Per- and polyfluoroalkyl substances (PFAS) are man-made chemicals that are persistent (don't degrade) and toxic to human health and the environment. The Canadian Food Inspection Agency's (CFIA) interim standard is part of a broader Government of Canada suite of risk control measures intended to reduce human and environmental exposure to PFAS, from their point of manufacture to their disposal (product life cycle approach).
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Overview of engagement process
On September 13, 2023, after gathering input from federal partners, the CFIA began targeted consultations with the provinces and biosolids industry on the implementation of the standard. In addition, two focused engagement webinar sessions, one for provinces and the other for industry, were held on September 26 and 28. The written comment period ended October 11, 2023.
Feedback was received from:
- national fertilizer industry associations,
- individual biosolids processors and generators
- national and regional biosolids industry associations
- provincial government departments
6 different sets of comments and questions were received. Each clearly indicated that the respondents are very familiar with the issue, understood the proposal in detail and fully appreciate its impacts on their sector.
What we heard
There was overall support for the proposed interim standard for PFAS in municipal biosolids imported or sold as fertilizers. Both the industry and the provinces recognized that these contaminants are of concern to the public, industry and regulators. They also felt that the limit is reasonable and feasible to implement without causing major disruption to their business operation(s) and waste diversion in general.
Many comments emphasized that the most effective way to minimize PFAS levels in biosolids is to control their discharge at the source and voiced concerns that the public may perceive the standard as discriminating against downstream products which only receive waste and do not add to the level of contamination through their processing and treatment.
There were a number of requests for CFIA to provide detailed guidance to generators, processors and importers in the implementation plan (analytical parameters, sampling and sample handling procedures, accredited laboratories, the certificates of analysis, attestations and inspection processes and frequencies). Several respondents also questioned the narrow scope of the interim standard and asked that the CFIA would consider applying the threshold to composts, digestates and other mixtures, derivatives or organic residuals that are likely to contain PFAS.
The respondents also highlighted the importance of well balanced communication; one that not only identifies the risks of PFAS but also conveys the environmental and economic benefits of municipal biosolids for agriculture, organic waste diversion and recycling. Some also offered useful suggestions on how to best communicate the complexities of the issue to the general public.
How the feedback was considered
Additional clarity on analytical parameters was introduced to the proposed implementation plan and the CFIA committed to providing detailed guidance to generators, processors and importers on sampling procedures, analysis, criteria for certificates of analysis etc. The CFIA is also in the process of validating a testing method for PFAS in biosolids so additional compliance verifications can be done in-house in the future.
The CFIA will also continue to compile Canadian data on mixtures and other waste residuals to identify an appropriate threshold for these materials. Similarly, the CFIA will maintain its collaboration with Environment and Climate Change Canada and Health Canada on risk mitigation measures to minimize the discharge of PFAS at the source (manufacturing, consumer products etc.) and support provinces in the development and implementation of provincial risk mitigation approaches that meet their regional needs in terms of agro-climatic conditions and market realities.
In light of the clear need to continuously review the interim standard, the CFIA will closely monitor both scientific developments and risk mitigation actions taken by domestic and international jurisdictions and adjust its interim standard accordingly.
Next steps
The CFIA will begin its public engagement on the implementation of the interim standard in municipal biosolids imported or sold in Canada as fertilizer for a 60 day consultation. Comments will be compiled and analyzed. The final publication of the standard, and the detailed guidance to processors, generators and importers will be made available after the end of the comment period. The implementation of the standard is targeted for early 2024.