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The Ontario Environment Industry Association became one of the first Canadian industry groups to hold a conference on the topic when it held a PFAS Symposium in September 2023. While the conference involved several Canadian and international government agencies as well as private sector experts it took only small steps towards resolving the PFAS problem. This observer wonders whether the PFAS problem has already become intractable.

PFAS (Per‑ and polyFluorinated Alkyl Substances) is the generic name for a group of several thousand substances made up of molecules that contain at least one perfluorinated methyl group (BCF3) or a perfluorinated methylene group (BCF2B). PFAS are highly resistant to chemical, physical, and thermal degradation, they repel oil and water, and they have low surface tension. For decades some PFAS chemicals have been used in many commercial, industrial, and household applications, including such products as firefighting foams, cosmetics, non‑stick cookware, packaging, textiles, vehicles, electronics, pharmaceuticals and veterinary drugs. Today it is known that some PFAS cause seriously adverse effects on environmental and human health.

Several observers have likened the PFAS problem to the PCB (PolyChlorinated Biphenyl) problem of the mid 1980s. Like PFAS, PCBs have become ubiquitous in the global environment, having spread from pole to pole and all around the world before alarms about their persistent bioaccumulative and toxic properties were sounded. Somehow the PCB problem has disappeared from the popular press even though there are still many contaminated and electrical equipment sites around the world requiring clean up. Technologies for destruction of PCBs have been developed and deployed though the costs of remediation are still very high.

Superficially the PFAS and PCB problems share similar characteristic but the PFAS problem may yet prove to be much more intractable. PFAS have been used in many more commercial, industrial and household residential applications than PCBs. PFAS have become embedded at low but potentially serious concentrations in just about all materials that exist in commerce, from food to packaging materials and from plastics to fibres and some metal products. Removal of PFAS from materials is challenging at best and generally cost prohibitive even if the tools exist. Where removal is possible, for example from soils from contaminated sites, the difficulty of destroying PFAS means that much of the chemical will likely only be moved from one site to another from which it will continue to be released to the environment.

To date clean-up efforts have focused on contaminated sites and PFAS in drinking water. We seem to be a long way from having satisfactory removal methods for PFAS in food, packaging materials, and plastics. When materials are recycled the PFAS frequently remains within the mass of material from which it will very slowly disburse by slowly leaching into the environment.

Government actions so far are heading slowly towards bans on the manufacture, import and use of PFAS themselves. The banning of import and use of materials or products containing PFAS presents governments with something of a challenge because PFAS is so often present in very small concentrations which may nevertheless present a risk to the environment and health. An added complication is that the chemical and physical properties of most of the thousands of chemical structures which qualify for the PFAS classification has not been sufficiently researched and there is pressure from some sectors to allow the continued use of PFAS in commercial activities until such time as they have proven to be harmful.

With the Precautionary Principle (where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost‑effective measures to prevent environmental degradation) apparently mostly forgotten in Ottawa it is not inconceivable that we will be faced with a full blown crisis before adequate regulations banning all uses of PFAS are put in place.

One leading environmental lawyer, Janet Bobechko, a partner and Certified Specialist in Environmental Law at WeirFoulds LLP, gave the ONEIA Symposium participants some useful advice. She said that her advice to companies would be to not wait for government regulations but to review and test their entire supply chain for the presence of PFAS. It is better to know about, and hopefully address, potential and actual problems than to find out about them after government regulations kick in.

Some major brand owners and U.S. state governments are requiring that suppliers certify zero presence of PFAS. Given their ubiquitous presence and the sensitivity of tests for PFAS (often measured as total fluorine content), zero PFAS is likely unattainable in many products. It will have to be up to governments to decide what PFAS exposure can be tolerated and what zero means. The sooner this is done the sooner the flow of PFAS into the environment can be stopped.

The US Environmental Protection Agency has already taken the initiative of requiring all companies that use PFAS in any form to report their usage even for very small amounts used. No di minimus exemptions from reporting will be granted and the information on users of PFAS, including company names will be made public; the US EPA sees this as an incentive to encourage companies to reduce or eliminate use of these “substances of special concern.”

For further information on Canadian regulation of PFAS, click here.

Colin Isaacs is an environmental consultant specializing in Sustainable Development strategies for business. He was co-facilitator of Environment Canada‘s Accelerated Reduction / Elimination of Toxic Substances (ARET) program in the mid 1990s.

Featured image: Pixabay/Public

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