MEMO To ENGO Members of NPRI PFAS Sub-group From Beverley Thorpe, consultant, Clean Production Action

Due to their mobility in water and ability to circulate in air, they are ubiquitous contaminants in the Canadian environment, as described in the Government of Canada’s Draft State of Per- and polyfluoroalkyl substances (PFAS) Report of May 20, 2023.2 The federal government notes: This draft report provides a qualitative assessment of the fate, sources, occurrence, and potential impacts of PFAS on. [...] The report also proposes to conclude that PFAS as a class are harmful to human health and the environment.3 In Government concluded: On the basis of what is known about well-studied PFAS and the potential for other PFAS to behave similarly, it is proposed that the class of PFAS meets the criteria under paragraph 64(a) of 1 CEPA as these substances are entering or may enter the environment in a qua. [...] Information exists to identify the sources of PFAS for inclusion in the NPRI Extensive databases exist on the sources of PFAS facilitating their inclusion in the NPRI. [...] This brings the list of PFAS for reporting year 2023 to a total of 189 PFAS.9 The facilities required to report the release or treatment of these reportable PFAS are listed by NAIC codes.10 4 3.2 Critiques of early PFAS reporting in TRI offer valuable lessons for the NPRI A critique of the inadequacy of PFAS reporting in the TRI11 conducted by the Natural Resource Defense Council in October 2021,. [...] The use of firefighting foam containing PFAS is a significant source of drinking water contamination from PFAS and has been acknowledged by the Government of Canada as a priority point source of PFAS use and discharge into the Canadian environment.