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

A joint statement from six Canadian environmental and health organizations providing comments on the Draft state of per- and polyfluoroalkyl substances (PFAS) report and the Risk Management Scope (RMS). The organizations advocate for regulating PFAS as a class under the Canadian Environmental Protection Act (CEPA), fast-tracking their addition to Part 1 of Schedule 1 as toxic substances, and implementing a comprehensive ban on non-essential uses to protect human health and biodiversity.

• The commenters argue that PFAS must be regulated as a class rather than as individual substances to prevent 'regrettable substitution,' where regulated PFAS are replaced by unregulated ones that may be equally harmful. They note that the Draft Report indicates a "growing body of evidence suggesting concerns identified from well-studied PFAS are more broadly applicable."
• The document asserts that Canada is underestimating the size of the PFAS class at "over 4700 substances," noting that the US EPA estimates over 12,000 chemicals and the European Chemicals Agency estimates around 10,000 substances in the class.
• Biomonitoring data indicates that vulnerable populations in Canada face higher PFAS exposures. Specifically, pregnant Inuit women in the far north and Indigenous youth in Quebec show higher blood concentrations than the general population, and firefighters exhibit higher levels due to exposure to turnout gear and firefighting foams.
• The commenters recommend that the Minister fast-track the listing of the PFAS class in Part 1 of Schedule 1 of CEPA. They argue the class meets criteria for causing "harmful environmental and biodiversity effects" and constituting a "danger in Canada to human life or health."
• The statement criticizes the proposed Risk Management Scope (RMS) as "underwhelming," arguing that its health objectives fail to explicitly protect vulnerable populations and its environmental objectives should be expanded to align with the Kunming-Montreal Global Biodiversity Framework's goal of reducing risks from highly hazardous chemicals.
• The organizations call for a robust regulatory approach aiming for a complete ban on PFAS, with exceptions only for essential uses, citing similar proposals in the European Union and existing bans in US states such as Maine, Vermont, New York, and California.

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} }