Draft state of per- and polyfluoroalkyl substances (PFAS) report and risk management scope

The submission argues that PFAS should be regulated as a class to prevent 'regrettable substitution' and protect vulnerable populations, including Indigenous peoples and firefighters. The authors contend that the current Draft state of PFAS report underestimates the class size and that the proposed Risk Management Scope (RMS) is insufficient because it lacks a commitment to prohibiting non-essential uses. They recommend fast-tracking the listing of PFAS as toxic substances under CEPA Part 1 of Schedule 1, citing widespread contamination in the Canadian Arctic, the Great Lakes, and human blood.

• The authors argue that PFAS must be regulated as a class rather than as individual substances to avoid 'regrettable substitution', where regulated PFAS are replaced by unregulated alternatives that may be equally harmful.
• The document asserts that Canada's estimate of 'over 4700 substances' in the PFAS class is an underestimate, noting that the European Chemicals Agency estimates around 10,000 and the US EPA estimates over 12,000.
• Biomonitoring data indicates that PFAS are present in over 99% of the sampled Canadian population, with disproportionately higher concentrations found in pregnant Inuit women in the far north, Indigenous youth in Quebec, and firefighters.
• PFAS contamination is documented in various Canadian ecosystems, including the Great Lakes where PFOS levels in trout exceed safe wildlife consumption limits, and the Canadian Arctic where concentrations are increasing in ringed seals.
• The authors claim the PFAS class meets the criteria for Part 1 of Schedule 1 of CEPA because it is inherently toxic, persistent, bioaccumulative, and results from human activity, posing a high risk to human health and biodiversity.
• The submission criticizes the proposed Risk Management Scope (RMS) for failing to commit to prohibiting PFAS uses and releases, and for not explicitly protecting vulnerable populations in its health objectives.

APA

Canadian Association of Physicians for the Environment (2023). Draft state of per- and polyfluoroalkyl substances (PFAS) report and risk management scope. https://cape.ca/wp-content/uploads/2023/07/PFAS-comments-Ecojustice-ED-CAPE-DSF-BCAQ-and-WHEN-July-2023.pdf

Chicago

Canadian Association of Physicians for the Environment. Draft state of per- and polyfluoroalkyl substances (PFAS) report and risk management scope. 2023. https://cape.ca/wp-content/uploads/2023/07/PFAS-comments-Ecojustice-ED-CAPE-DSF-BCAQ-and-WHEN-July-2023.pdf.

Wikipedia

{{cite press release |author=Canadian Association of Physicians for the Environment |title=Draft state of per- and polyfluoroalkyl substances (PFAS) report and risk management scope |date=21 July 2023 |url=https://cape.ca/wp-content/uploads/2023/07/PFAS-comments-Ecojustice-ED-CAPE-DSF-BCAQ-and-WHEN-July-2023.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{canadianassociationofphysiciansfortheenvironment2023draft, author = {{Canadian Association of Physicians for the Environment}}, title = {{Draft state of per- and polyfluoroalkyl substances (PFAS) report and risk management scope}}, publisher = {Canadian Association of Physicians for the Environment}, year = {2023}, month = jul, url = {https://cape.ca/wp-content/uploads/2023/07/PFAS-comments-Ecojustice-ED-CAPE-DSF-BCAQ-and-WHEN-July-2023.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }