Continuing with comments on “fluoride” from the Canadian parliament website, so that readers can explore their preconceived ideas about what pollution consists of.
Proceedings of the Standing Senate Committee on Energy, the Environment and Natural Resources – February 26, 2008 (original: http://www.parl.gc.ca/39/2/parlbus/commbus/senate/com-e/enrg-e/04eva-e.htm?Language=E&Parl=39&Ses=2&comm_id=5)
With respect to pollution, it is not something that we see in the North — with all its vastness, it is so pure. We are so far away from the industrial heartland of our country. I continue to be amazed at scientists who study the contamination of the North and find all sorts of mercury — fluoride from Mexico or Texas finding its way to the Arctic.
When you travel to the North, you will not think it is polluted in any way. It looks so pristine. However, many contaminants are finding their way to the North.
Mr. Laurence Moore, Member of the Board of Directors and Manager of Environmental Programmes, Ontario Clean Water Agency, Canadian Water and Wastewater Association:
Mr. Chairman and members of the committee, the Ontario Clean Water Agency serves about 250 municipalities in Ontario with both water and wastewater services. I am here with Duncan Ellison, head of staff of the Canadian Water and Wastewater Association, to bring the position of that association to this committee, and we appreciate the opportunity to do so.
The Canadian Water and Wastewater Association represents on a national level municipal non-profit agencies or organizations that provide those essential water and wastewater services. Altogether, we represent about 4,000 municipalities that serve 24 million to 25 million Canadians.
These municipal services, as many of you know, are already very strictly regulated at the provincial level as well as at the municipal level. Municipalities have no option but to operate the facilities in total compliance with provincial law. In fact, my job as manager of compliance is to ensure that we always do so.
We contribute to the development of regulations and the guidelines that often precede the regulations. Across North America, various water and wastewater utilities contribute about $36 million to research to continually improve the regulations and the science. Over the last 10 years in particular, there has been a high level of cooperation at the federal and provincial levels to harmonize the regulations across Canada and to continually raise the standard. Therefore, none of the standards are getting weaker. They are consistently getting stronger as our understanding of the science becomes better. We fully support the efforts to raise standards to ensure public health and to protect the environment.
Therefore, when we appear before a committee like this, we do not want to be seen as a group that is trying to weaken or soften standards. Our position is clear. We support the fundamentals of the bill to protect the environment. However, we have some concerns focusing on the same thing that virtually everyone else who has appeared before the committee has been concerned about, that being the process for listing toxic substances under the provisions of the bill. We believe that in this bill there are some real barriers to us successfully carrying out our duty to protect public health through the operation of our facilities. We are asking you to help us find a way of overcoming those barriers.
Like many of the other speakers you have heard, we believe that it is reasonable for Canadians to expect that, when a substance is declared toxic, efforts will be taken to save them from harm’s way. The listing alone gives people that reasonable expectation. It is an unequivocal statement by the Governor in Council that the named substance is toxic.
The Canadian Water and Wastewater Association submits that there are two flaws in the process required by the bill. First, there is a failure to take into account that there may be health benefits from the use of a substance, as well as environmental impacts. Second, there is a failure to declare the levels of concentration or quantities that are of concern.
Without amendment, substances which in their normal uses have public health or safety benefits while in other respects may present an environmental hazard, or vice versa, are labelled as toxic under CEPA. In any case, no consideration is given to the concentration of those substances or the quantities that may be discharged.
In short, although it may seem counter-logical, there must be more than proof of toxicity to list a substance under the Canadian Environmental Protection Act. In our view, it is not enough only to prove that something is toxic.
Municipalities expect new water or wastewater plants to serve them for 60 years or more. These plants require huge capital investment, often the largest capital investment in a municipality. These facilities can be modified and upgraded, but it normally costs a great amount of money to do that and those expenditures have to be weighed off against other uses that might have a greater public health or environmental benefit.
We work with our municipalities to make those investment decisions based on the best scientific knowledge. As I mentioned before, great effort goes into establishing that knowledge. Municipal governments look to the industry leaders, provincial regulators, and the federal scientific authorities like Health Canada and Environment Canada, for this advice. Therein lies our interest specifically in the provisions of the bill regarding the assessment and evaluation of chemical substances.
We submit that there are some substances that should not be listed or that, if listed, should be quantified by the levels of concentration or the quantity of concern. I think it is clear that, when a substance is declared toxic, it forever colours the character of the agencies and the organizations that use it. If we use a number of declared or listed substances, do we suddenly move from the side of protecting public health — which is what we consider our sole job — to being polluters of the environment because we emit toxic substances or we use a toxic substance in the very act of protecting
public health? We are concerned about having to carry that taint with us.
