The Water Does Not Know Whether You Are Working or Swimming
Why the same contaminated shoreline can trigger strict worker protections—but almost no visible public-health assessment
A person enters the Gorge Waterway in the morning as an employee. He may be diving, handling debris, disturbing bottom sediment or working beside an outfall.
Because he is at work, the employer must consider what may be in the water and sediment. If the environment is contaminated, WorkSafeBC requires an operational plan identifying the contaminants, possible health effects, specialized equipment, controlled work zones, decontamination procedures, medical precautions and emergency arrangements. (WorkSafeBC)
That same person finishes work, removes his protective equipment and returns to the same shoreline as a resident. He may swim, paddle, wade, dig in the mud with his grandchildren or launch a boat.
The contaminants have not changed. The sediment has not changed. The outfall has not moved. The person’s skin, lungs and digestive system are the same.
What changes is the administrative system responsible for protecting him.
At work, the starting assumption is that the hazard must be identified and controlled.
During recreation, the visible public-health response may consist primarily of periodic testing for fecal-indicator bacteria.
That difference is the heart of our concern.
This is not an attack on Island Health staff
We want to be clear from the beginning.
We are not claiming that Island Health lacks knowledgeable professionals. Island Health publicly announced in 2023 that it had created an environmental-health scientist position filled by Dr. Kobby Awuah, whose role included contaminant reviews, spill response and human-health risk assessments. Island Health described his work as protecting people from the health effects of chemicals. (Island Health)
Island Health also employs Medical Health Officers responsible for Greater Victoria and a Chief Medical Health Officer who leads public-health protection across the region. (Island Health)
That is encouraging.
It also sharpens the question.
Was this expertise actually used to assess recreational contact with historically contaminated sediment in the Gorge, Cecelia Cove, Banfield Park and the surrounding harbour?
Perhaps a thorough assessment has been completed and we have simply not seen it. Perhaps sediment chemistry, historical industrial activity, stormwater, direct skin contact, accidental ingestion and disturbance were all considered.
If so, that assessment could answer many of the concerns raised by residents, volunteers and organizations working in the waterway.
The difficulty is that the public record we have seen does not clearly show that such an assessment exists.
One person, two entirely different standards
Imagine the following ordinary day.
At 10 a.m., a worker is sent into water near contaminated sediment.
The employer must ask:
What chemicals or biological contaminants may be present?
Could the work disturb sediment?
What might be swallowed, inhaled or absorbed through the skin?
What protective clothing is needed?
How will contaminated equipment and workers be cleaned?
What happens if exposure occurs?
At 4 p.m., that worker returns with his family.
Now he is treated as a recreational user. The principal question may become:
What was the latest enterococci or E. coli result?
Fecal-indicator testing is important. Sewage pathogens can cause gastrointestinal, respiratory, skin, eye and ear illnesses. No responsible person would suggest abandoning bacterial testing.
But bacteria are not a substitute for assessing chemical contamination.
A sample showing acceptable enterococci levels does not tell us whether the sediment contains:
PAHs;
PCBs;
dioxins and furans;
petroleum hydrocarbons;
mercury or other metals;
pentachlorophenol;
pesticides;
pharmaceuticals;
endocrine-active compounds;
mixtures of historic and continuing urban contaminants.
It also tells us little about what happens when contaminated sediment is disturbed by children, swimmers, storm flows, construction, anchors, propellers or cleanup work.
Sediment is an exposure pathway, not simply the bottom of the water
There is a tendency to talk about contaminated sediment as though it were safely stored beneath the water.
That is not how shallow urban waterways behave.
Sediment can be:
touched directly;
swallowed accidentally;
carried onto hands;
trapped inside clothing;
resuspended into the water column;
transported by currents and storms;
inhaled as aerosols or particles under some conditions;
consumed by bottom-dwelling organisms;
transferred through fish and shellfish.
A Canadian exposure study estimated that recreational sediment ingestion could range from approximately 18 to 72 milligrams per hour, depending on age and activity. For people spending sustained periods in direct sediment contact, the estimated ingestion could exceed assumptions commonly used for ordinary soil exposure. (HERO)
A Swedish study did exactly the kind of work we are asking about. Researchers observed how people used an urban bathing area, sampled both water and sediment and calculated exposure to metals and PAHs. Oral exposure was important for metals, while skin absorption was more important for PAHs under the study assumptions. The particular site was ultimately found unlikely to present a significant public-health risk—but that conclusion followed an actual site-specific assessment. (PubMed)
That is an important distinction.
