Canada: Notice of intent to address the broad class of per- and polyfluoroalkyl substances
April 27, 2021
The Government of Canada intends to move forward with activities to address the broad class of per- and polyfluoroalkyl substances (PFAS) because scientific evidence to date indicates the PFAS used to replace regulated PFOS2 PFOA3 and long-chain PFCAs (LC-PFCAs)4 may also be associated with environmental and/or human health effects.
Substance-specific information is lacking for most PFAS that are currently used, including those that have been used to replace restricted PFAS. The large number of PFAS that are commercially available and their diverse chemical structures, combined with the lack of data on the hazards and properties of the individual substances, renders a traditional substance-by-substance assessment and management approach impractical. This has been recognized in publications prepared by a number of scientists following international meetings regarding PFAS, including the Zurich Statement, which recommends a grouping approach for this class of substances. Considering PFAS as a class of chemicals would better address situations where exposure occurs to multiple PFAS at the same time. This will allow the Government of Canada to consider cumulative effects, and to prevent regrettable substitutions.
In 2021, the Government of Canada will
- continue to invest in research and monitoring on PFAS;
- collect and examine information on PFAS to inform a class-based approach; and
- review policy developments in other jurisdictions.
In addition, within the next two years, the Government of Canada will publish a State of PFAS Report, which will summarize relevant information on the class of PFAS.
Stakeholder engagement is an important step to advance Canada's efforts. Stakeholders and interested parties will have opportunities to provide input to help inform Government of Canada activities related to addressing PFAS as a class. As a first step, stakeholders are invited to provide initial feedback on the intent to address PFAS as a class, including any challenges or opportunities they foresee. Contact information is provided below.
Rationale for action
In recent years, a growing number of jurisdictions, including in the United States, Australia, New Zealand, and the European Union, are addressing or are proposing to address PFAS as a class, including restricting specific uses in some jurisdictions. Often these actions relate to foams used to fight fuel fires, or to restricting non-essential uses where alternatives exist.
The Stockholm Convention on Persistent Organic Pollutants (POPs) requires its 184 Parties to eliminate or severely restrict PFOS and PFOA and advises against the use of other PFAS in firefighting foams. This recommendation was aimed at avoiding regrettable substitutions because they recognized that other PFAS could have similar hazard profiles and properties, potentially resulting in similar contamination of drinking water and the surrounding environment.
Per- and polyfluoroalkyl substances (PFAS) are a broad group of over 4 700 human-made substances that contain linked carbon and fluorine atoms. Because of their unique properties, they are used in a wide range of products, such as surfactants, lubricants, and repellents (for dirt, water, and grease). PFAS can also be found in other products as diverse as firefighting foams, textiles (e.g. carpets, furniture, and clothing), cosmetics, and in food packaging materials. PFAS are not manufactured in Canada but enter through importation, within products or manufactured items.
Well-studied PFAS have demonstrated the following characteristics:
- They are environmentally persistent and mobile within the environment. In the environment, they do not readily degrade under normal conditions and within organisms. Their persistence and potential for transformation from precursors to stable, toxic end products suggest that additional releases will add to current contamination, which would result in increased concentrations in the environment.
- They have been detected in humans, wildlife, and environmental media worldwide. While these substances do not occur naturally, certain PFAS have been detected in wildlife and humans around the globe, and can remain within humans and wildlife for years. Measurements of certain PFAS in umbilical cord blood and human breast milk suggest exposure during vulnerable life stages. Certain PFAS have also been found in drinking water, ice cores from the Arctic, soils, sediments, the oceans, the atmosphere, indoor air, and dust. Their presence in remote locations, such as the Canadian Arctic, indicates that they are subject to long-range transport (via the atmosphere and ocean currents).
- They biomagnify in food webs. Concentrations of certain PFAS are higher in top predators as a result of accumulation from consuming prey which contain lower levels. The increased exposure of wildlife higher in the food chain (e.g. polar bears, whales, seals and birds) may indicate that they are more likely to suffer adverse effects.
- They are associated with a range of adverse effects on the environment and effects that may have implications for human health. Laboratory studies in animals show that exposures to certain PFAS are associated with reproductive, developmental, endocrine, liver, kidney, and immunological effects. Well-studied PFAS, such as PFOA and PFOS, have been shown to cause tumours in animals at high doses. In epidemiological studies, exposure to PFOA and PFOS in humans has been associated with a range of effects, including but not limited to, effects on the liver, birth weight, metabolism, and the immune system. The clinical significance of these findings, and new data, continues to be examined.
Globally, PFAS have been found in the environment in close proximity to, and downstream from, point sources, such as manufacturing plants and sites where firefighting foams have been released (e.g. airports, military bases, and fuel storage areas). In Canada, a major point source of PFAS contamination is the use of firefighting foams to extinguish fuel fires or in the conduct of firefighting training and testing activities. PFAS can also be released to the environment during consumer use and disposal of PFAS-containing manufactured items; therefore, landfills and wastewater treatment facilities are potential sources of PFAS release.
Existing risk management measures and other activities in Canada for certain PFAS
The Government of Canada evaluated the risks of PFOS, PFOA, and LC-PFCAs, and published the findings in screening assessment reports in 2006 and 2012. These substances were found to be toxic to the environment, and added to the List of Toxic Substances under Schedule 1 of the Canadian Environmental Protection Act, 1999 (CEPA). As a result, measures to manage risks from these substances were put in place. In response to risk management measures taken over the past decade by the Government of Canada and other international jurisdictions, industry has shifted from using PFOS, PFOA and LC-PFCAs to using other PFAS as substitutes. The large majority of the 4 700 PFAS, as identified by the Organisation for Economic Co-operation and Development, have not been assessed and are not being managed globally.
In Canada, risk management actions for PFOS have been in place since 2008. Since 2016, the manufacture, use, sale, offer for sale or import of PFOS, PFOA, LC-PFCAs, and products that contain them have been prohibited, with a limited number of exemptions (e.g. manufactured items containing PFOA or LC-PFCAs) under the Prohibition of Certain Toxic Substances Regulations, 2012. In 2018, a consultation document was published outlining a proposal to further restrict these substances by removing all current exemptions. The proposed regulations are targeted for publication in the spring of 2021.
The Government of Canada conducts regular monitoring and surveillance of certain PFAS. For example, over the past decade, concentrations of certain PFAS in the blood of Canadians have been measured to establish baseline concentrations, track trends over time, and allow for comparisons with subpopulations. PFAS will continue to be monitored over time and reflect exposures from all sources, including air, dust, water, products, and food.
The federal government develops environmental quality guidelines to protect human health and the environment. Since 2018, the Guidelines for Canadian Drinking Water Quality for PFOS and PFOA, screening values for 9 other PFAS in drinking water, and Canadian soil screening values for 11 PFAS (including PFOS and PFOA) have been made available. Federal Environmental Quality Guidelines for PFOS in surface water, fish tissue, wildlife diet, and bird eggs also help assess the significance of PFOS concentrations in the environment, including contaminated sites.
Stakeholders are invited to submit relevant information or indicate their interest in being engaged in future discussions by emailing [email protected]. Stakeholders are also invited to subscribe to the Chemicals Management Plan subscription service to be kept informed of future information sessions and/or consultations.
Acting Director General
Industrial Sectors and Chemicals Directorate
Environment and Climate Change Canada
Science and Risk Assessment Directorate
Environment and Climate Change Canada
Safe Environments Directorate