HEJSupport joined a group of NGOs to prepare comments to Environment and Climate Change Canada on the Consultation document “Phase 1 of the Risk Management of Per- and Polyfluoroalkyl Substances (PFAS), Excluding Fluoropolymers: Prohibition of the Use of PFAS, not Currently Regulated, in Firefighting Foams”.
Recommendation 1: We recommend the Government of Canada pass new regulations under CEPA to prohibit manufacture, use, sale and import of PFAS in firefighting foams.
Recommendation 2: New regulations to prohibit PFAS under CEPA should address the full cycle of PFAS in firefighting foam and could include specific provisions to: (1) address remaining stocks of PFAS in AFFF; (2) outline factors to consider time limited exemptions, final disposal and management of AFFF; and (3) address requirements for permits, disclosure and reporting for any uses.
Recommendation 3: Eliminate all exemptions that apply to PFAS substances: PFOS, PFOAs, LC-PFCAs in the Prohibition of Certain Toxic Substances Regulations as proposed in May 2022 immediately.
The complete document with comments and recommendations is available here:
