Consultation Document on Phase 1 of the Risk Management of Per- and Polyfluoroalkyl Substances (PFAS), Excluding Fluoropolymers: Prohibition of the Use of PFAS, not Currently Regulated, in Firefighting Foams

A joint statement by five Canadian environmental and health organizations—Ecojustice, Breast Cancer Action Quebec, the Canadian Association of Physicians for the Environment, the David Suzuki Foundation, and Environmental Defence—providing feedback on the 'Consultation Document on Phase 1 of the Risk Management of Per- and Polyfluoroalkyl Substances (PFAS), Excluding Fluoropolymers: Prohibition of the Use of PFAS, not Currently Regulated, in Firefighting Foams'. While the organizations support the proposed risk management measures and their alignment with European Union and Washington State standards, they strongly criticize the proposed implementation timelines, which could allow some facilities to use PFAS-containing foams until 2039.

• The submitting organizations support the proposed risk management tools for Phase 1, specifically those aligning Canadian regulations with the EU and the State of Washington. These include transitional periods, disclosure and labelling requirements, AFFF management plans, record keeping, permits for transition-period extensions, and incidental presence concentration thresholds.
• The organizations express deep concern over the proposed phaseout timelines, noting that a final risk management instrument is not expected until 2029. Under the current proposal, certain facilities could continue using PFAS-containing firefighting foams until 2039, which the authors argue is an 'indefensible exacerbation of the crisis'.
• The document highlights severe health risks for firefighters, stating they are exposed to high levels of PFAS in both firefighting foams (AFFF) and protective 'turnout gear'. It cites data indicating that 94% of line-of-duty deaths among firefighters are caused by occupational cancers, and that firefighters face an increased risk for eight specific cancers compared to the general population.
• PFAS-containing foams are identified as a source of widespread environmental contamination in Canada, affecting soils, drinking water, and aquatic species. The document notes that for Indigenous people and other communities, a single serving of contaminated freshwater fish can be equivalent to drinking PFAS-contaminated water for a month.
• The authors argue that viable alternatives to PFAS-containing foams already exist, such as fluorine-free firefighting foams (F3 or SFFF) and non-foam suppression systems like encapsulator agents. They reference the Consultation Document's finding that nothing suggests F3 foams cannot work for all scenarios previously managed by AFFF.
• The organizations recommend that the government expedite the final order listing the class of PFAS (excluding fluoropolymers) as toxic under the Canadian Environmental Protection Act, 1999 (CEPA), as this listing is a prerequisite for implementing the risk management instruments.
• Regarding high-hazard facilities eligible for a 6-year transitional period, the authors suggest implementing strong accountability and inspection measures. They propose adopting inspection protocols from the EU's Seveso III Directive, which would require site visits at least every three years.

APA

Canadian Association of Physicians for the Environment (2025). Consultation Document on Phase 1 of the Risk Management of Per- and Polyfluoroalkyl Substances (PFAS), Excluding Fluoropolymers: Prohibition of the Use of PFAS, not Currently Regulated, in Firefighting Foams. https://cape.ca/wp-content/uploads/2026/01/Comments-Re-Consultation-Document-on-Phase-1-of-the-Risk-Management-of-Per-and-Polyfluoroalkyl-Substances-PFAS.pdf

Chicago

Canadian Association of Physicians for the Environment. Consultation Document on Phase 1 of the Risk Management of Per- and Polyfluoroalkyl Substances (PFAS), Excluding Fluoropolymers: Prohibition of the Use of PFAS, not Currently Regulated, in Firefighting Foams. 2025. https://cape.ca/wp-content/uploads/2026/01/Comments-Re-Consultation-Document-on-Phase-1-of-the-Risk-Management-of-Per-and-Polyfluoroalkyl-Substances-PFAS.pdf.

Wikipedia

{{cite press release |author=Canadian Association of Physicians for the Environment |title=Consultation Document on Phase 1 of the Risk Management of Per- and Polyfluoroalkyl Substances (PFAS), Excluding Fluoropolymers: Prohibition of the Use of PFAS, not Currently Regulated, in Firefighting Foams |date=25 November 2025 |url=https://cape.ca/wp-content/uploads/2026/01/Comments-Re-Consultation-Document-on-Phase-1-of-the-Risk-Management-of-Per-and-Polyfluoroalkyl-Substances-PFAS.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{canadianassociationofphysiciansfortheenvironment2025consultation, author = {{Canadian Association of Physicians for the Environment}}, title = {{Consultation Document on Phase 1 of the Risk Management of Per- and Polyfluoroalkyl Substances (PFAS), Excluding Fluoropolymers: Prohibition of the Use of PFAS, not Currently Regulated, in Firefighting Foams}}, publisher = {Canadian Association of Physicians for the Environment}, year = {2025}, month = nov, url = {https://cape.ca/wp-content/uploads/2026/01/Comments-Re-Consultation-Document-on-Phase-1-of-the-Risk-Management-of-Per-and-Polyfluoroalkyl-Substances-PFAS.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }