NGO Comments on the draft of Canada’s Great Lakes Strategy for PFOS, PFOA and LC-PFCAs Risk ManagementBlog
HEJSupport prepared comments on the draft of Canada’s Great Lakes Strategy for PFOS, PFOA and LC-PFCAs Risk Management. Comments were endorsed by 25 organisations and include detailed recommendations to strengthen the draft Strategy.
The recommendations inter alia urge Canada to address gaps in information disclosure of PFAS chemicals in products to facilitate assessment of alternatives for the target chemicals and mixtures and avoid regrettable substitution including short-chain PFAS and various fluorinated chemicals. The draft Strategy should emphasize that the confidential business information (CBI) should not undermine efforts for the assessment of PFAS and their chemical alternatives in products. The use of CBI claims should be limited to ensure that information on chemicals relating to the health and safety of humans and the environment is not regarded as confidential.
Product manufacturers using PFAS in the Great Lakes basin should provide a list of the PFAS chemicals they use and an action plan for switching to safe, non-PFAS alternatives, including non-chemical alternatives, with a clear timeline for implementation. Data and information about PFAS alternatives assessment utilised by these facilities should be provided.
The draft Strategy should initiate the development of a database of brands and retailers operating in the Great Lakes basin, of PFAS-free products including carpets, textiles, building materials, food contact materials, and electronic products. The database will help prioritise these companies within the federal and provincial procurement policy and inform consumers and other stakeholders within the Great Lakes basin about the availability of PFAS-free products on the market.