in certain communities in 2005.
    Please define     last resort and explain what steps were taken as a first resort in places other than Winnipeg? For example, does the province larvicide in all the rural communities it has demanded fogged, such as Deloraine, Carman, Portage, Steinbach, etc.? Where has the province undertaken source reduction measures? Has the province eliminated any standing water sites, such as stagnant toxic lagoons, which are potential habitat for Culex tarsalis?

  12. As the complaint is about one component of the Program, the ULV ground based spraying, Manitoba will not provide further details at this time on source reduction and larviciding actions that are undertaken, but these are critical components of the Program.
    Please do provide details about the other programs. Specifically, please explain why Winnipeg is still allowed to use Dursban for larviciding when it has been banned in other parts of Canada? Is Dursban being used elsewhere in the province?

    Adult Mosquito Control

    A) STATUTORY SCHEME

  13. The Minister of Health has the supervision of all matters relating to the preservation of life and health in the province of Manitoba. Section 2(1) of The Public Health Act provides:

    Duties of minister
    2(1) The minister has the supervision of all matters relating to the preservation
    of life and the health of the people of the province, and of all matters relating to
    the prevention of injury to life and limb not specifically dealt with under some
    other Act of the Legislature; and, without limiting the generality of the foregoing,
    he shall ......
    Why is the Minister ignoring this duty for those considered to be sensitive to pesticides?  Please note that he was made well aware of his duty on July 15, 2005. (16)

  14. In addition the Minister of Conservation has a duty under section 25.1(1) of The Environment Act which provides that:

    Order by minister to municipality re health emergency
    25.1(1) Notwithstanding anything in this Act, where the Minister of Health
    declares that a health emergency exists, or that one appears imminent, because
    of mosquitoes capable of transmitting diseases, the minister responsible for this
    Act may, by order, require a municipality to take measures specified in the order
    to prevent, minimize or alleviate the threat to health, on the terms and conditions
    and in the manner set out in the order.
    In Saskatchewan, health regions cannot protect the public health by putting at risk the health of those with disabilities. (2) We deserve the same protection in Manitoba.

    B) FACTS

  15. On July 14, 2005 the Minister of Health made a declaration that effective that date a health emergency appeared imminent in the City of Winnipeg because of the high prevalence of mosquitoes capable of transmitting West Nile virus. By that date the trap counts of Culex tarsalis were at the highest levels ever measured in Winnipeg since West Nile virus was first detected here in 2002. In addition, the number of mosquitoes infected with West Nile virus was high in parts of the City and weather conditions were conducive to mosquito development.
    Please note that in a meeting with the Minister of Health on July 15, 2005, he was made aware that the use of malathion could potentially increase the risk of humans acquiring WNv and of acquiring the more virulent form of WNv, and he was made aware that there is a substantial group of people made ill by pesticides. He was furthermore made aware that malathion is immunotoxic, neurotoxic, and genotoxic. (16)

According to the Minister, his decision to declare an imminent Health emergency to permit fogging was based in large part on a review of insecticides used for fogging which implies that fogging will reduce the risk of West Nile virus by about 70%. Neither the Minister nor any of his staff were able to answer the question as to whether this data came from mosquitoes that were in traps when fogging equipment was used, or whether this data reflected real-world situations where mosquitoes are able to hide or leave. Subsequent freedom of information act requests revealed that the data upon which the Minister based his decision was indeed from experiments in which mosquitoes were primarily trapped, and in fact, the fine print from that same report indicates that “in residential areas, the mean mortality was less than 26%.” (17) Whether out of ignorance or indifference, the Minister greatly and publicly exaggerated the effectiveness of the mosquito fogging program to the detriment of less toxic alternatives, and to the detriment of citizens upon whose behalf this complaint has been lodged.

  1. It should also be noted that the Culex tarsalis mosquitoes are the primary mosquito species that carries West Nile virus in Manitoba, and that the mosquito trap counts relied on by the Government are not the same trap counts undertaken by the City with respect to 'nuisance' mosquitoes.
    Trap counts have nothing to do with the issue. Manitoba's use of toxic pesticides infringes on human rights.

  2. In response to the Minister of Health's declaration respecting a public health emergency the Minister of Conservation issued an Order to the City of Winnipeg pursuant to section 25.5(1) of The Environment Act. The Order mandated the implementation of a mosquito adulticiding program within the City of Winnipeg using the product malathion dispersed by an ultra low volume cold aerosol method.
    This is a case of the fox ruling the hen house. The Department of Conservation regulates the permit process and, in many cases, it is also the applicator or it mandates the application, as in this case.

  3. Manitoba states that the Order was made in response to a declaration of an imminent public health emergency which requires Manitoba to take steps to alleviate the risk and to protect the public. Manitoba asserts that the declaration of the health emergency is not reviewable by the Commission.
    The Commission is not being asked to review the immensity of the error that was declaring a health emergency. The Commission is being asked to uphold the public's right to accommodation (such as safe lodging, travel expenses, meals and potentially, lost income) in the advent of further decisions to disperse the nerve toxin malathion into our environment without respecting buffer zones.

  4. Malathion is an organophosphate insecticide that is registered by Health Canada's Pest Management Regulatory Agency (PMRA) under the Pest Control Products Act (Canada). The PMRA is the federal agency responsible for the regulation of pest control products. The PMRA states that its “primary objective is to prevent unacceptable risks to people and the environment from the use of pest control products.”
    The PMRA is supposed to be governed by the new     Pest Control Products Act which received Royal assent in 2002, but which has yet to be enacted. (9) Before doing so, Health Canada is busy streamlining existing policy to be more in line with US policy (the so-called “smart regulations”). This is particularly disturbing, given the current US administration's attitude with respect to increasing risk to humans, particularly sensitive sub-populations. (18)

  5. Malathion was chosen as the product, and the ULV method selected, as best able to control the adult mosquito population in a safe way. Health Canada's PMRA “fact sheet on the use of malathion in mosquito control programs” from April 2003 states in part:


“Among the available mosquito control options, malathion has the most current and comprehensive safety information available. The adulticiding use of malathion has recently been reviewed by Health Canada's Pest Management Regulatory Agency (PMRA) under its re-evaluation program. Canadian regulators apply high safety standards and rigorous risk assessment approaches that include special consideration of risk to sensitive subpopulations such as infants and children. The PMRA's conclusions indicate that the continued use of malathion for adult mosquito control in residential areas, using ground or aerial ultra-low volume application, will not pose a health concern......Given the recent re-evaluation of malathion, and the measures to minimize exposure that are normally taken, the PMRA finds ultra-low volume application of malathion to be a safe practice for the control of adult mosquitoes that pose a nuisance or public health hazard.”
(emphasis added)
The more things change, the more they stay the same. Please permit a brief history lesson. I quote Manitoba relinquishing its responsibility to protect its populace on a previous occasion via the Clean Environment Commission:
"The Federal Government officials, responsible for pesticide registration and testing,
present at the hearings gave evidence to the Commission that Baygon is environmentally acceptable for aerial spraying when used in accordance with authorized dosage directions
and application procedures for this purpose. Nevertheless, the possibility exists that
exposure to aerial spraying may adversely affect persons in a high risk category, particularly
those persons with respiratory diseases and those with an unusual sensitivity to the
chemical. The Commission does not consider this sufficient reason for disallowing aerial spraying with the chemical since one can avoid exposure without undue hardship. But the fact that safety cannot be guaranteed for all persons makes it essential that all reasonable steps be taken to ensure that the public is made fully aware of the intention to spray and the timing thereof in each of the areas to be treated."
Manitoba Clean Environment Commission (19)

Twenty-one stillbirths were reported following the Baygon aerial spraying, including some who had organs growing on the outside of their bodies. (20) Baygon is no longer registered for use in Canada but because it was in 1981, the government of Manitoba felt justified in using it, just as they feel justified in using malathion now despite mounting evidence of its ill health effects.

  1. Manitoba states that the above noted decision, and determinations and registering decisions of the PMRA are not subject to review by the Commission, and are not within its jurisdiction.
    Agreed. The PMRA is subject to review by the Standing Committee on the Environment and Sustainable Development (1) and the Auditor General of Canada and it does not hold up well to the scrutiny. The first point of the Auditor General's 2003 report states “the federal government is not adequately ensuring that many pesticides used in Canada meet current standards for protecting health and the quality of the environment. The range of weaknesses we identified raises serious questions about the overall management of the health and environmental risks associated with pesticides.” (21)

  1. Manitoba denies that there is discrimination under the terms of The Human Rights Code.
    The Manitoba Human Rights Code (22) states:

"Discrimination" defined
9(1) In this Code, "discrimination" means

(d)failure to make reasonable accommodation for the special needs of any individual or group, if those special needs are based upon any characteristic referred to in subsection (2).

