Click here to download full comment PDF, including detailed analysis that follows the cover letter below.
December 24, 2010
Mr. David Morin, Executive Director
Program Development and Engagement Division
Science and Risk Assessment Directorate
Environment Canada, Gatineau, Quebec K1A 0H3
Re: Teflon chemical PFOA – Comments on Draft Screening Assessment
Notice published in the Canada Gazette, Part I, p. 2760 on October 30, 2010
On behalf of the Environmental Working Group, a non-profit research and advocacy organization based in Washington, D.C., and Environmental Defence Canada we are submitting comments on the “Draft Screening Assessment for perfluorooctanoic acid (PFOA), its salts, its precursors” published by Environment Canada and Health Canada. Since the 1950’s, numerous industries have used PFOA to manufacture everyday consumer products, among them, non-stick cookware, food packaging and clothing. PFOA has become a pervasive global contaminant because of its widespread use over many years and its extraordinary persistence and toxicity.
As demonstrated by an extensive body of research, PFOA has been linked to developmental toxicity, immunotoxicity, alterations in hormonal levels, metabolic disturbances and an elevated risk of cancer. Environment Canada and Health Canada are right to give PFOA regulatory scrutiny. Yet the section of the draft assessment entitled “Potential to Cause Harm to Human Health” does not accurately represent the weight of the scientific evidence for PFOA’s potential toxicity to humans. Further, it appears to dismiss the risks of PFOA exposure to human health at pollutant levels to which the general population is typically exposed.
The assessment’s scientific analysis ignores at least 12 key epidemiological and laboratory studies of PFOA. As a result, the risk to human health may be up to 100 times greater than the assessment’s estimate. The assessment suggests that the dose of PFOA that causes adverse effects in laboratory animals is more than 2000 times greater than the PFOA contamination found in people by recent biomonitoring studies. However, a review of the most sensitive animal studies suggests that lab animals show damage at doses that are just 20 times greater than concentrations detected in humans. This number is much smaller than the 1000-fold margin of safety typically recommended by Health Canada for toxic pollutants. If these false assumptions are not remedied, Canada’s PFOA assessment will undermine ongoing and much-needed efforts to reduce PFOA pollution in people and the environment. We urge you to address the shortcomings of the current draft assessment, as outlined in our detailed comments attached.
|Olga V. Naidenko, PhD
Environmental Working Group
|Rick Smith, PhD
Click here to download full comment PDF, including detailed analysis that follows the cover letter above.