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Public policy measures designed to promote and protect the health and wellbeing of Canadian children are being implemented in a piecemeal fashion and, as a result, far too many kids are falling through the cracks and suffering sickness and injuries, the Canadian Paediatric Society says.

To correct that lingering problem, governments need to put checks and balances in place in the form of an independent Child and Youth Commissioner, according to the group representing Canada's 2,500 pediatricians.

"The commissioner should be both an advocate and a bully pulpit," CPS president Robert Issenman said yesterday in Montreal.

A federal commissioner is needed, Dr. Issenman said, but each of the provinces and territories should have a similar office, to ensure that the voice of children is heard in legislative and policy matters. (Currently a number of provinces have child advocates, but they tend to be principally focused on children who are in the care of the state.)

"In the absence of advocacy, the needs of children will be lost in the tidal wave of adult concerns," Dr. Issenman said.

"There needs to be someone there to be asking the question: 'How does this affect children?' "

Yesterday, the CPS released a status report on public policies that affect children and youth.

The 28-page report, titled "Are We Doing Enough?" compared how provinces are faring in areas such as health promotion, disease prevention and injury prevention.

One of the areas where children and youth are most poorly served is mental health, according to the report.

About 1.1 million young people suffer from mental-health conditions that affect their daily lives, but there is no co-ordinated strategy, and shockingly long wait times for care in many jurisdictions, said Andrew Lynk, a pediatrician in Sydney, N.S., and lead author of the report.

Dr. Lynk said another area where children are being grossly neglected is in planning for an influenza pandemic. He noted that every government has a pandemic plan but only one, Ontario, has made detailed provisions for children.

Similarly, the report notes that child-safety legislation varies markedly between provinces and territories.

For example, seven of 13 jurisdictions have no bicycle helmet legislation, while four have sweeping laws requiring helmets for all wheeled sports, and two require them in only some circumstances.

Similar disparities exist in safety rules that establish the age at which someone can legally drive an all-terrain vehicle or snowmobile, and even the rules about what size of child must use a booster seat.

"There's no consistent approach to keeping kids safe in Canada," Dr. Issenman said. "Keeping them safe seems to depend on where they live."

The new CPS report was not universally critical.

In fact, the pediatricians' group dropped two points from this, the second edition of its status report, because the issues had essentially been resolved.

In its 2005 report, the CPS complained that emergency contraception was not available and that graduated licensing policies for young drivers were not in place, but in the past two years all provinces and territories have dealt with those issues.

"There was progress and that's good," Dr. Lynk said.

But he added that, with a Child and Youth Commissioner in place, these kinds of issues could be analyzed far more systematically and be addressed more quickly.

The CPS said that in its next report, due in two years, it will expand the focus of analysis to social issues like child poverty.

"Poverty is the single most important determinant of poor health in Canadian children," said Gary Pekeles, of the Montreal Children's Hospital and president-elect of the CPS.