Thank you, Chair, committee members.
We don't have much time, so we'll be brief. We're talking today about Bill C-298, which is a bill to virtually eliminate perfluorooctane sulfonate, or PFOS.
The Canadian Environmental Protection Act says that any toxic substance that is mostly due to human activity and is persistent, bioaccumulative, and inherently toxic is supposed to be virtually eliminated. PFOS is extremely persistent and bioaccumulative, more so than even our famous persistent organic pollutants DDT and PCBs. It stays in the environment for decades, and the human body takes over eight years to clear just half of it.
Human studies have found increased rates of bladder cancer, male reproductive cancers, liver cancer, and multiple myeloma. That's in worker studies and in studies of people living around factories using PFOS.
Animal studies have shown that PFOS harms the thymus, the pancreas, the brain, and the immune system. What really alarmed the United States Environmental Protection Agency when they first looked at PFOS was that when they gave PFOS to pregnant rats, it killed the pups, their kids. When they lowered the level of PFOS enough so that the pups survived, many of the grandkids didn't survive, meaning that the majority of the pups' pups died. The EPA found this to be a rare finding, and they found it extremely alarming. At the time, they concluded that
PFOS represents an unacceptable technology that should be eliminated to protect human health and the environment from potentially severe long term consequences.
The United States banned PFOS in 2000, with certain exceptions. Since then, Sweden has called for a global ban, nominating PFOS as a persistent organic pollutant under the Stockholm Convention on Persistent Organic Pollutants, again with exemptions for semi-conductors and photography for the moment.
We were happy in the spring of 2006 to see this private member's bill, six years after the United States banned PFOS. We saw this as an attempt to catch up with our neighbours. Since then, the government has announced its own prohibition, with exemptions, and the government's assessment under CEPA, the Canadian Environmental Protection Act, found PFOS to be persistent and toxic, but not to be bioaccumulative. This is because of the way the regulations for bioaccumulation are written. They didn't anticipate that substances like PFOS would bioaccumulate in new and novel ways, or what we're finding out are new ways.
Even though PFOS is possibly the most bioaccumulative chemical we know, it has been declared not bioaccumulative in Canada. This private member's bill will declare PFOS a candidate for virtual elimination, as it should be as a persistent bioaccumulative and inherently toxic substance.
There is concern about a lack of alternatives in some uses: in making semi-conductors, for certain photography uses, and for chrome and electroplating. These exemptions are found in the proposed prohibition regulations. We think the government should take another serious look at the need for these exceptions, always keeping in mind that health and a healthy environment need to come first. In particular, there should be another look at chrome and electroplating. Half of the platers in Canada don't use PFOS, so it's hard for us to see why the others cannot switch over.
PollutionWatch believes that PFOS should be listed for virtual elimination, as it meets the criteria in real life. What the government needs is more flexibility in how virtual elimination is done. As raised before this committee at the review of the Canadian Environment Protection Act, virtual elimination needs to be fixed. We need to eliminate the level of quantification that is making virtual elimination unworkable.
As well, there should be the option of using prohibition as a tool for virtual elimination, so that we can put something on the virtual elimination list because it's persistent, bioaccumulative, and inherently toxic. The prohibition should be a justifiable way of making that elimination happen. The goal of virtual elimination, after all, is to continuously work towards getting rid of PFOS. In that light, any exemptions to a prohibition need to be temporary.
The objective is to eventually eliminate manufacturer import, use, and release. There is a global movement to do this, as I've said, with Sweden having nominated PFOS to be listed under the Stockholm Convention. Canada should be helping by vocally supporting this nomination internationally and by eliminating PFOS at home.
Finally, just as a comment, the PFOS case has revealed problems with our bioaccumulation regulations. The government should amend these regulations to reflect what we know today about bioaccumulation.
In summary, we ask the government to add PFOS to the virtual elimination list, to fix virtual elimination, to amend the bioaccumulation regulations, and to be a leader in ridding the world of PFOS.
Thank you.