Long-chain (C9-C20) perfluorocarboxylic acids (LC-PFCAs), their salts and precursors

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Health science summary

In August 2021, the Government of Canada nominated LC-PFCAs for consideration under the Stockholm Convention on Persistent Organic Pollutants. Canada's nomination will be considered at the seventeenth meeting of the Persistent Organic Pollutants Review Committee (POPRC-17).

In preparation for the nomination, the Government of Canada examined the science as it relates to human health and a Health science summary: Long-chain perfluorocarboxylic acids (LC-PFCAs) their salts and related compounds was published.

Risk management action milestones

In December 2018, Environment and Climate Change Canada and Health Canada published the Consultation Document on Proposed Amendments to the Prohibition of Certain Toxic Substances Regulations, 2012 for PFOS, PFOA, LC-PFCAs, HBCD, PBDEs, DP and DBDPE.

The objective of this consultation document was to inform stakeholders of the proposed amendments to the Prohibition of Certain Toxic Substances Regulations, 2012, solicit comments and request information. Comments and information were requested by February 18, 2019, and will be considered in the development of the proposed Regulations to Amend the Prohibition of Certain Toxic Substances Regulations, 2012.

In October 2018, a notice of intent was issued in the Canada Gazette, Part I: Vol. 152, No. 41 – October 13, 2018 indicating that the Department of the Environment and the Department of Health were initiating the development of amendments to the Prohibition of Certain Toxic Substances Regulations, 2012. These amendments would seek to further restrict the manufacture, use, sale, offer for sale and import of certain toxic substances, including LC-PFCAs. There was a 30-day consultation period associated with this publication. Comments received on this publication will be considered in the development of the proposed Regulations to Amend the Prohibition of Certain Toxic Substances Regulations, 2012.

In October 2016, the Regulations Amending the Prohibition of Certain Toxic Substances Regulations, 2012 were published in the Canada Gazette, Part II: Vol. 150, No. 20 - October 5, 2016 and came into force in December 2016. These amendments prohibit LC-PFCAs, their salts and their precursors and products containing them, unless present in manufactured items. Time-limited exemptions and ongoing uses were provided for certain uses where the development of alternatives was underway or where there were currently no known alternatives. For these amendments, compliance-related materials include the Substance prohibition summary for PFOA, LC-PFCAs and related substances and the Aqueous film-forming foam and the Prohibition of Certain Toxic Substances Regulations fact sheet.

In April 2015, the proposed Regulations Amending the Prohibition of Certain Toxic Substances Regulations, 2012 were published in the Canada Gazette, Part I: Vol. 149, No. 14 - April 4, 2015, for a 75-day public comment period. Comments were considered in the final development of these regulations. Comments and the Government's response are provided in the summary of public comments on the proposed Regulations Amending the Prohibition of Certain Toxic Substances Regulations, 2012.

In January 2014, a Consultation Document on the Proposed Risk Management Measure for Long-Chain (C9-C20) Perfluorocarboxylic Acids (PFCAs), their Salts and their Precursors was published. Comments and the Government's response are provided in the summary of public comments on the consultation document on the proposed risk management measure for LC-PFCAs, their salts and their precursors. Comments received were considered during the development of the proposed risk management action.

In March 2010 a voluntary environmental performance agreement respecting PFCAs and their precursors in perfluorochemical products sold in Canada was signed. Signatories to this performance agreement agreed to reduce the amount of PFOA and LC-PFCAs in perfluorinated chemicals in Canadian commerce by 95% by December 31, 2010, and to eliminate them by December 31, 2015. This performance agreement was implemented as an early risk management action while Environment Canada and Health Canada pursued further assessment to guide future risk management actions. As a result of the agreement, participating companies successfully met their commitment to eliminate residual PFOA, LC-PFCAs and their precursors.

In June 2006, a notice of action plan for the assessment and management of PFCAs and their precursors was published in the Canada Gazette, Part I: Vol. 140, No. 44 - June 17, 2006. The action plan included measures to prevent the introduction of new substances into Canada that would contribute to the level of PFCAs in the environment, and to seek action from industry to address sources of PFCAs already in Canadian commerce.

Adding substances to Schedule 1

LC-PFCAs, their salts and their precursors have been added to Schedule 1.

Final ecological screening assessment and proposed risk management approach

In August 2012, the Final Ecological Screening Assessment on Long-chain (C9-C20) Perfluorocarboxylic Acids, their Salts, and their Precursors was released and the related notice was published in the Canada Gazette, Part I: Vol. 146, No. 34 - August 25, 2012.

The final ecological screening assessment concluded that LC-PFCAs, their salts, and their precursors meet one or more of the criteria in section 64 of the CEPA 1999.

Additionally, it is concluded that LC-PFCAs and their salts meet the criteria for persistence but do not meet the criteria for bioaccumulation potential set out in the Persistence and Bioaccumulation Regulations. Nevertheless, the weight-of-evidence is sufficient to conclude that LC-PFCAs and their salts accumulate and biomagnify in terrestrial and marine mammals.

A Proposed Risk Management Approach on Long-chain (C9-C20) Perfluorocarboxylic Acids (PFCAs), their Salts, and their Precursors was also released on August 25, 2012 for a 60-day public comment period. Comments and the Government's response are provided in the summary of public comments on the proposed risk management approach on LC-PFCAs, their salts, and their precursors. Comments received were considered during the development of the proposed risk management action.

Draft ecological screening assessment and risk management scope

In October, 2010, the Draft Ecological Screening Assessment on Long-chain (C9-C20) PFCAs, their Salts, and their Precursors was released and the related notice was published in the Canada Gazette, Part I: Vol. 144 No. 44 - October 30, 2010 for a 60-day public comment period. A risk management scope was also released in conjunction with this publication.

The draft ecological screening assessment of 14 precursors to LC-PFCAs, their salts, and their precursors (CAS RNs 678-39-7, 65530-63-4, 65530-66-7, 65530-71-4, 65530-72-5, 65530-74-7, 65605-58-5, 65605-70-1, 65636-35-3, 68239-43-0, 68391-08-2, 68412-68-0, 110053-43-5 and 115592-83-1), was conducted under sections 68 and 74 of the CEPA 1999 because they were found to meet the ecological categorization criteria for persistence and/or bioaccumulation potential and inherent toxicity to non-human organisms.

The draft ecological screening assessment of LC-PFCAs, their salts, and their precursors was conducted under section 68 of CEPA 1999 because they were not found to meet the categorization criteria, or they were not categorized since they do not appear on the Domestic Substances List (DSL).

The draft ecological screening assessment proposeed to conclude that LC-PFCAs, their salts, and their precursors are entering the environment in concentrations or quantities or under conditions that pose a risk to the environment. Therefore, LC-PFCAs, their salts, and their precursors met one or more of the criteria set out in section 64 of CEPA 1999. The Ministers of the Environment and of Health have since added these substances to Schedule 1 of the Act.

The public comments received were considered and addressed within the final screening assessment, and are provided in the summary of public comments received on the draft screening assessment for LC-PFCAs.

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