Comments on the Draft State of PFAS Report and Risk Management Scope (July 2023)

The submission argues that the Canadian government's updated approach to PFAS is insufficient, specifically criticizing the proposal to exclude fluoropolymers from the PFAS class and the use of outdated bioaccumulation criteria. The authors call for the fast-tracking of PFAS listing on Schedule 1 of the Canadian Environmental Protection Act (CEPA) and a more ambitious risk management scope that prioritizes prohibitions over technical feasibility studies.

• The authors argue that the proposal to exclude fluoropolymers from the PFAS class is not science-based and contradicts the precautionary principle, asserting that there is no scientific justification to separate them from other PFAS regarding human or environmental health impacts.
• The document claims that the Updated Draft Report fails to accurately determine PFAS bioaccumulation because it relies on outdated CEPA Persistence and Bioaccumulation Regulations based on freshwater aquatic species rather than dietary biomagnification.
• The submission notes a reduction in the strength of the language used in the Updated Draft Report compared to the May 2023 version, specifically the removal of terms such as "precautionary", "protective", and "hazardous".
• The authors recommend that the PFAS class be listed in Part 1 of Schedule 1 of CEPA, arguing that they meet the criteria for the highest risk substances, including being carcinogenic, mutagenic, and toxic for reproduction.
• The Revised Risk Management Scope (RMS) is criticized for being too narrow, particularly for limiting its focus to high exposures from firefighting foams and prioritizing "technically feasible" instruments over the prohibition of non-essential consumer uses.
• The document highlights significant socioeconomic costs associated with PFAS contamination in Canada and elsewhere, including drinking water remediation and health harms to firefighters, which the authors argue should outweigh industry concerns regarding reformulation costs.

APA

Armstrong, C. G. (2024). Comments on the Draft State of PFAS Report and Risk Management Scope (July 2023). Canadian Association of Physicians for the Environment. https://cape.ca/wp-content/uploads/2024/09/Update-PFAS-RA_RM-Ecojustice-ED-CAPE-BCAQ-DSF-SWCC-CPCHE-Sept-11-2024.pdf#new_tab

Chicago

Armstrong, Chelsey Geralda. Comments on the Draft State of PFAS Report and Risk Management Scope (July 2023). Canadian Association of Physicians for the Environment, 2024. https://cape.ca/wp-content/uploads/2024/09/Update-PFAS-RA_RM-Ecojustice-ED-CAPE-BCAQ-DSF-SWCC-CPCHE-Sept-11-2024.pdf#new_tab.

Wikipedia

{{cite press release |last1=Armstrong |first1=Chelsey Geralda |title=Comments on the Draft State of PFAS Report and Risk Management Scope (July 2023) |publisher=Canadian Association of Physicians for the Environment |date=11 September 2024 |url=https://cape.ca/wp-content/uploads/2024/09/Update-PFAS-RA_RM-Ecojustice-ED-CAPE-BCAQ-DSF-SWCC-CPCHE-Sept-11-2024.pdf#new_tab |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{armstrong2024comments, author = {Armstrong, Chelsey Geralda}, title = {{Comments on the Draft State of PFAS Report and Risk Management Scope (July 2023)}}, publisher = {Canadian Association of Physicians for the Environment}, year = {2024}, month = sep, url = {https://cape.ca/wp-content/uploads/2024/09/Update-PFAS-RA_RM-Ecojustice-ED-CAPE-BCAQ-DSF-SWCC-CPCHE-Sept-11-2024.pdf#new_tab}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }