ASEQ-EHAQ

PFAS (per- and polyfluoroalkyl substances) Public Consultation

Media Release

References

This is a call to participate in a public comment period ending on July 19, 2023, on PFAS (per- and polyfluoroalkyl substances).

Below you will find two sample letters which you can send in via email or regular mail. Please act today.

WHAT ARE PFAS (per- and polyfluoroalkyl substances)?

PFAS (per- and polyfluoroalkyl substances) are chemicals that are added to everyday products, such as rugs, carpets, furniture, clothing, fast-food packaging, and cosmetics, namely, to repel oil and fat. Those chemicals are highly profitable, but when ingested by humans through food or water, they can cause serious negative health effects. For more information, please refer to the information sheet provided by the Government of Canada: Per- and polyfluoroalkyl substances (PFAS) – information sheet

To access the documents and provide your input, please visit: Draft State of Per- and Polyfluoroalkyl Substances (PFAS) Report and Risk Management Scope

Policy Position Paper: PFAS

Problem: The presence of PFAS in consumer products poses a grave threat to public health, environmental sustainability, and social justice in Canada. PFAS are pervasive chemicals found in various everyday items, including textiles (such as carpets, furniture, and clothing), food packaging, non-stick kitchenware, cosmetics, vehicles, electronics, and certain firefighting foams. These chemicals, which repel oil and fat, have proven to be impressive technological innovations and very profitable, but come with severe negative health consequences. Per- and polyfluoroalkyl substances (PFAS) – information sheet – Canada.ca

While private businesses aim to maximize profits, it is crucial to prioritize the health and safety of consumers in the products they produce and distribute. Regulating and monitoring the presence of toxic substances is essential to minimize potential health risks and safeguard the well-being of individuals and communities.

ASEQ-EHAQ and EHAC-ASEC Position Statement:

The Environmental Health Association of Quebec and the Environmental Health Association of Canada both firmly believe that it is imperative for the Canadian government to take prompt and decisive action to address PFAS contamination in consumer products. We advocate for policies and initiatives that prioritize public health, remove barriers to access, and improve environmental sustainability, and ecological justice.

We need stronger regulations that safeguard us from all forms of PFAS exposure.

Why We Need to Ban PFAS Immediately:

Low-income individuals and marginalized communities bear disproportionate risks due to limited choices and reduced access to safer alternatives. Additionally, environmental pollution and exposures disproportionately affect vulnerable populations, women, Indigenous peoples, and racialized groups, perpetuating systemic inequalities.

Addressing PFAS contamination requires regulations and immediate transition strategies that prioritize environmental justice and equitable access to PFAS-free alternatives. People with disabilities, particularly those with Multiple Chemical Sensitivities (MCS), are vulnerable to the health impacts of PFAS exposure. Policy development must actively involve disability advocates and ensure accessibility in decision-making processes.

PFAS contamination poses a severe threat to ecosystems, including water bodies and wildlife, compromising ecological integrity. Implementing strict regulations that include clean-up measures of present contamination, assuring health protection including for the most vulnerable, and supporting sustainable alternatives are crucial for preserving environmental justice.

Recommendations and Call to Action:

Due to the aforementioned risks of PFAS, l’Association pour la santé environnementale du Québec / Environmental Health Association of Québec (ASEQ-EHAQ) and the Environmental Health Association of Canada / Association pour la santé environnementale du Canada (EHAC-ASEC) urge the Canadian government to take the following actions:

1. Immediate Ban on PFAS: Enact legislation and regulations that ban the use, import, and sale of PFAS. This ban should have few exceptions and include a comprehensive range of products such as: textiles, food packaging, cosmetics, kitchenware, and other items where PFAS are commonly used.
2. Immediate Recall of PFAS in Existing Products: Recall products with PFAS from shelves. Include incentives for businesses to transition to safer alternatives. No phase-outs.
3. Improved Labelling on Consumer Products: Improve the labels on products that have PFAS and other dangerous chemicals that can impact our health and environment. These labels should be accessible to all so that product content can be easily identified, and they must include clear health warnings to inform consumers of the risks associated with use. By providing comprehensive information about all hazardous chemicals present in the product, consumers can make informed decisions on product choices. Some ingredients in products can harm our health, and Canadians have the right to know what they are.
4. Implementation of a Robust Regulatory Framework for Evaluating and Reviewing Hazardous Chemical Products: Establish a robust system for continuous evaluation and review of PFAS-related regulations and policies to ensure their effectiveness and adapt to emerging scientific evidence.
5. Enhanced Healthcare Support and Funding: Establish comprehensive systems to provide assistance to individuals affected by health issues related to these exposures.
6. Educational Campaign on PFAS: Launch an educational campaign that utilizes findings from this report to inform Canadians about the risks associated with PFAS and where they can seek health support. This campaign can be financed by imposing fines or taxes on private industries that profit from the use of PFAS and that have contributed to the harm.
7. Removal of PFAS from Drinking Water Supply: Investment by the government to develop adequate tools to remove PFAS from drinking water supplies in all communities across Canada.
8. Improved International Cooperation: Engage in international partnerships to exchange best practices and establish uniform standards and regulations concerning PFAS and other hazardous chemicals and substances.
9. Additional Investment in Research and Monitoring: Provide more funding for research to learn more about the health risks of PFAS exposure and programs that monitor the prevalence of PFAS in the environment, such as MIREC Canada (mirec-canada.ca) and Northern Contaminants Program (science.gc.ca), should be supported. Collaboration between government agencies, educational institutions, community organizations, and health organizations should be encouraged to address this important issue.
10. Creating Accountability Mechanisms: Hold private industries accountable for environmental harm they have caused by shifting the burden and cost of cleanup and health impact back onto them.
11. Class Action Lawsuit Fund/Health Fund: Allocate a fund of $50 million to support Canadians whose health has been negatively impacted by these unsafe products.

