JUNK SCIENCE: ISN'T IT WONDERFUL FOR POLLUTERS?

The first obvious question is why isn't the Ontario Ministry of Environment, Conservation and Parks (MECP) taking Lanxess and GHD to task for their junk science? Maybe I'm mistaken and MECP actually stands for Ministry of Enhanced Corporate Pollution. You the readers feel free to interpret the following data in Lanxess's just released "2017 Canagagigue Creek Sediment and Floodplain Soil Investigation".


MOE Table 8 criteria.(ppm.)../...ISQG (interim sed quality guide)(ppm.)


DDD ....... .008 .............../...... .00354

DDE ...... .005 .............../...... .00142

DDT ...... .007 .............../...... .00119



Five different locations in the creek have the following numbers of samples with non detect values rather than a specific numerical value for DDD, DDE, and DDT. These non detects are all at detection limits many times greater than both the criteria listed immediately above.

Figure 6.2 102 non detects at a detection limit of .020 ppm. This detection limit is 2 1/2 to 6 times greater than the two relevant criteria for DDD. The detection limit is 4 to 16 times greater than the two relevant criteria for DDE. The detection limit is nearly 3 to 18 times greater than the two relevant criteria for DDT. Therefore large numbers of exceedances are most probably being missed with these method detection limits being so much higher than the criteria set for these toxic chemicals found in the Canagagigue Creek.

Figure 6.2 102 as mentioned immediately above.

Figure 6.4 231 non detects at a detection limit of .020 ppm.

Figure 6.6 155 non detects at a detection limit of .020 ppm.

Figure 6.8 194 non detects at a detection limit of .020 ppm.

Figure 6.10 95 non detects at a detection limit of .020 ppm.


There are other non detects at even higher method detection limits for these three chemicals (DDD, DDE, DDT). These higher detection limits vary from .030 ppm to .22 ppm and include many at .030, .040, and .060 ppm. There is 1 at each of the following detection limits: .072, .10, .12, and .22 ppm. The total number of non detects at these ridiculously higher detection limits is 46.

It is my submission that there are vastly greater numbers of non detections in the creek than there are detections (approx. 800 non detects versus 200 detections. This gives the incorrect and inaccurate impression that the Canagagigue Creek is in far better condition than it actually is.