We are not arguing that the presence of contamination automatically proves that swimmers are being harmed.
We are arguing that the assessment must be performed before anyone can responsibly conclude that the risk is acceptable.
Even beach sand can matter
Research involving nearly 5,000 beachgoer interviews found associations between gastrointestinal illness and contact with fecally contaminated wet sand. Digging and being buried in sand were associated with increased illness where microbial contamination was higher. (PMC)
Broader scientific reviews describe beach sand as a potential reservoir for fecal indicators and pathogens, sometimes at concentrations greater than those measured in adjacent water. Children may receive greater exposure because they play actively in sand and have more frequent hand-to-mouth contact. (PMC)
Again, this does not prove illness at any particular Gorge location. It demonstrates that shoreline and sediment contact cannot simply be ignored because the overlying water looks clean.
Divers accidentally swallow water too
A study of occupational and recreational divers in the Netherlands measured accidental water ingestion during diving. It confirmed that divers swallow measurable quantities of water and that equipment such as full-face masks and helmets can reduce exposure. (PMC)
That helps explain why occupational rules are strict.
But it also creates an obvious public-health question.
A swimmer may swallow water. A child may swallow more. A paddler may fall in. A person digging in mud may transfer sediment from hand to mouth. A shoreline user with a cut may have direct contact for hours.
The exposure frequency may differ from that of a worker, but the pathway is real in both settings.
The correct scientific response is not:
Workers are workers and swimmers are swimmers.
It is:
What is the dose, how often does exposure occur, who is being exposed, and what contaminants are biologically available?
Health Canada already provides the framework
Canada is not short of scientific guidance.
Health Canada says recreational-water protection should use a preventive risk-management approach rather than relying only on laboratory monitoring. Its guidance calls for Environmental Health and Safety Surveys that consider biological, chemical and physical hazards. (Canada)
For possible chemical contamination, Health Canada recommends considering:
the history of the area;
previous activities that may have contaminated water or sediment;
outfalls and sewage discharges;
industrial discharges and spills;
contaminated runoff;
representative water and sediment chemistry;
toxicological information;
ingestion, inhalation and skin absorption;
the types and frequency of recreation;
tides, currents, depth, winds and other hydrodynamic conditions.
It also says chemical hazards should be assessed case by case and that primary-contact recreation may need to be restricted in areas or during periods of increased risk. (Canada)
This is remarkably close to what concerned residents have been asking about.
The question is therefore not whether Canadian science recognizes contaminated sediment as a possible recreational-health issue.
It does.
The question is whether that guidance has been applied here.
Why Europe provides a useful comparison
Europe has not solved every water-pollution problem. Its Bathing Water Directive also relies principally on E. coli and intestinal enterococci for bathing-water classification.
But the European system does something critically important: it surrounds bacterial monitoring with a legal management structure.
The European directive states that compliance must involve management and quality assurance, not merely measurement and calculation. Each designated bathing water must have a bathing-water profile identifying physical, geographic and hydrological conditions and pollution sources within the catchment that could affect bathers’ health. (EUR-Lex)
European authorities must also:
identify and assess pollution sources;
predict and manage recognizable short-term pollution;
warn the public;
explain why bathing is discouraged;
publish monitoring history;
identify responsible authorities;
describe actions being taken to address pollution.
The public must be given a plain-language description of the bathing water and access to the underlying profile. (EUR-Lex)
That does not mean every European beach receives continuous chemical testing.
It means the wider context cannot be quietly separated from the swimming area.
A European-style bathing-water profile for the Gorge would reasonably have to consider the connected system:
Cecelia Creek and Cecelia Cove;
Banfield Park;
stormwater outfalls;
historic industry;
contaminated shoreline and subtidal sediment;
sewer overflows and cross-connections;
rainfall;
tides and circulation;
sediment disturbance;
upstream municipal drainage;
public swimming, paddling, fishing and shoreline use.
Europe’s 2025 bathing-water report also makes the limitation clear: bacterial bathing-water classifications do not cover pollutants such as pharmaceuticals, pesticides and nutrients. Those are dealt with under wider European water legislation. (European Environment Agency)
That honesty is important.
An “excellent” bacterial classification is not presented as proof that every chemical or ecological question has been answered.
What kind of assessment is actually needed?
No single water sampler, engineer, physician or biologist can properly answer every question at a complex urban harbour site.
A credible assessment would normally involve several disciplines.
