PFAS environmental contaminants in Canadian provinces: Where are the guidelines?
September 05, 2019
September 05, 2019
As we study impacts of persistent contaminants, jurisdictions are implementing standards. But Canada needs more provincial regulations.
Per- and polyfluoroalkylated substances (PFAS) are all around us, in many different places. These persistent contaminants can be found in microwave popcorn bags, pizza boxes, cosmetics, water-resistant clothing, firefighting foams, drinking water, paints, and cleaning products, to name a few. But these man-made chemicals, which have been used since the 1940s, can have negative health consequences for humans.
Thankfully, many jurisdictions around the world are setting regulations and standards for specific PFAS and are taking steps to assess their potential for human exposure. But, aside from British Columbia, we haven’t seen any guidelines from Canadian provinces on PFAS. Here’s why I think they are needed.
Let me start my PFAS discussion by telling you about PFOS—perfluorooctane sulfonate. My introduction to PFOS occurred in 2000 when I was working in the Directorate of Environmental Protection as the head of environmental engineering for the Canadian Armed Forces. A senior researcher from the Quality Engineering and Testing Establishment asked me to help with a project targeting the management of contaminated water and sludge from a containment pond at the Canadian Forces Fire Academy at Canadian Forces Base Borden.
At the time, the Department of National Defence (DND) was concerned about managing the waste. The water contained PFOS, a toxic and persistent chemical found in aqueous film forming foams (AFFF) used in firefighting foams at the Academy. DND took notice of the issue when 3M, one of the major manufacturers of PFOS in the United States, announced a voluntary phase-out of the chemical.
Much has changed since then. For example, now we know that PFOS is one of a family of over 3,000 PFAS. We also know that the chemicals in the PFAS family are extremely persistent and mobile in the environment and that these chemicals are found in more than firefighting foams.
These chemicals find their way in the environment—and of particular concern, into our drinking-water supplies—from industrial discharges, wastewater treatment plant aqueous effluents, treated sludge (biosolids) land applications, and through long range air dispersion of PFAS attached to fine water droplets.
It’s been 19 years since 3M announced that they’d be voluntarily phasing out PFOS. Nineteen years is a long time to effect change and, as companies and organizations phase out many PFAS thanks to government regulations, this ultimately reduces additional inputs in the environment.
Here’s one thing that hasn’t changed: the lack of regulations on PFAS from Canadian provinces, whether in the context of their contaminated sites programs—my current field of practice—or in the context of hazardous waste management or the wastewater industry. This regulatory inertia is mainly caused by the deep uncertainty in PFAS toxicity for many of the chemicals in the family, including their potential for synergistic effects on human toxicity. In other words, we have very limited understanding of the effect caused by the exposure to two or more PFAS at one time, resulting in health effects that may be greater than the sum of the effects of the individual chemicals.
Let’s look at what some other jurisdictions are doing before examining the situation with Canadian provinces.
The United Nations Environmental Program has published technical guidelines dealing with the sound management of wastes impacted by persistent organic pollutants (POP)—chemical compounds that remain in the environment for a long time. These guidelines include PFOS-containing wastes. The guidelines require that wastes are disposed of in such a way that the POP content is destroyed, irreversibly transformed, or otherwise disposed of in an environmentally sound manner.
In the US, several states have issued, or proposed, low part per trillion (ppt) drinking water standards or groundwater cleanup goals. In some cases, neighboring states do not have any defined criteria. In April 2019, the US Environmental Protection Agency published Draft Interim Recommendations to Address Groundwater Contaminated with PFOA and PFOS for public comment. Several states have taken actions to propose and implement their own PFAS remediation criteria.
Australia leads the charge in addressing PFAS. In 2018, an Intergovernmental Agreement (IGA) on a National Framework for Responding to PFAS Contamination came into effect to support collaboration and cooperation to respond to PFAS contamination. Under the IGA, Australians have done several things: they’ve adopted a PFAS contamination response protocol, applied a PFAS national environmental management lan, and implemented guidelines to provide advice to government agencies involved in responding to PFAS contamination. A PFAS taskforce, established in 2016, coordinates these initiatives. Dealing with PFAS contamination has become a national priority.
From a global perspective, and as noted in the Interstate Technology Regulatory Council (ITRC)’s History and Use of PFAS factsheet, the reported increased production of PFOA—perfluorooctanoic acid, considered another high-profile PFAS—and related PFAS in China, India, and Russia have potentially offset the global reduction anticipated with the US phaseout.
