Risk management strategy for perfluorooctane sulfonate and its salts and precursors: chapter 3

3. Why We Need Action

The final ecological screening assessment report concluded that PFOS, its salts and its precursors are entering the environment in a quantity or concentration or under conditions that have or may have an immediate or long-term harmful effect on the environment or its biological diversity. PFOS is anthropogenic and has been detected in vertebrate and invertebrate biota worldwide. In Canada, PFOS has been detected in higher trophic level biota such as fish, fish-eating birds, and Arctic marine mammals far from known sources or manufacturing facilities. A potential risk may occur through bioaccumulation and biomagnification of PFOS in wildlife.

The ecological screening assessment concluded that PFOS and its salts meet the criteria for persistence under the Persistence and Bioaccumulation Regulations. While there is scientific evidence that PFOS is a persistent organic pollutant that accumulates in animals and magnifies in food chains, PFOS does not meet the numeric criteria for bioaccumulation defined in the Persistence and Bioaccumulation Regulations and therefore PFOS, its salts and its precursors do not meet the conditions set out under subsection 77(3) for mandatory addition to the Virtual Elimination List.

Given the conclusions of the ecological screening assessment, PFOS, its salts and its precursors will be managed as a group under the provisions of CEPA 1999 with the objective of achieving the lowest level of releases to the environment that is technically and economically feasible from all emission sources. Section 8 of this report outlines the proposed risk management approach and objectives in more detail.

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