Presentation to the Standing Senate Committee on Social Affairs, Science and
Technology regarding Bill C-314 (The Breast Density Awareness Act)
May 29, 2013, Ottawa
Anne Rochon Ford
I am honoured to be able to speak to you today. My name is Anne Rochon Ford
and I am the Executive Director of the Canadian Women’s Health Network
(CWHN). There are a number of issues that this Act raises which I am pleased to
review with you on behalf of my organization.
The CWHN is this month celebrating its 20th anniversary. We are a non-profit
network of individuals and organizations united by interest in women’s health and
the policies that shape it. We provide trusted, independent women’s health
information aimed at improving the health of women and girls via our on-line
magazine, a 15,000-item on-line database, and 7,000 web-based links to
community organizations. We are a fully bilingual organization operating out of
Winnipeg and Toronto. For the general public and for health professionals we
provide on-line seminars, undertake research projects and produce a wide range
of educational materials. For 18 years we acted as the communication hub for the
Centres of Excellence for Women’s Health Program funded by Health Canada. A
complete cut to funding to this program was announced in the 2012 federal
budget and put into effect in April 2013.
Addressing the Breast Density Awareness Act
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A range of scientific studies have demonstrated clearly a relationship between
dense breast tissue and risk for breast cancer. On this basis, Canada’s move to
pass an Act related to this observation is in keeping with a trend begun in the U.S.
to develop legislation centred on specific mammographic assessments related to
breast density and we note that breast-density notification laws have been
enacted in several U.S. states.
As with all new policies introduced by Parliament, the CWHN seeks to ensure that
the needs of all or most women are addressed and that what is being proposed is
in the best interests of all or most women. Our worry is that this proposed Act, by
raising as many questions as it addresses, may fall short.
Specific questions raised by the Act:
1) What is driving this Act? Is it the result of scientific inquiry by independentthinking radiologists and oncologists working in the field? And is it backed
by concerned women and their families? Or have the commercial interests
of those manufacturing and promoting the new technology filling the
mammographic landscape played a role behind the scenes in moving this
legislation forward? If this is driven more by the latter than by the former,
we must question if this is truly in women’s best interest. The CWHN
supports the creation of new health policies based on evidence that is free
of commercial bias.
2) The Act does not mention women’s need for resources that will improve
their awareness and mentions only “the use of existing programs and other
initiatives”. Does the government intend to provide funds to allow for the
work that is outlined in the Act under 2. (a) (b) and (c) which represents a
considerable body of new research?
3) If relatively new technologies such as breast tomosynthesis, or 3D
Mammography, are proposed for use to improve the quality of
mammographic screening for women with dense breast tissue, we have
other questions: while studies may have demonstrated that these tools can
provide more detailed and useful readings, their use also doubles the
amount of radiation received by the breast.i This is a significant
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consideration, given the growing body of evidence showing the harms
related to increased radiation exposure.
4) What role is hormone replacement therapy (HRT) playing in the increase in
frequency of women with dense breast tissue? Up to a quarter of women
who start to use estrogen only or combined estrogen and progesterone
hormone preparations have increases in breast density.ii Canada’s SOGC
continues to promote a qualified use of HRT. Should we be creating
additional methods to detect cancers in women with dense breast tissue,
or looking more closely at the factors contributing to dense breast tissue
and the growing number of women with this?
5) Given the relationship between obesity and dense breast tissue, and the
on-average, higher rates of obesity in Canada’s First Nations communities,
are any provisions being made to specifically address the possible
additional or different needs of women in First Nations communities (e.g.
information/awareness outreach tailored for language and cultural
difference; real access to mammography; etc.)? Similarly, if there are racial
variances in breast tissue density, are those communities being identified
for particular attention?
While there is a need for the refinement of screening technologies, we must
remember that screening is secondary – not primary – prevention. There is a need
for both in the fight against breast cancer, but resources directed to primary
prevention should at least equal those aimed at secondary prevention and at the
moment they do not match. Increased funding for more screening technologies
will only widen this gap further. Moreover, the hype created by recent celebrity
media attention to breast cancer will no doubt drive more women to believe
(falsely) that only more, not less, screening is what they need.
We acknowledge the important role that breast cancer screening plays in the fight
against breast cancer but far more public education is needed about the very
slow-growing nature of most breast cancers. To site Wendy Armstrong of the
Consumers Association of Alberta on this issue: "It's almost like people see
screening as some kind of force field that protects them from even getting
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disease and, remarkably, the more screening some people have, the more they
suffer uncertainty and fear and desire more."
The Need for More Attention to Primary Prevention
It is commonly understood that in only 5 to 10 percent of new breast cancers is
there a familial genetic link. This raises the question of what is causing the vast
majority of cancers.
If we relied only on reports in the popular media (which many women do) we
might think breast cancer was the result of defective genes we may have
inherited, or the lifestyle choices we make. This only answers part of the question.
It is estimated that more than half of breast cancers cannot be explained by
traditionally understood causes such as genetic mutations, reproductive history,
and lifestyle factors such as weight gain, alcohol consumption and lack of physical
exercise.
A growing body of scientific evidence demonstrates that exposure to a wide range
of toxic chemicals – in the air, water, cleaning and personal care products; in
household furniture and carpets; in medical treatments; in the linings of canned
foods as well as in the toys our children play with, and in the cars we drive – can
increase ones risk of breast cancer. In our daily lives, over the course of weeks,
months, and years, we are exposed to a myriad of common chemicals, in varying
mixtures and in dosages that are shown to be altering hormonal profiles and
biological processes that may be leading to breast cancer risk.
A survey conducted by the Silent Spring Institute in 2007 indicated that 216
chemicals and radiation sources have been recognized by national (U.S.) and
international regulatory agencies as being implicated in breast cancer causation.iii
And that number only represents the ones that have been identified – and does
not include a wide array of endocrine disrupting chemicals (EDCs) such as
bisphenol A, dioxins, parabens, and phthalates.
More recently, and in Canada, researchers affiliated with the National Network on
Environments and Women’s Health at York University – with funding, in part, by
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from Health Canada and the Canadian Breast Cancer Foundation - recently
completed a six-year studyiv in which they identified a clear link between
workplace chemical exposures and increased breast cancer risk. The key finding of
the six-year study was that young women working in the automotive plastics and
food packing industries are five times more likely to have breast cancer than
women working in other industries.
One of the study’s conclusions was that while there may not yet be sufficient
human evidence to satisfy agencies evaluating chemicals for their carcinogenicity,
there is ample evidence upon which to base prevention strategies in
environments such as specific workplace settings where elevated risks have been
identified.
This work – and a growing body of similar work on occupational and
environmental links to breast cancer (I would direct you to the report, “State of
the Evidence: The Connection Between Breast Cancer and the Environment” http://www.breastcancerfund.org/assets/pdfs/publications/state-of-theevidence-2010.pdf - for further elaboration and substantiation) give credence to
the concept that some breast cancers may be prevented.
There are still many unanswered questions about what causes breast density and
the full health impact of increased amounts of screening. While we support the
need for patients being made aware of information held by their care providers,
we must also invoke the Precautionary Principle in making policies and in making
decisions about where our health care dollars are best spent.
i
Kaunitz, Andrew. 3D Mammography: Coming to a Screening Near You? Medscape, May 17, 2013
Greendale G, Reboussin B, Aie A, et al. Effects of estrogen and estrogen-progestin on mammographic
parenchymal density. Ann Intern Med 1999;130:262–9
iii
Rudel RA, Attfield KASchifano JN, Brody JG. (2007) Chemicals causing mammary gland tumours in animals signal
new directions for epidemiology, chemicals testing and risk assessment for breast cancer prevention. Cancer 109
Issue S12: 2635-2666
iv
Brophy, J., Keith, M., Watterson, A., Park, R., Gilbertson, M., Maticka-Tyndale, E., Beck, M., Abu-Zahra, H.,
Schneider, K., Reinhartz, A., DeMatteo, R., & Luginaah, I. (2012). Breast cancer risk in relation to occupations with
exposure to carcinogens and endocrine disruptors: a Canadian case control study. Environmental Health.
http://www.ehjournal.net
ii
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