As we covered in our March 11, 2025, blog, the Government of Canada introduced the Risk Management Approach to address per- and polyfluoroalkyl (PFAS) substances. The approach includes three phases. Phase I of the Risk Management Approach was released on September 26, 2025.
Phase 1 proposes to address all known remaining uses of PFAS that are not already regulated in firefighting foams that contain Aqueous Film Forming Foam (AFFF).
Proposed Risk Management Plan for PFAS: Phase 1
The proposed regulatory framework for Phase 1 includes the following:
- Time-Limited Exemptions: Time-limited exemptions to the prohibition are being considered only in exceptional circumstances—specifically to accommodate critical applications that cannot be immediately phased out.
- Transitional Periods: Transitional periods range from 18 months to 6 years.
- Disclosure and Labeling: Disclosure and labelling requirements regarding the presence of PFAS are being considered to support risk management actions by informing and warning users of their presence and to ensure that best practices are adopted where possible throughout the lifecycle to avoid releases to the environment and human exposure.
- Management Plans: The Government is considering imposing specific conditions at the coming into force to ensure that PFAS in AFFF are managed appropriately through their life cycle to avoid releases to the environment and human exposure.
- Permits: Time-limited permits are under consideration to allow the continued use of C6 AFFF in specific circumstances to protect human life and under specific conditions to protect the environment.
See Section 4 of the proposed approach for details. Also, see the blog by the law firm Torys.
Phase 1 proposes to address all known remaining uses of PFAS that are not already regulated in firefighting foams that contain Aqueous Film Forming Foam (AFFF) (Image by Andrea from Pixabay).
Potential Sources of AFFF
Who might have AFFF for firefighting? According to the Government of Canada, the following are sources that may have Class B firefighting foams.
Aviation: PFAS-containing firefighting foams are mostly used in aviation aircraft rescue firefighting (ARFF) operations on mobile firefighting trucks (airport crash trucks) and in fixed fire suppression systems within aircraft hangars.
Military: In the military, AFFF is used by the Department of National Defence (DND) in aviation for ARFF operations on crash trucks and in hangars as well as aboard ships.
Shipboard and shore facilities: AFFF is also used aboard civilian ships as well as at port authorities.
High-hazard industries: Some industrial applications often involve the use, storage, handling, processing, and production of sufficiently large quantities of highly combustible and flammable or explosive hazardous products to constitute a significant risk of a Class B fire
Municipal fire services: Municipal fire services are known to primarily use AFFF as part of mutual aid agreements.
The proposed regulations under Phase 1 will be published in the spring of 2027. A final consultation will follow the issuance of the proposed regulations. The final regulations for Phase 1 are expected to come into force around the spring of 2029.
Next Phases of PFAS Risk Management Plan
There are no hard dates for the next two phases of the PFAS risk management plan. The March 2025 announcements state that for Phase 2, consultation is to follow the publication of proposed Phase 1 Regulations in 2027.
When the next Phases are published, here is what to expect.
Phase 2: Includes the prohibition of the use of PFAS, excluding fluoropolymers, not needed for the protection of health, safety, or the environment, which includes consumer applications such as the following:
- cosmetics
- natural health products and non-prescription drugs
- food packaging materials, food additives, and non-industrial food contact products such as paper plates, bowls, and cups
- paint and coating, adhesive and sealant, and other building materials available to consumers
- consumer mixtures such as cleaning products, waxes, and polishes
- textile uses (including in personal protective equipment such as firefighting turnout gear)
- ski waxes
Phase 3: Includes the prohibition of the use of PFAS, excluding fluoropolymers, requiring further evaluation of the role of PFAS for which currently there may not be feasible alternatives, and taking into consideration socio-economic factors, including the following:
- fluorinated gas applications
- prescription drugs (human and veterinary)
- medical devices
- industrial food contact materials
- industrial sectors such as mining and petroleum
- transport and military applications
Comments on Phase 1 must be submitted no later than November 25, 2025.
If you need assistance with a PFAS issue, contact Christopher Paré, P.Geo., at 519-948-7300. Also see our PFAS Resource Page (for the US and Canada).
Alan Hahn drafted this blog. Alan has an undergraduate degree in Environmental Studies and completed a graduate program in Environmental Management. He has worked in environmental management for more than 45 years. He has written hundreds of blogs and articles. His published work includes HazMat Magazine, BizX Magazine, Michigan Lawyers Weekly, GreenStone Partners, Manure Manager Magazine, and Progressive Dairy.
Christopher Paré, P.Geo, reviewed this blog. Chris is a senior geoscientist and manager of Dragun’s Windsor, Ontario, office. Chris has more than 30 years of experience on projects ranging from environmental site assessments (Phase One/Two ESA), excess soils, remedial investigations, soil and groundwater remediation, Permits to Take Water, Records of Site Conditions, vapour intrusion, and site decommissioning. Chris is a frequent speaker, author, and expert witness. See Chris’ bio.
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