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Protecting our health from toxics: 3 questions that need answers before election day
The Canadian Association of Physicians for the Environment, via the Coalition for Action on Toxics, identifies three priority areas for federal political action: reinforcing the Zero Plastic Waste agenda to end plastic pollution by 2040, expediting the phase-out of PFAS (forever chemicals), and providing long-term funding for the Chemicals Management Plan. The document argues that toxic exposures are a public health and environmental justice issue, noting that 88% of Canadians support increased federal regulatory action under CEPA. It highlights that Indigenous, racialized, disabled, and poor communities, as well as women and gender-diverse people, are disproportionately impacted by these pollutants.
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Document type: Statement
letter-to-congress-defending-epa-ord-iris-3-21-25-de7c6daaefa004c6.pdf
A coalition of 123 organizations argues that dismantling the EPA's Office of Research and Development (ORD) and the Integrated Risk Information System (IRIS) would undermine the scientific basis for protecting public health from toxic chemicals. The letter specifically opposes H.R. 1415 and S. 623, asserting that IRIS provides essential, peer-reviewed toxicity evaluations used for Superfund cleanups, air toxics standards, and drinking water safeguards. The authors warn that removing these scientific resources would increase risks of cancer and birth defects, particularly in industrial areas like Geismar, Louisiana, and Houston, Texas.
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Document type: Statement
Emission control vs Restriction
The document argues that current EU legislation, including the Industrial Emissions Directive (IED), is insufficient to prevent PFAS pollution and cannot replace a REACH restriction. It highlights gaps in the IED's scope, a lack of specific emission limit values for most PFAS, and weak monitoring and reporting requirements. Furthermore, it finds that occupational health and waste management regulations fail to provide robust protection against PFAS risks. The briefing concludes that while emission controls are a necessary complement, only a REACH restriction can effectively cut pollution at the source.
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Document type: Briefing
LATINO CLIMATE JUSTICE FRAMEWORK 2025-2028
The Latino Climate Justice Framework 2025-2028 outlines systemic inequities facing Latino/a/e communities, including higher energy burdens, exposure to fossil fuel pollution, and lack of access to nature. It proposes specific policy objectives across energy justice, climate resilience, worker protections, and migration rights, while warning against 'false solutions' like carbon capture and storage. The framework emphasizes the need for equitable clean energy transitions, the protection of climate-displaced persons, and the liberation of Puerto Rico from restrictive energy and economic policies.
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Document type: Report
Fall 2024 Earthjustice Program Report
Earthjustice reports a series of legal victories in 2024, including a landmark settlement to decarbonize Hawaii's transportation system by 2045, the cessation of coal leasing in the Powder River Basin, and a historic Inter-American Court of Human Rights ruling requiring Peru to remediate lead pollution in La Oroya. The organization also secured wins against cryptomining operations in New York, fossil fuel infrastructure expansion in New Jersey, and the loss of wetlands protections following the U.S. Supreme Court's Sackett v. EPA decision, notably helping Colorado pass legislation to reinstate wetland protections in May 2024. Additionally, the report highlights efforts to regulate PFAS in plastic containers, limit lead wheel weights, and protect endangered species such as the Cook Inlet beluga whale and Pacific sardine.
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Document type: Report
Joint open letter from the representatives of civil society and the environment on the Draghi Report considerations regarding chemicals
A joint open letter from civil society organizations criticizes the Draghi report for neglecting the societal and environmental costs of the chemicals industry, misrepresenting EU regulatory processes like REACH, and overlooking the availability of safer alternatives to PFAS.
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Document type: Statement
An opportunity for Canada: Regulating chemicals of concern in plastics ahead of INC-5
The Canadian Association of Physicians for the Environment and partners call for Canada to prohibit CEPA-toxic substances like DEHP, BPA, and PFAS in plastic products before INC-5 to build global momentum for the Global Plastics Treaty. They recommend prioritizing various chemical groupings in the 2025 Priority Plan and finalizing a Plastics Chemicals Strategy by Fall 2025 to restrict precursors such as formaldehyde and vinyl chloride.
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Document type: Statement
EPA and State Inaction on PFAS Puts Public Health at Risk and Leaves Taxpayers to Foot Cleanup Costs
The document criticizes the U.S. EPA and state governments for failing to regulate industrial PFAS discharges, which shifts cleanup costs to taxpayers. It proposes three primary actions: enforcing pretreatment requirements for Publicly Owned Treatment Works (POTWs), codifying Method 1633 for wastewater testing, and establishing Effluent Limitation Guidelines (ELGs) to mandate PFAS removal by industries.
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Document type: Statement
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.
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Document type: Statement
The State of PFAS (Forever Chemicals) in America 2024
The document examines the prevalence of perfluoroalkyl and polyfluoroalkyl substances (PFAS), known as "forever chemicals," in the U.S. environment and population. It details the health risks, including cancer and immune suppression, and outlines the regulatory response led by the EPA's 2021 Strategic Roadmap and the 2024 National Primary Drinking Water Regulation. The brief also covers state-level phase-outs, legislative efforts in the 118th Congress, and technical challenges in remediating PFAS from water and soil.
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Document type: Briefing
Corporate Environmental Due Diligence and Reporting in the EU
The report analyzes the CS3D, highlighting gaps in its scope of companies, value chain coverage, and the definition of environmental impacts compared to international standards like the OECD Guidelines and the CSRD. It argues that the current framework is too narrow, particularly regarding downstream activities and the financial sector. The authors provide 20 specific recommendations for Member States to strengthen the directive during transposition, focusing on expanding the scope of impacts, enhancing the effectiveness of climate transition plans, empowering supervisory authorities with proactive investigative powers, and broadening civil liability to better protect victims and the environment.
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Document type: Report
2024 Climate, Environmental, and Energy Congressional Hearings
The document tracks congressional hearings in 2024 across various House and Senate committees, covering topics such as energy security, climate risk, environmental regulations, and budget requests for agencies like the EPA and Department of Energy.
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Document type: Fact sheet
City of Everett Water Pollution Control Facility National Pollutant Discharge Elimination System (NPDES) Wastewater Discharge Permit
The document argues that the draft NPDES permit for the City of Everett Water Pollution Control Facility fails to meet legal requirements under the Clean Water Act and state law. It specifically demands the establishment of effluent limits for polybrominated diphenyl ethers (PBDEs), per- and polyfluoroalkyl substances (PFAS), and nutrients (nitrogen and phosphorus). The authors highlight a 'hot spot' of PBDEs in the lower Snohomish River that impairs the immune systems of juvenile Chinook salmon, and they call for stringent pretreatment requirements for industrial users, including Boeing, landfills, and industrial laundries. The statement also advocates for a halt on the land application of biosolids until they are sampled for these persistent toxics.
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Document type: Statement
The State of PFAS Forever Chemicals in America
The document examines the prevalence and risks of PFAS 'forever chemicals' in the U.S., highlighting the EPA's efforts to regulate drinking water and the significant financial burden on states to implement these standards. It details the widespread contamination of water and soil, the health risks associated with PFAS exposure, and the legislative and legal challenges surrounding remediation and liability.
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Document type: Briefing
State of Global Environmental Governance 2024
The 2024 state of global environmental governance is characterized by a 'polycrisis' of geopolitical tension, climate disasters, and economic instability. While some progress was made in Indigenous Peoples' participation and the establishment of the Cali Fund for biodiversity, major negotiations on plastic pollution and chemicals failed to reach landmarks. Climate finance remains a central point of contention, with the new collective quantified goal (NCQG) of USD 300 billion per year by 2035 falling short of developing countries' expectations. The report highlights a growing trend of environmental litigation at global courts and the persistent challenge of 'siloed' governance, where the three Rio Conventions operate independently despite the interconnected nature of climate, biodiversity, and land degradation.
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Document type: Report
Pollution prevention planning for primary food plastic packaging
The Canadian Association of Physicians for the Environment (CAPE), Women’s Healthy Environments Network (WHEN), and Breast Cancer Action Quebec (BCAQ) advocate for mandatory, transparent pollution prevention plans for large grocery chains to reduce single-use plastic food packaging. They argue that reuse systems are the most effective waste reduction method and demand that any new packaging be free of toxic chemicals like PFAS and phthalates. The organizations emphasize that plastic production is a major driver of greenhouse gas emissions and that plastic-related health harms disproportionately affect marginalized communities, including Indigenous peoples in Canada.
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Document type: Statement
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.
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Document type: Statement
A ROADMAP NOWHERE?
The report argues that the EU's Restrictions Roadmap is failing to meet its ambition of creating a 'non-toxic environment' due to narrow chemical grouping, excessive industry derogations, and systemic regulatory delays. While the roadmap provides a list of priorities, the authors find that most current restriction initiatives are too limited in scope to effectively tackle the risks of hazardous substances like bisphenols and PFAS.
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Document type: Report
Reach-ing further: what do we want to see in the EU’s reformed chemicals law?
ClientEarth argues that the current REACH law is inadequate, noting that over 70% of chemicals produced and used are hazardous. The organization calls for 'REACH 2.0' to implement a non-essential use ban with specific phaseout deadlines, strengthen 'no data, no market' registration requirements, and enable the fast-track restriction of entire chemical groups. Additionally, it advocates for stronger enforcement mechanisms—comparable to GDPR fines—and the creation of legal tools for citizens to demand action against pollution in 'toxic hotspots'.
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Document type: Statement
PETITION TO THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY To revoke the approval of approximately 600 per- and polyfluoroalkyl substances (PFAS) that were granted through low-volume or low-release and low-exposure exemptions to the premanufacture notice requirements of the Toxic Substances Control Act
Earthjustice and a coalition of environmental and health organizations petitioned the EPA to revoke PMN exemptions for approximately 600 PFAS. The petitioners argue that the weight of scientific evidence proves PFAS pose unreasonable risks to human health and the environment, including to susceptible subpopulations, thereby failing the legal standard for exemptions under the Toxic Substances Control Act (TSCA). They highlight that current LVE and LoREX thresholds allow contamination levels far exceeding safe drinking water health advisories and that the EPA's voluntary stewardship program has a withdrawal rate of less than 3 percent.
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Document type: Statement