DEEP DIVE: Canada Addresses PFAS Risks, Prevention in Updated State of PFAS Report

In response to the prevalence of per- and polyfluoroalkyl substances (PFAS) and the dangers they pose to human and environmental health, the Canadian government is taking steps to reduce the prevalence of PFAS to promote a healthier Canada. In July 2024, the Canadian government released an updated Draft State of PFAS Report, which assesses the dangers of PFAS, along with a Revised Risk Management Scope, detailing solutions to reduce the amount of PFAS distributed in Canada.

PFAS are a class of more than 4,700 human-made chemicals used in the manufacture of many common household products. They are in the sunscreen you put on your kids in the summer, the food packages holding your lunch for the day, and even in the fabric of the couch you relax on in the evenings. Although they are the building blocks for many of the products we rely on for everyday convenience, scientific evidence continues to show that PFAS contaminate both the human body and the environment, impacting the health of both.

As their commonly known nickname, “forever chemicals,” implies, PFAS aren't going anywhere anytime soon. A key qualification of PFAS is a chemical structure resistant to degradation and repellant of water and oil. Not only have studies found PFAS in natural environments including groundwater, soil, and even air, but research confirms that PFAS accumulate in the human body, impacting body systems and organs.

“Given the thousands of substances in the class of PFAS and their evolving uses, it is imperative that we continue engaging Canadians and the scientific community as we deliver new tools to secure a cleaner environment for all,” Minister of Environment and Climate Change Steven Guilbeault stated.

Public Comments Incorporated Into the Report

The Draft State of PFAS was first published in May 2023, followed by a 60-day public consultation period. The 2024 version considers these public comments, the most notable update being the differentiation between PFAS and fluoropolymers, which pose different risks to human and environmental health. The Canadian government is therefore proposing a separate analysis of and response to fluoropolymers, independent of studies conducted on PFAS.

More than 130 organizations and individuals of the general public submitted comments on the original draft. According to the Summary of Public Comments released by the government, more than 200 comments expressed support for the draft's conclusion that PFAS are toxic. Other comments submitted to the Updated Draft State of PFAS include requests for additional research and investment on monitoring effects of PFAS, a call for increased governmental transparency regarding PFAS in drinking water, and assertions of the urgency for more comprehensive PFAS regulations.

State of PFAS Findings: Effects on Human Health

The State of PFAS Report delves into scientific research on the effects PFAS exposure has on human health. Of the thousands of substances classified as PFAS, less than 50 are currently monitored in human systems.

Still, research concludes that PFAS are present in the blood of nearly 100% of the Canadian population. Metric trends include higher levels of certain types of PFAS in males as opposed to females and higher levels in adults versus children. Even place of residence and occupation impacts PFAS exposure potential, as the report specifies that the Indigenous population in northern Canada tends to have higher PFAS levels, and firefighters specifically appear to have higher levels opposed to the general population.

Humans are exposed to a variety of individual PFAS compounds, and researchers determined that they are “readily absorbed into the body and are eliminated very slowly.” As noted by Minister of Health Mark Holland, the research indicates “that these chemicals can have detrimental impacts on our health, including effects on the liver, kidney, thyroid, reproduction and development, and immune and nervous systems.”

The report details the following health impacts:

• As the organs responsible for detoxing the body, the liver and kidneys are specifically susceptible to PFAS, and the report indicates that the liver and kidneys are at risk for chronic diseases due to PFAS accumulation.
• The endocrine system, responsible for hormone production, is prone to deregulation due to PFAS exposure.
• The thyroid, which controls metabolism, is specifically targeted, with research acknowledging that PFAS have the potential to cause thyroid diseases, increasing the risk of obesity and diabetes.
• PFAS exposure impacts the nervous system, leading to neurological effects such as behavior disorders and compromised cognitive function.

In addition, exposure to PFAS impacts both the male and female reproductive systems, resulting in lower chances of pregnancy and delayed development during pregnancy and in early stages of life. In females, PFAS exposure is associated with decreased levels of hormones necessary for conception, as well as higher rates of pregnancy complications such as preeclampsia and pregnancy-induced hypertension. PFAS are known to pass from mother to child through the placenta during pregnancy and after birth through human milk. In males, PFAS are known to decrease sperm count and motility.

Researchers also noted the human immune system is compromised by exposure to PFAS in two ways: immunosuppression and immunoenhancement. Immunosuppression means the body does not respond as well to vaccinations, leading to increased cases of infectious diseases. Immunoenhancement refers to an increased sensitivity to allergens or hypersensitive response conditions, such as asthma.

State of PFAS Findings: Effects on Environmental Health

PFAS are present in ecosystems globally. While high concentrations are typically found near points of industrial production, landfills, and wastewater treatment plants, PFAS compounds have also been found in remote areas and wildlife far from industrial sources. PFAS are present in diverse environments worldwide ranging from natural fresh water sources and oceans to agricultural lands and Arctic and Antarctic terrain. Similar to the accumulation found in human bodies, PFAS are known to accumulate in the tissue of wildlife, including land and aquatic mammals, amphibians, and birds.

The prevalence of PFAS in the environment not only affects biological diversity and overall ecosystem health but increases human exposure. By infiltrating drinking water, soil composition used in commercial produce, and animals used for food, PFAS are hard to avoid, even when consuming organic foods. Current monitoring research is limited in detecting the full class of PFAS in ecosystems, potentially underestimating their prevalence and concentrations in the environment.

Risk Management Scope: Canada's Action Plan Against PFAS

The findings of the updated Draft State of PFAS Report have resulted in the Canadian government proposing adding the class of PFAS to Part 2 of Schedule 1 in the Canadian Environmental Protection Act (CEPA), subjecting the class to further governmental regulation and risk management practices. The Risk Management Scope defines the proposed objectives as “reduc[ing] releases of these substances to the Canadian environment so as to avoid adverse effects; and reduc[ing] exposure of the general population, including disproportionately impacted populations, to these substances to protect human health.”

Some individual PFAS are already regulated under CEPA, but not all of them. The Risk Management Scope proposes further restricting PFAS in firefighting foams and regulating the manufacture and importation of PFAS in other sectors as to reduce prevalence in Canada. The document also suggests voluntary risk management practices, including increasing available upfront information in packaging on products containing PFAS, voluntarily phasing PFAS out of manufacturing processes, and coming up with alternative assessments of PFAS substitutions.

Insight on the original Draft State of PFAS Report from Canadian law firm McMillan LLP projects that regulation of more PFAS compounds is expected, and companies operating in Canada should take proactive steps to prepare by assessing and phasing out use of these substances when possible. “It is likely that companies will eventually be required to do so, and this will help them meet new regulatory standards for potential disclosure, management, substitution, notification and remediation of these substances,” assessed a post on the firm's blog.

Public comments on the Updated State of PFAS Report and Revised Risk Management Scope are due 11 September 2024 and will be considered in the next draft of both publications. Comments may be sent to the following contact:

Substance Prioritization, Assessment and Coordination Division, Science and
Risk Assessment, Science and Technology Branch
Environment and Climate Change Canada
351 Saint-Joseph Boulevard
Gatineau QC K1A 0H3
Telephone: 1-800-567-1999 (within Canada) or 819-938-3232 (outside of Canada)
Email: substances@ec.gc.ca

———

Editor's Note: 3E is expanding news coverage to provide customers with insights into topics that enable a safer, more sustainable world by protecting people, safeguarding products, and helping businesses grow. Deep Dive articles, produced by reporters, feature interviews with subject matter experts and influencers as well as exclusive analysis provided by 3E researchers and consultants.