The lead should be an experienced human-health risk assessor, toxicologist or exposure scientist—usually someone with graduate-level training in environmental toxicology, public health, environmental chemistry, pharmacology or exposure science.
That person would need to evaluate:
accidental water ingestion;
sediment ingestion;
skin absorption;
inhalation where relevant;
short-term and repeated exposure;
children and adults;
cancer and non-cancer effects;
mixtures and cumulative exposure;
uncertainty and missing information.
The team would also need:
an environmental chemist to design and validate sampling;
a sediment scientist, hydrogeologist or environmental engineer to examine movement and resuspension;
a microbiologist to assess sewage, pathogens and microbial source tracking;
an occupational hygienist to compare workers, divers and public users;
an epidemiologist or public-health physician to interpret population risk;
an aquatic toxicologist or biologist to address bioaccumulation and food-web effects.
Professional qualifications matter. So does direct experience.
A professional designation in engineering or biology does not automatically establish competence in dioxin toxicology. A toxicologist does not automatically understand tidal sediment transport. A physician does not automatically know how to design sediment-core sampling.
The strength comes from assembling the right team and openly documenting who performed each part.
Island Health appears to have access to relevant expertise
This is why we do not want the story reduced to an accusation that Island Health staff are unqualified.
Island Health has publicly described an environmental scientist position specifically intended to provide scientific support for:
human-health risk assessments;
contaminant reviews;
spills;
groundwater contamination;
chemical impacts on human health. (Island Health)
Its Medical Health Officers have the authority and public-health training needed to interpret that work and decide whether preventive action, further investigation or public advice is appropriate. (Island Health)
Environmental Health Officers also have important roles in beach monitoring, inspection, communication and enforcement.
The concern is not necessarily the absence of capable people.
It is the absence of a visible process showing:
what evidence was reviewed;
what questions were asked;
what exposure pathways were assessed;
which specialists participated;
who reached the conclusion;
what uncertainties remain.
A brief assurance is not the same thing as a signed human-health risk assessment.
A bacterial sample is not the same thing as a contaminated-sediment evaluation.
A construction environmental plan is not automatically a recreational-health assessment.
An ecological assessment is not automatically a human-health assessment.
Each may provide a useful part of the answer. None should be mistaken for the whole answer.
Why this matters particularly in the Gorge
The Gorge is not an untouched wilderness swimming hole.
It is an urban receiving water surrounded by more than a century of development, road runoff, industrial activity, sewer infrastructure and stormwater drainage.
It is also a place where people are increasingly encouraged to:
swim;
paddle;
wade;
use public docks;
attend water events;
restore habitat;
volunteer;
work;
bring children.
The more strongly governments promote public access and swimming, the greater their responsibility to understand and communicate the complete exposure setting.
Clean-looking water can still lie over contaminated sediment.
A passing bacterial result does not erase historical contamination.
Likewise, historical contamination does not automatically prove that current recreation is unsafe.
Between those two statements lies the work that needs to be done: a proper assessment.
We are looking for answers, not villains
Our purpose is not to frighten people away from the Gorge. For more than thirty years, our work has been directed toward restoring the waterway and reconnecting people with it.
We want the Gorge to be swimmable.
But “swimmable” must mean more than meeting a bacterial number on the day a sample happened to be taken.
It should mean that authorities have considered:
sewage;
stormwater;
contaminated sediment;
chemical mixtures;
children’s exposure;
frequent users;
sediment disturbance;
changing tides and weather;
historic and continuing pollution sources.
We may discover that the risks are low. That would be welcome news.
We may discover that certain areas or activities require precautions, remediation or better public information.
Either result would be more useful than uncertainty hidden behind administrative boundaries.
An invitation to those who know this field
There may be toxicologists, public-health physicians, occupational hygienists, environmental chemists, sediment scientists, engineers, microbiologists and regulators reading this who can help clarify the issue.
Perhaps Island Health has already completed the necessary work.
Perhaps another agency holds an assessment we have not located.
Perhaps European or Canadian examples can help establish a practical model for the Gorge.
We welcome those answers.
The question is simple enough for the public to understand:
If an employer must investigate and control exposure before sending a worker into contaminated water, what scientific process determines that the same location is suitable for unrestricted public recreation?
The water does not know whether the person entering it is an employee, a volunteer, a swimmer or a child.
Our health-protection system should be able to explain why the level of protection changes when the person’s role changes—and show the evidence supporting that decision.
Studies, Reports and Regulatory References
The following sources establish recognized exposure pathways, professional assessment methods and regulatory approaches. They do not, by themselves, prove that a particular Gorge location is unsafe; that requires a site-specific human-health risk assessment.
