It was about a year ago when we mentioned the emerging regulatory concern related to a particular class of persistent organic chemicals: Polybrominated Diphenyl Esters (PBDEs) (see PBDE: An Emerging Environmental Regulatory Concern?).
There is another group of persistent organic chemicals that have been making news, not just in Canada, but across North America and elsewhere. Per- and polyfluoroalkyl substances (PFAS) are a group of chemicals that includes Perfluorooctanoic acid (PFOA) and Perfluorooctane Sulfonate (PFOS). Public health and environmental regulators are increasingly concerned about these chemicals due to potential public health issues.
PFAS Widely Used
In general, Canadian regulations prohibit the manufacture, use, sale, offer for sale, and import of PFOS and products containing PFOS (see Toxic substances list: PFOS). However, while this group of chemicals was not manufactured in Canada, it was widely used. The uses have included fume suppressants in metal plating (prohibited after May 29, 2013), firefighting foams, and repellants for paper, packaging, carpets, and fabrics.
Because they were so widely used, they are believed to be ubiquitous in the environment (in groundwater, surface water, sediment, and biosolids). Relative to biosolids from public wastewater treatment plants, there are additional concerns because the biosolids, in some cases, have been “land applied” to farm fields for the soil amendment nutrient value. The fate, transport, and potential plant uptake may be a larger question.
PFAS Sites of Concern in Canada
In late September (2017), there was a news release by Transport Canada stating they were, “…proactively reaching out to select airports it previously owned to request permission to test for offsite per- and polyfluoroalkyl substances (PFAS) concentrations surrounding fire training areas.” The detection around airports is owed to the use of Aqueous Film-Forming Foam (AFFF or A triple F), which contains perfluorochemicals.
PFAS has been detected in the area surrounding the National Fire Laboratory in Mississippi Hills, Ontario. The National Research Council of Canada has conducted testing and has provided water filters to the residents in the affected area.
PFAS were detected in residential wells in North Bay where the Department of National Defence used firefighting foam. Several water samples from Lees Creek exceeded Health Canada’s screening values for PFAS. There is a drinking water advisory for Lees Creek warning the public not to drink the water, and the Ministry of the Environment and Climate Change (MOECC) also has a warning not to eat the fish from Lees Creek due to PFAS levels detected in fish.
PFAS in the United States
Our neighbours in the United States have also been very active in assessing the potential impact of this group of chemicals. In fact, my colleagues in our US office have worked closely with some of our clients who are currently assessing PFAS in groundwater. Below are some of the developments in the US:
- EPA Director, Scott Pruitt, has stated that PFAS needs to be addressed quickly.
- The US Centers for Disease Control reported that PFOA was found in the blood serum in nearly all the people they tested.
- An EPA Fact Sheet states that “To provide Americans…with a margin of protection from a lifetime of exposure to PFOA and PFOS from drinking water, EPA established the health advisory levels at 70 parts per trillion” (this is not enforceable).
- Vermont issued groundwater standards and listed certain wastes containing PFOA as “hazardous.”
As with many emerging contaminants, there are more questions than answers. It does appear that PFAS are wide spread in the parts-per-trillion range; however, more data are needed to know what this means relative to understanding the potential effect on human health and the environment. As the father of toxicology, Paracelsus, stated hundreds of years ago, “All things are poison and nothing is without poison; only the dose makes a thing poison.”
What Should You Do?
At this point, because there are no enforceable regulatory limits, it is an awareness issue. At some point in the future, there may be actionable items, including remediation efforts. If you have an active groundwater remediation program underway for other chemicals and you suspect you may have PFAS in the groundwater, you may want to consider discussing options with your environmental advisors (consultants and lawyers).
If you have questions or would like to discuss this issue, you can contact me at 519-979-7300, ext. 114.