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While there’s less media and legal attention on PFAS in Canada compared with the United States, the Government of Canada is definitely getting more active on PFAS. In July 2024, Canada released a revised risk management scope for PFAS. While the keenly awaited drinking water guidelines are not out yet (later this summer?), this document provides a valuable look at where Canadian Environmental Protection Act (CEPA) regulation will be focused. Some points of summary to note
Toxicity
Canada concludes that the class of PFAS (excluding fluoropolymers!) are toxic under CEPA 64(a) and 64(c) on ecotoxicological harm and chronic human harm, but not under 64(b) which deals with acute/immediate danger. The report recommends PFAS be added to Part 2 in Schedule 1 to CEPA. The discussion around regulating PFAS as a class as opposed to individual substances to be regulated separately has been contentious and it’s interesting to see Canada confirm intent to look at PFAS as a class of substances, not solely as individuals.
Regulation
The proposal is to add PFAS as a class to Part 2, which prioritizes pollution prevention and regulatory/other measures rather than to Part 1, which is stricter and can include prohibition of activities, release and monitoring. The report mentions there will updates and potential movement to Part 1 based on updated risk assessments for PFAS of specific priority.
Exclusion of fluoropolymers
The current exclusion of fluoropolymers is important and likely to be misinterpreted, so read this carefully! Every current definition of PFAS includes polymeric PFAS that have been swept into the same discussion as small-molecule PFAS which have well-established toxicity concerns. The policy document divides polymeric PFAS into three distinct categories
- Fluoropolymers. Polymers made from an olefinic CF2 backbone. Polytetrafluoroethylene (PTFE) is the best example
- Perfluoropolyethers or PFPEs which contain ether (oxygen) linkages in addition to the CF2- chain.
- Side-chain fluoropolymers have a non-fluorinated polymer backbone, and with fluorinated structures on the side-chain to add waterproofing/other desirable properties
Only fluoropolymers are excluded and this is a critical point as most people don’t get lost in the details of polymeric PFAS types. The document recognizes that the classic fluoropolymers are different enough in properties to warrant a separate risk assessment, There’s considerable evidence including groundbreaking work by Environment Canada scientists such as Robert Letcher that show side-chain polymers can release small molecule PFAS into the environment from degradation/transformation. There is a lot more detail in Canada’s state of PFAS report if you’re interested.
Risk Management Priorities (AFFF and the rest)
Firefighting foams (AFFFs) not currently regulated are going to be the first priority. Canada currently only restricts PFOS-containing AFFFs. This proposed risk assessment framework adds C8 AFFF to the phase out list for end of 2025 while putting C6 AFFF to the “under consideration” list. The full phaseout of PFAS from AFFF is will depend on the successful addition of PFAS to Schedule 1, which is proposed. For context, US Military has added fluorine-free foams (F3) to their qualified products list (QPL) and the US federal aviation administration has also published a transition plan to F3. So AFFF will be Canada’s first priority, and all other PFAS uses will follow based on prioritization
Monitoring
The government proposes to continue and expand the monitoring of PFAS both under the Chemical Management Plan (CMP) and biomonitoring using the Canadian Health Measures Survey (CHMS). So look for more data coming out on PFAS in Canada soon. Compliance monitoring will start in 2024 with biosolids under the CFIA, and the drinking water guidelines to be announced later this year will trigger further testing. SGS specializes in measuring PFAS in all relevant compartments and has provided data to support government PFAS priorities for 15+ years. So we will continue to keep you informed on what’s happening on this front!