Information Sheet 1: Per- and polyfluoroalkyl substances (PFAS)

Information Sheet 2: PFAS: Protecting Your Health and the Environment

References:

Abraham K, Mielke H, Fromme H, Völkel W, Menzel J, Peiser M, Zepp F, Willich SN, Weikert C. 2020. Internal exposure to perfluoroalkyl substances (PFASs) and biological markers in 101 healthy 1-year-old children: Associations between levels of perfluorooctanoic acid (PFOA) and vaccine response. Arch Toxicol. 94(6):2131-2147. Retrieved from https://pubmed.ncbi.nlm.nih.gov/32227269/

Abunada Z, Alazaiza MYD, Bashir MJK. 2020. An overview of per- and polyfluoroalkyl substances (PFAS) in the environment: source, fate, risk and regulations. Water. 12(12):3590. Retrieved from https://www.mdpi.com/2073-4441/12/12/3590

Agency for Toxic Substances and Disease Registry (ATSDR). 2021. Toxicological profile for perfluoroalkyls [PDF].” US Department of Health and Human Services. Retrieved from tp200.pdf (cdc.gov)

Backhaus T, Faust M. 2012. Predictive environmental risk assessment of chemical mixtures: A conceptual framework. Environ Sci Technol. 46(5):2564-2573. Retrieved from https://ehp.niehs.nih.gov/doi/10.1289/EHP7431

Government of Canada. 2023. Northern Contaminants Program: Human Health. Retrieved from https://science.gc.ca/site/science/en/northern-contaminants-program/ncp-subprograms/human-health

Government of Canada. 2023. Supporting document: Ecological state of the science report on Short-chain (C4–C7) Perfluorocarboxylic Acids (SC-PFCAs) Short-chain (C4–C7) Perfluorosulfonic Acids (SC-PFSAs) Long-chain (C9–C20) Perfluorosulfonic Acids (LC-PFSAs). Retrieved from

https://www.canada.ca/en/environment-climate-change/services/evaluating-existing-substances/supporting-document-ecological-state-science-report-sc-pfcas-sc-pfsas-lc-pfsas.html

Government of Canada. 2023. Healthy Home. Retrieved from https://www.canada.ca/en/health-canada/services/healthy-home.html

Government of Canada. 2023. Per- and polyfluoroalkyl substances (PFAS). Retrieved from https://www.canada.ca/en/health-canada/services/chemicals-product-safety/per-polyfluoroalkyl-substances.html

Government of Canada. 2022. Use household chemicals safely. Retrieved from https://www.canada.ca/en/health-canada/services/home-safety/household-chemical-safety.html#a2.2

Government of Canada. 2022. Canada’s systems for addressing chemicals. Retrieved from https://www.canada.ca/en/health-canada/services/chemical-substances/canada-approach-chemicals/canada-system-addressing-chemicals.html

Government of Canada. 2022. Overview of the Chemicals Management Plan. Retrieved from https://www.canada.ca/en/health-canada/services/chemical-substances/fact-sheets/overview-chemicals-management-plan.html

Government of Canada. 2023. Long-chain perfluorocarboxylic acids (LC-PFCAs), their salts and precursors. Retrieved from https://www.canada.ca/en/health-canada/services/chemical-substances/other-chemical-substances-interest/long-chain-perfluorocarboxylic-acids-containing-9-20-carbon-atoms-salts-precursors.html

Jones, Benji. 2023. PFAS, the ‘forever chemicals,’ explained by a chemist. Vox. Retrieved from https://www.vox.com/2022/8/25/23318667/pfas-forever-chemicals-safety-drinking-water

New York Times. Forever Chemicals Are Everywhere. Here’s How to Limit Your Exposure. (nytimes.com). Retrieved from https://www.nytimes.com/wirecutter/blog/how-to-limit-exposure-to-forever-chemicals/