Canadian public-health and contaminated-sediment guidance
Health Canada — Federal Contaminated Site Risk Assessment in Canada: Supplemental Guidance on Human Health Risk Assessment of Contaminated Sediments—Direct Contact Pathway (2017).
Covers accidental sediment ingestion, skin contact and inhalation of sediment particles. It recognizes that sediment adherence, ingestion and exposed skin area may be greater than ordinary soil-assessment assumptions.
Read the Health Canada guidance (Canada)Health Canada — Guidelines for Canadian Recreational Water Quality: Summary Document (2024).
Identifies biological, chemical and physical hazards as parts of recreational-water protection and states that higher-risk chemical locations should be identified through an Environmental Health and Safety Survey.
Read the summary document (Canada)Health Canada — Guidelines for Canadian Recreational Water Quality: Physical, Aesthetic and Chemical Characteristics (2022).
Calls for case-by-case assessment of chemical hazards and consideration of site history, contaminated water and sediment, outfalls, runoff, representative sampling, toxicology, ingestion, skin absorption, inhalation, tides and currents.
Read the complete guideline (Canada)Health Canada — Understanding and Managing Risks in Recreational Waters (2023).
Describes the preventive risk-management approach and Environmental Health and Safety Surveys rather than relying solely on periodic laboratory samples.
Read the guidelineHealth Canada — Indicators of Fecal Contamination in Recreational Waters (2023).
Explains the role and limitations of E. coli and intestinal enterococci as indicators of fecal contamination. These organisms do not measure chemical contamination.
Read the technical document (Canada)Health Canada — Microbiological Pathogens and Other Biological Hazards (2023).
Reviews pathogens, beach sand, illness studies and biological hazards not fully described by routine indicator counts.
Read the technical document (Canada)Health Canada — Microbiological Sampling and Analysis (2024).
Covers sampling design, frequency, laboratory analysis and interpretation of recreational-water microbiology.
Read the technical document (Canada)
Occupational and contaminated-water diving protection
WorkSafeBC Occupational Health and Safety Regulation, Section 24.66—Contaminated Environments.
Requires identification of contaminants, health effects, specialized clothing and equipment, controlled zones, decontamination, first aid and emergency procedures before contaminated-water diving begins.
Read section 24.66 (WorkSafeBC)United States Environmental Protection Agency — Diving Safety Manual, Revision 2.0 (2022).
Includes contaminated-water diving procedures, dry suits, full-face masks, surface-supplied air, controlled work zones and diver and equipment decontamination.
Read the EPA manual (EPA Nepis)United States Navy — Guidance for Diving in Contaminated Waters (2019).
Provides technical guidance for chemical and biological hazards, protective equipment, risk classification, diving procedures and decontamination.
Visit the Navy contaminated-water diving resourceSchijven and de Roda Husman — “A Survey of Diving Behaviour and Accidental Water Ingestion Among Dutch Occupational and Sport Divers” (2006).
Demonstrated that both occupational and recreational divers accidentally swallow measurable amounts of water and examined resulting microbial risks.
Read the full study — DOI: 10.1289/ehp.8523 (PubMed)
Direct sediment exposure and human-health risk
Wilson et al. — “Estimation of Sediment Ingestion Rates Based on Hand-to-Mouth Contact and Incidental Surface-Water Ingestion” (2015).
Estimated recreational sediment ingestion rates of approximately 18–72 milligrams per hour across different age groups and activities.
Study summary — DOI: 10.1080/10807039.2014.974498 (HERO)Filipsson et al. — “Exposure to Contaminated Sediments During Recreational Activities at a Public Bathing Place” (2009).
A Swedish site-specific assessment combining observation of bathing behaviour with water and sediment testing. It evaluated oral exposure to metals and dermal exposure to PAHs.
PubMed summary — DOI: 10.1016/j.jhazmat.2009.05.128 (PubMed)Hussain et al. — “Lifetime Health Risk Assessment from Exposure of Recreational Users to Polycyclic Aromatic Hydrocarbons” (1998).
Canadian study of sediment at beaches and harbours in Ontario assessing lifetime skin-cancer risk from dermal PAH exposure.
Study summary — DOI: 10.1007/s002449900412 (HERO)Rakowska et al. — “In Situ Remediation of Contaminated Sediments Using Carbonaceous Materials” (2012).
Reviews contaminated sediment, porewater, bioavailability, bioaccumulation, capping and remediation. It also discusses the danger of contaminant resuspension during disturbance or incomplete removal.
PubMed summary — DOI: 10.1002/etc.1763 (Wageningen Research Portal)Arp et al. — “Influence of Historical Industrial Epochs on Porewater and Partitioning Profiles of PAHs and PCBs in Oslo Harbour Sediment Cores” (2011).
Shows that older industrial contamination may be buried beneath newer sediment but can be re-exposed by erosion, dredging or propeller wash.
PubMed summary — DOI: 10.1002/etc.466 (PubMed)Hilscherová et al. — “Seasonally and Regionally Determined Indication Potential of Bioassays in Contaminated River Sediments” (2010).
Used chemical measurements together with tests for dioxin-like activity, estrogenic and anti-androgenic effects, showing the value of biological-effects testing for complex contaminant mixtures.
DOI: 10.1002/etc.83
Beach sand, microorganisms and illness
Heaney et al. — “Contact with Beach Sand Among Beachgoers and Risk of Illness” (2009).
Based on 27,365 interviews at seven beaches. Digging in or being buried in sand was associated with increased gastrointestinal illness and diarrhea, with important variation among beaches.
Journal abstract — DOI: 10.1093/aje/kwp152 (Johns Hopkins University)Heaney et al. — “Fecal Indicators in Sand, Sand Contact, and Risk of Enteric Illness Among Beachgoers” (2012).
Examined 144 wet-sand samples and 4,999 beachgoer interviews. Higher microbial contamination in sand was associated with increased gastrointestinal illness among people contacting the sand.
Read the full study — DOI: 10.1097/EDE.0b013e31823b504c (PMC)World Health Organization — Guidelines on Recreational Water Quality, Volume 1: Coastal and Fresh Waters (2021).
Includes beach profiles, sanitary inspections, microbial hazards, beach sand, cyanobacteria, pollution-source management and public communication.
Read the WHO guidance through NCBI
European bathing-water and watershed management
European Union Bathing Water Directive—Directive 2006/7/EC.
Requires designated bathing waters, four-year classifications, bathing-water profiles, pollution-source identification, short-term pollution management, public warnings and corrective measures.
Read the directive (EUR-Lex)European Environment Agency — European Bathing Water Quality in 2025.
Reports European bathing-water classifications and explains that bacterial bathing-water ratings do not cover chemical contaminants such as pharmaceuticals and pesticides, which are addressed under other EU laws.
Read the 2025 report (European Environment Agency)European Union Water Framework Directive—Directive 2000/60/EC.
Establishes river-basin management, prevention of deterioration, ecological and chemical status assessment and coordinated pollution-control measures across municipal and political boundaries.
Read the European Commission overviewEuropean Union Urban Wastewater Treatment Directive—Directive 2024/3019.
Expands controls for sewage, stormwater overflows and urban runoff and introduces stronger requirements for micropollutant monitoring and advanced wastewater treatment.
Read the directiveKrupska et al. — “Forecasting Bathing Water Quality in the UK: A Critical Review” (2024).
Reviews rainfall, river-flow, tide, wind and other forecasting systems used to warn bathers before delayed laboratory results become available.
Read the open-access review — DOI: 10.1002/wat2.1718 (Wires)Stidson, Gray and McPhail — “Development and Use of Modelling Techniques for Real-Time Bathing-Water Quality Predictions” (2012).
Describes Scotland’s use of rainfall and river-flow information to predict short-term pollution and issue timely public advice.
DOI: 10.1111/j.1747-6593.2011.00258.xCao et al. — “Reimagining Urban River Bathing in Europe: A Multisectoral and Interdisciplinary Dive into Lyon’s Rivers” (2025).
Addresses urban river bathing through public health, microbiology, contaminated sediment, stormwater, ecology, law, public safety and urban planning.
DOI: 10.1002/rra.70050
Local program and professional-capacity references
Island Health — Recreational Water and Beach Reports.
Describes Island Health’s bacterial sampling, advisory process and risk-based monitoring frequencies for Vancouver Island beaches.
Read the Island Health beach-program pageIsland Health — Profile of Environmental Health Scientist Dr. Kobby Awuah.
Island Health describes this position as providing scientific support for contaminant reviews, spills and human-health risk assessments.
Read the Island Health profileIsland Health — Medical Health Officers.
Identifies the Medical Health Officers responsible for Greater Victoria and other Vancouver Island regions and their statutory public-health roles.
View Island Health’s Medical Health Officers
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