Applicable characteristics
9(2) The applicable characteristics for the purposes of clauses (1)(b) to (d) are

(l)physical or mental disability or related characteristics or circumstances, including reliance on a dog guide or other animal assistant, a wheelchair, or any other remedial appliance or device

Systemic discrimination
9(3) In this Code, "discrimination" includes any act or omission that results in discrimination within the meaning of subsection (1), regardless of the form that the act or omission takes and regardless of whether the person responsible for the act or omission intended to discriminate.

Reasonable accommodation required
12 For the purpose of interpreting and applying sections 13 to 18, the right to discriminate where bona fide and reasonable cause exists for the discrimination, or where the discrimination is based upon bona fide and reasonable requirements or qualifications, does not extend to the failure to make reasonable accommodation within the meaning of clause 9(1)(d).

    Those people who are most affected by pesticides are often in a position to be the least able to protect themselves. A simple announcement which is not site-specific, does not provide any alternatives (such as travel, housing, expenses, lost income etc), and is not necessarily accessed by everyone does not constitute reasonable accommodation.

It is sad to acknowledge that the right to breathe clean air must now be considered a “special need”
but for those of us affected by pesticides that has indeed become the case.

    C. ACCOMODATION

    29.  In the alternative, the Respondent asserts that if there is discrimination in services, there is a bona fide and reasonable cause for same and the Government has made reasonable accommodation for those who are particularly concerned about the effects of malathion, or concerned that they may be particularly adversely affected by it.
    Please forgive my ignorance. What accommodation has the government made?

    30.  The concern of the West Nile Virus Program, and the Order in particular is to protect the public health. If control of adult mosquitoes becomes necessary due to the inability of other methods undertaken in a given year to address the health risk, then that can reasonably be accomplished without harm to humans by use of malathion by Ultra Low Volume ground spraying.
    Humans have been and continue to be harmed by the use of malathion—that is precisely why this complaint has been lodged. Please refer to the attached letter from another chemically sensitive individual as anecdotal evidence of the harm to humans caused by malathion. (23)

    It is not reasonable to use a chemical toxic to the human nervous and immune systems as a defence against a virus which attacks the nervous and immune systems. Considerable research exists to indicate that exposure to toxic organophosphate pesticides such as malathion may increase the risk of both contracting the West Nile virus and suffering from its more virulent forms, such as encephalitis. (24)

    31.  Adult mosquitoes are extremely mobile and have a large potential range of travel. The elimination of buffer zones was done in order to maximize the effectiveness of the malathion spraying, and Manitoba states that allowing buffer zones in these circumstances would not be a reasonable accommodation.
    It is agreed that buffer zones are not reasonable. This point reflects the inadequacy of a standard 100-metre buffer zone to adequately protect the population, especially the more vulnerable sub-populations. It is known that drift from fogging can travel as much as 200 to1000 metres or more, depending on conditions. Unless entire communities (such as Wolseley) cooperate, individual buffer zones do not fully protect us. Interestingly, the Wolseley experience contradicts the theory behind the political decision to eliminate buffer zones. Before the health emergency was declared, predator bird and insect populations flourished in Wolseley, and residents will tell you that mosquito populations were minimal. (25)

    32.  In order to allow those with concerns about the application of malathion to take measures they consider appropriate, provision has been made for notification of the public. The Order specifically states that there shall be “advance notice to the public, in the print media, radio or on television, at least 24 hours prior to the commencement of the spraying program.”
    I refer you to my response for point #8; most of us cannot afford to evacuate the city for the weeks or months of repeated spraying. Expecting us to evacuate without assistance is unreasonable; factors such as cost (especially given the generally lower incomes and increased health costs of people with MCS or other disabilities) and timing (simply not enough notice, potential loss of income, and disruption of lifestyles) make evacuation extremely difficult. I am aware of many people considering leaving Winnipeg permanently because of this exact issue.

  1. There is also information provided to the public, as part of the education and information referred
    to above in this Reply as another component of the Program as to the best steps to take to reduce
    exposure such as closing windows and turning off air-conditioning units.
    I refer you again to my response for your point #8, toxic residues exceed those outdoors within 5 –
    6 hours after spraying. Please provide information to the public about how to protect their personal
    gardens, community gardens, playgrounds, children’s outdoor toys, lawn furniture, door handles,
    swimming pools, pets, etc. from pesticide exposures.

  1. Manitoba states that the Complaint against it should be dismissed.
    When     Manitoba stops poisoning its citizens, or starts providing adequate accomodation, there will
    be no further need to complain.

References

  1. Pesticides: Making the Right Choice for the Protection of Health and the Environment, House of Commons Canada Standing Committee on Environment and Sustainable Development

  2. Saskatchewan Chief Human Rights Commissioner Donna Scott writes on the subject of fogging for West Nile virus to Saskatchewan municipalities

  3. Ontario Chief Human Rights Commissioner Keith Norton writes to Ontario municipalities regarding possible plans to adulticide for West Nile virus

  4. The Canadian Human Rights Commission writes to other government departments and industry regarding their duty to accommodate should they consider fogging for West Nile virus

  5. Age dependence of organophosphate and carbamate neurotoxicity in the postnatal rat: extrapolation to the human, Toxicology and Applied Pharmacology 196 (2004) 287-302

  6. Immunotoxicity of Organophosphorous Pesticides, Ecotoxicology, 12, 345-363, 2003

  7. Molecular bases of hprt mutations in malathion-treated human T-lymphocytes, Mutation Research, 397 (1998) 137-148

  8. Malathion, What is it?, Genetics Laboratory, University of Vermont

  9. Canada Gazette, Part II, Vol 139, No 24, pages 2642-43

  10. Personal correspondence from Ottawa lawyer, Mike Christie

  11. No Protection staying indoors during pesticide spraying, Environmental Health Perspectives Volume 109, Number 1, January 2001

  12. Winnipeg Free Press, Who Makes What, February 6, 2006 and Virus, August 5, 2005

  13. Malathion Medical Research Index

  14. Official CCHE statement on the West Nile virus, Canadian Coalition for Health & Environment

  15. Read about the main features of the Pesticide Code of Quebec. Read the Pesticide Code of Quebec.

  16. July 16th, 2005 letter to Minister of Health Tim Sale and Minister of Conservation Stan Struthers

  17. Use of Malathion ULV for West Nile Vector Management, R. A. Ellis, 2005 (copy available upon request)

  18. U.S. increases risks, Policy News, February 2006

  19. Report on Mosquito Control Programs in Manitoba, Manitoba Clean Environment Commission, 1982

  20. Cities Under Siege, Irene Paparo-Stein, 1988

  21. Report of the Commissioner of the Environment and Sustainable Development to the House of Commons, Chapter 1: Managing the Safety and Accessibility of Pesticides

  22. The Human Rights Code of Manitoba

  23. Letter from Robin Faye to Glenda Whiteman in support of this HRC complaint (attached)

  24. Open Letter to Politicians, Civil Servants and Medical Officers of Health, by Concerned Residents of Winnipeg        

  25. Personal conversation with biologist and Wolseley resident, Dan Moroz


    Other useful resources

i Pesticides Literature Review by the Ontario College of Family Physicians

ii The Truth about Pesticides, by the Sierra Club of Canada

iii Malathion Breaks down into toxic Malaoxon, Bulletin of Environmental Toxicology

iv Chemical Watch Factsheet: Malathion by Beyond Pesticides

v Fact Sheet on the use of Malathion in Mosquito Control Programs by Health Canada

vi Hazardous Substance Fact Sheet: Malathion by the New Jersey State Department of Health
& Senior Services Right to Know Program

vii Why Canadian Physicians Are Concerned about the Policies Regulating Pesticide Use by the
Canadian Association of Physicians for the Environment

viii Chemical Trespass; Pesticides In Our Bodies and Corporate Accountability, by Pesticide
Action Network North America

ix Toxic Nation, Environmental Defence, November, 2005