Risk management strategy for perfluorooctane sulfonate and its salts and precursors: chapter 8

8. Proposed Risk Management Approach

Given the conclusions of the final ecological screening assessment, as outlined in section 3 of this report, action is required to prevent the reintroduction of PFOS, its salts and its precursors into the Canadian market and to address the remaining uses.

It is, therefore, proposed that PFOS, its salts and compounds that contain the C8F17SO2, C8F17SO3 or C8F17SO2N group be added to the Prohibition of Certain Toxic Substances Regulations, 2005. This will result in a prohibition on manufacture, use, sale, offer for sale and import of PFOS its salts and its precursors and products or formulations containing PFOS, its salts and its precursors.

Standard exemptions for the use of PFOS, its salts and its precursors in a laboratory for scientific research and as a laboratory analytical standard are provided for in the Prohibition of Certain Toxic Substances Regulations, 2005. Additional exemptions may be considered for applications where it has been clearly demonstrated that viable alternatives are not yet available in the marketplace or when it is has been clearly demonstrated that the proposed alternatives may also represent an environmental or health risk. Exemptions that are already being considered include: the use of existing stock of PFOS AFFF, other than for testing or training purposes, for a period of up to five years following the date on which the proposed regulations come into force, and the import of manufactured articles that may contain PFOS.

The average PFOS content of AFFF is approximately 1% and the 3 tonnes of PFOS in the existing stockpile of AFFF is distributed across a large number of facilities in Canada. The proposed use restriction on PFOS AFFF effective 5 years after the coming into force of the Regulations is proposed to allow an orderly transition to non-PFOS AFFF while minimizing releases of PFOS to the environment from the long-term use of existing stocks. In addition to the proposed use restriction, a complementary instrument under CEPA 1999 is being considered to ensure best management practices are being employed during the storage, use and disposal of PFOS AFFF. Further consultation with affected stakeholders is required prior to concluding on the need for a complementary instrument targeting PFOS AFFF.

Environment Canada has considered proposing restrictions on the import of manufactured articles containing PFOS. Canada's major trading partners have already or will soon be implementing restrictions on the use of PFOS and there are expectations that global production of PFOS will eventually be eliminated or significantly reduced. As a result, the total number of imported articles that may contain PFOS will be declining without any direct Canadian intervention. Use pattern data on current imports of manufactured items containing PFOS into Canada is limited. In some instances, the originating country and the Canadian importers may not even be aware that PFOS is contained in the article. Furthermore, analytical methodologies to detect and quantify PFOS concentrations in a wide range of imported articles that could contain these substances would need to be developed.

Therefore, due to the apparent decline in global PFOS production, the concerted actions in other countries and in international forums to address PFOS as well as practical difficulties in enforcing such a measure, restrictions on the import of articles are not being proposed at this time. However, complementary instruments under CEPA 1999 may be considered in the future to address imported articles. A complementary approach for imported articles is being considered since, despite the declining global production and the actions in other jurisdictions and at international forms, it is possible that emerging markets may begin to export more articles containing PFOS to Canada in the future. Consultations with affected stakeholders will be required prior to determining the need for complementary instruments. The proposed consultation approach outlined in section 9 of this strategy will provide an opportunity to initiate these discussions.

Furthermore, Environment Canada will continue to engage international partners related to the long term reduction and eventual elimination of the worldwide manufacturing and use of PFOS. Environment Canada will also continue domestic research and monitoring activities related to the presence of PFOS in the Canadian environment to contribute to the international body of knowledge on perfluorinated substances and to evaluate if the environmental objective and risk management objective are being achieved.

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