[All] Opportunity to require public reporting of PFAS releases to the environment by Canadian companies

[John Jackson]

All of you are aware of the hazards that PFAS are subjecting all life to. PFAS are a major threat to our well being because of:
the serious health and environmental impacts of PFAS at very low concentrations;
the persistent and ubiquitous nature of PFAS, and
the widespread use of PFAS.

Yesterday's Waterloo Record includes a column by regular columnist Susan Koswan, GLEN steering committee member, on the hazards of PFAS, the "forever" chemicals and "everywhere" chemicals. The article focuses on the products containing PFAS. Link to her column this week:

https://www.therecord.com/opinion/columnists/its-difficult-to-live-a-clean-life-in-a-forever-chemical-world/article_34896da2-9b2b-5025-8d66-3442733c435f.html

PFAS are not just in our communities in the products that we buy. PFAS are also released into the environment by the companies that use PFAS in the process of making these and other products, and when the products are disposed of and released from facilities such as sewage treatment plants.

In an effort to get information on these releases into communities across Canada, many of us have been working to have PFAS added to Canada's National Pollutant Release Inventory (NPRI). Success in this would mean that producers and users of PFAS would have to publicly report every year on the types and amounts of PFAS that they released to air, water, and the ground, as well as how much they transfer off site to disposal and recycling. This is a unique tool to provide for community-right-to know and to strengthen your ability to understand pollutants released into our communities, to encourage and support actions to reduce pollution, and to help track progress in protecting our health and the environment.

We are at the point where it is highly likely that companies will have to start reporting their releases and transfers of PFAS to the NPRI for next year and yearly thereafter. At our stimulus, Environment and Climate Change Canada (ECCC) is proposing to add PFAS to NPRI. We now need your help to get the legal requirement for PFAS reporting and to strengthen the PFAS reporting beyond what ECCC is currently proposing. For example, ECCC is now proposing reporting on a mere 131 out of the estimated 16,000 known PFAS. For ECCC proposal https://www.canada.ca/en/environment-climate-change/services/national-pollutant-release-inventory/public-consultations/proposals-changes/pfas.html.

We have put together a submission to NPRI on changes needed in the ECCC proposal to meet the full potential and needs. See attached submission. We urge you to sign on to the attached ENGO submission whether as an individual or as an organization. The timeline is very short. Comments must be submitted to ECCC by this coming Monday November 25th. We need to hear from you by 9:30 Monday morning so we can pull the sign-ons together and submit the document that day. 

The Grand River Environmental Network has already signed onto this submission. We urge others on the GREN list to sign on behalf of their groups or as an individual.

Please send the following information to Fe at deleonf at cela.ca <mailto:deleonF at cela.ca> by 9:30 am Eastern time Monday November 25.

Individual
Organization's name (if applicable)
E-mail
Province

If you have any questions or comments, don't hesitate to contact either of us.

John Jackson, Citizens' Network on Waste Management jjackson at web.ca <mailto:jjackson at web.ca>
Fe de Leon, Canadian Environmental Law Association  deleonf at cela.ca <mailto:deleonf at cela.ca>

John Jackson
GREN Chair
519-744-7503
17 Major Street
Kitchener N2H 4R1



------------------------------
John Jackson
17 Major St
Kitchener N2H 4R1








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