This blog post provides a high-level overview of the federal government’s recent final State of Per- and Polyfluoroalkyl Substances (PFAS) Report (the “Report”) and accompanying proposed Risk Management Approach for PFAS (the “PFAS Risk Management Approach”). It highlights key findings, particularly the identification of PFAS “hot spots” and federally designated PFAS contaminated sites listed in the Federal Contaminated Sites Inventory (the “FCSI”). Additionally, it covers recent updates on the human health impacts of PFAS exposure.
The majority of these PFAS “hot spots” are linked to aqueous film-forming foam (“AFFF”), a firefighting foam widely used to suppress liquid fuel fires. According to the Report, PFAS contamination is especially prevalent at airports and military facilities, where AFFF has been used extensively in fire suppression, training exercises, and equipment maintenance.
Part 1: Canada’s Final State of PFAS Report and Proposed PFAS Risk Management Approach
On March 5, 2025, the Government of Canada released the final State of PFAS Report along with the proposed Risk Management Approach for PFAS. The Report recommends designating PFAS, excluding fluoropolymers, as “toxic” under Part 2 of Schedule 1 of the Canadian Environmental Protection Act, 1999 (“CEPA”). While this classification would not result in an outright ban, it would enable the federal government to implement the measures outlined in the PFAS Risk Management Approach.
The PFAS Risk Management Approach aims to minimize environmental and human exposure to PFAS as much as technically and economically feasible through the following phased strategy:
- Phase 1: Prohibition of the use of PFAS not currently regulated in firefighting foams, due to high potential for environmental and human exposure
- Phase 2: Prohibition on the uses of PFAS not needed for the protection of health, safety or the environment, which includes consumer applications (e.g., cosmetics and food packaging), and
- Phase 3: Potential prohibition on the use of PFAS where there may not be feasible alternatives at present (e.g., prescription drugs and medical devices).
The PFAS Risk Management Approach is open for public consultation until May 7, 2025, and comments can be submitted to: substances@ec.gc.ca.
Part 2: Federal PFAS Contaminated Sites
The Report states that despite PFAS being ubiquitous in the environment, certain locations—particularly sites where PFAS-containing AFFF has been used, such as firefighting training areas—are considered “hot spots” where elevated PFAS levels may be present.
However, contamination is not necessarily confined to these sites. Due to the high mobility of PFAS, contamination can migrate offsite, posing potential risks to human health and the environment over a much larger area. PFAS can travel several kilometers via groundwater and surface water, significantly expanding the potential impact of a single contamination point source.
One key pathway for human exposure highlighted in the Report is the consumption of drinking water contaminated by PFAS migrating from impacted sites (refer to Figure 2, as adopted from the Report).
Figure 2: Conceptual site model for a PFAS-impacted contaminated site due to historical AFFF use and associated human and ecological receptor exposure pathways to be assessed in a human health and ecological risk assessment, Final State of PFAS Report at page 22.
The FCSI identifies over 100 federal sites across all provinces and territories with confirmed or suspected PFAS contamination. The primary source of contamination at these sites is AFFF, which has been used in activities such as firefighting training and equipment maintenance.
Several PFAS were detected in the groundwater at former firefighting training areas in British Columbia, Alberta, Nova Scotia, Quebec, and Ontario. The Report also notes that many affected federal sites are located in areas where local communities rely on private groundwater wells for drinking water.
According to the Report, PFAS are difficult to remediate from contaminated sites and cannot be fully removed from the broader environment. The highest concentrations of PFAS are typically found near original points of release. If potential ecological or human health risks are identified at PFAS-contaminated sites, the Report indicates that action may be required to reduce or eliminate human exposure. Such actions may include:
- Providing alternative drinking water sources (e.g., bottled water)
- Installing water treatment systems
- Implementing food consumption advisories
- Remediating specific areas of contaminated sites to remove PFAS hot spots/source areas, and
- Conducting long-term monitoring and management accounting for:
- Changing environmental conditions that affect PFAS migration and transformation of PFAS precursors
- Expansion of the analytical suite of PFAS, and
- Updates to environmental guidelines.
Part 3: Updates on Potential PFAS Health Impacts
Although specific Canadian biomonitoring information is not available, the Report states that “people living in the vicinity of sites contaminated with PFAS (for example associated with the use of AFFF) may also be disproportionately exposed to higher levels of PFAS.” The highest reported PFAS concentrations are typically found near known sources, such as contaminated sites where PFAS levels may pose risks to both human health and the environment.
The Report highlights several key concerns regarding PFAS and human health:
- Significant Health Impacts Linked to PFAS Exposure: There is a growing body of evidence linking PFAS exposure to widespread health impacts across the human body. Studies demonstrate that PFAS can negatively impact the liver, kidneys, immune system, reproductive health, thyroid function, nervous system, and metabolism.
- Health Effects at Lower PFAS Levels Than Previously Thought: Recent findings show that PFAS—particularly well-studied compounds like PFOA and PFOS—can harm human health at lower concentrations than previously understood.
- Bioaccumulation and Long-Term Persistence in the Human Body: PFAS are not easily eliminated once absorbed, persisting in the body for years and accumulating over time. This bioaccumulation is associated with various negative health effects.
The Report makes one thing clear: due to the extreme persistence of PFAS, their ability to bioaccumulate in living organisms, and their resistance to environmental remediation, human exposure will continue—and potentially increase—without intervention.
This blog post was written by Michael Hebert member of the Mann Lawyers Environmental Law team and Nathan Adams (primary author), member of the Mann Lawyers Business Law team and Environmental Law team. Michael can be reached at 613-369-0360 or at michael.hebert@mannlawyers.com and Nathan at 613-369-0380 or at nathan.adams@mannlawyers.com.