The persistence of PFAS chemicals has generated a sustained scientific and political challenge to resolve, and it continues to be an issue in many jurisdictions. So, what’s Canada’s position on PFAS?
On a federal level, Canada took steps to deal with PFAS contaminants—notably long-chain perfluorocarboxylic acids (PFCAs), PFOS, and PFOA—in the environment beginning in 2006. At that point, the federal government concluded that PFOS, its salts, and certain other compounds could be entering the environment under conditions that could have an immediate or long-term harmful effect on the environment or its biological diversity. The human health assessment concluded that the 2006 levels of PFOS exposure were below levels that might affect human health. By 2012, those chemicals were included in Canada’s Prohibition of Certain Toxic Chemicals regulations, which prohibit the manufacture, use, sale, offer for sale, or import of certain toxic substances, as well as products containing these substances.
In 2018, Health Canada introduced drinking water screening values for PFOS, PFOA, and seven other PFAS. Health Canada further published soil screening values as well as drinking water quality guidelines in 2019.
Other federal initiatives include the publication of a federal environmental quality guideline for PFOS in 2018 by Environment and Climate Change Canada (ECCC). Canada’s Federal Contaminated Sites Action Plan published interim advice on waste removal approaches in 2018. ECCC is expecting the development of new regulatory amendments to the Environmental Protection Act’s Toxic Substances List, targeted for publication in winter 2020.
Canada’s approach differs from the Australian model in the lack of a centralized federal policy. In the absence of a centralized Canadian federal leadership champion, the PFAS issue will continue to be dealt with in a piecemeal approach driven mainly by the evolving understanding of human and ecological risks across the country. The existing federal guidelines are not enough. They need to be partnered with provincial regulatory guidance, because without this, there simply will be no drivers to take any action for the monitoring of—or for the assessment and remediation of—these chemicals.
Canadian provinces are struggling with the deep uncertainties that continue to surround the management of PFAS in the environment. This is particularly true of the uncertainties related to our understanding of the toxicity, both to humans and to the environment, of many PFAS and their potential presence in our drinking water, or in a wide range of effluents streams with existing monitoring guidelines. Provinces acknowledge the issue, mainly for PFOS and PFOA, and the potential presence of these contaminants in our wastewater treatment plant (WWTP) effluents and in terms of their relative toxicology. In the absence of hard data, sustainable cost-effective treatment technologies, and the potential for ambient levels found in the environment from multiple potential sources, provinces have not proposed any guidelines or standards beyond those proposed by federal government departments.
Aside from British Columbia, no provinces have released provincial standards. BC recently added PFOS to the water and soil schedules in recent amendments to its regulations. Ontario is working on a groundwater quality action level, but they haven’t officially released it.
Canadian provinces are struggling with the amount of uncertainty surrounding PFAS.
Considering the environmental and human health challenges created by these chemicals, provinces need to start proposing standards for PFAS for which we have a baseline of reliable information related to their environmental fate, transport, and toxicity. This should include environmental standards for soils and groundwater (especially where potable water sources are of concern), standards for waste management and waste disposal, and standards for effluent monitoring from various sources such as WWTPs and landfills.
Canadian provinces have suffered from the inertia of “paralysis by analysis”—where over-analyzing something devolves into inaction—and from the potential financial implications of monitoring for substances in comparison to what may end up being a very conservative standard in the parts per trillion range, with no easy or cost-effective remediation/mitigation solution at hand. At a minimum, there is a social and ethical responsibility to protect human health by understanding whether PFAS is in our water supplies, and by understanding if we are allowing it to enter in the environment through various effluents. This should be a priority for our provincial governments to focus on while science tries to catch up.
The good news is that people are paying attention to PFAS. The bad news is that it will take years before we resolve the issues surrounding these contaminants. Are the guidelines we’ve seen so far overly protective, or are the potential synergistic effects of exposure to a multitude of PFAS that are yet to be understood worse than what we think? Right now, there are more questions and challenges than answers.
It’s time for the scientific community to work under federal and provincial leadership (with the associated funding), and in collaboration with the international community, to come up with sustainable solutions that are based on sound risk management—and not risk aversion.
We need to protect the environment and ourselves from the effects of these contaminants. Canadian provinces must act. It’s time for leadership!