For example, chlorinated municipal effluents were found by Health Canada not to be toxic to humans when the substance was evaluated under the first Priority Substances List. Yet, it was found to be toxic to the environment by Environment Canada. This is not a surprise. Chlorine kills things. Chlorine is toxic. As such, it was added earlier this year to the List of Toxic Substances. The problem we have now is that few members of the public really understand that chlorine is added to municipal wastewater effluent streams under provincial regulatory requirements to protect public health. There was a clear acknowledgement and a thorough risk assessment of the public health benefits of adding chlorine versus the potential environmental impacts of adding the chlorine to the effluents. That risk assessment was already done and, yet, here it is, it is listed now as a toxic substance under the Canadian Environmental Protection Act.
There are thousands of wastewater treatment plants across the country that use chlorine as a disinfectant. It was, for decades, the only effective disinfectant available and it kills all microbial risks coming from a wastewater plant. Provincial regulatory requirements often set out the minimum doses of chlorine — not the maximum — that we have to add to the discharge. They also specify the time of contact to ensure that you end up with a safe effluent.
It is possible to dechlorinate a chlorinated effluent. However, again, since there is no quantity provision in the bill, even if you dechlorinate, there is always a trace of chlorine, so no matter what you do, if you have added chlorine, you will have a toxic discharge. Let me discuss my own company. We have several hundred toxic discharges in Ontario. That is potentially a problem because they are no more toxic now than they were before, and, again, it is added only to protect public health.
There are some alternatives, to be fair. The most powerful recent one, and one that we use quite extensively, where necessary, is the use of ultraviolet radiation. You put tubes in the discharge, they emit powerful ultraviolet light, and that kills most organisms. However, there are trade-offs there. Those units use very large amounts of power, of electricity. In most parts of the country, that means burning fossil fuels, which, of course, contribute to acid rain, the greenhouse gas effect and so on, plus you must consider the cost of the power. Those tubes also contain significantly more mercury than a normal fluorescent tube, so you have to handle those tubes very carefully. Finally, you have to wash the tubes occasionally with very strong phosphate solutions, and I think everyone understands the impact of phosphate. Alternatives may not be better. We have firsthand knowledge of several situations where we put in a UV system, and it did not kill the microbes sufficiently, and we had to go back to chlorine, so it is not a solution in all cases.
The assessment process set out under the Canadian Environmental Protection Act does not take into account the possibility of net public or environmental health benefits in the determination of toxicity. Under the current and proposed regimes, the assessment process determines whether or not a substance is toxic to human health or the environment. If it is found to be toxic under either of these criteria, it is declared so. If it is found to be persistent or bioaccumulative, then it proceeds to the virtual elimination category. Otherwise, it goes into the risk-management phase.
The point in issue is that investment decisions may be provoked by simply declaring a substance to be toxic and the resulting pressures to do something about it. The expectation is there to do something, to demand why this effluent is still chlorinated?
It is important to note that the infrastructure changes necessary to accommodate or use a substitute substance or technology is likely to be very expensive — billions of dollars across the country.
The CEPA process does not require the Governor in Council to declare what the concentration or quantities of concern are at the time of listing a substance on the List of Toxic Substances. That is despite the fact that these two essential quantitative sets of data have almost certainly been identified in the assessment process. They are therefore known but not shown. The only exception to this is when a substance is to be added to the list of substances destined for virtual elimination.
Let me give you a couple of examples. There is the example of Aspirin. In low doses, it is great for you; take too much, and you have a serious problem. We have another one in the water industry, the use of fluoride. Under municipal bylaws, we are required to add fluoride to the water. Everyone knows that fluoride is a toxin. At high concentrations, fluoride is definitely toxic. In fact, as a gas, it is terribly toxic. Of course, there is also the debate about using it in toothpaste. There is a huge public debate about the use of fluoride in water. It is not one of the substances under consideration at this point, but if it ever were to be tested under the system, it certainly would be declared toxic — no ifs, ands or buts about it — but for what net benefit? There would still be the discussion, yes, it has benefits and, yes, it is toxic. How do you propose to deal with that?
The same is true for many other substances.
The water in your glasses and the water in the bottles that we distributed is safe, clean water. It is totally fit for human consumption — this is the water from Ottawa-Carleton — and yet it contains within it a substance that is being considered for listing as a toxic substance. The substance that is in this bottle and in your glasses is a substance called chloramine. It is a combination of chlorine and ammonia that is added to the water to keep it sterile as it passes through the distribution system and through your tap, so that when it comes out of your tap, it is a safe product. It is not enough just to disinfect the water when it leaves the plant. You have to add chlorine or chloramine through the process. Chloramine will be declared toxic, so your water will be toxic — not toxic to you but to the environment. If you have poured it on your lawn or put it in the Ottawa River, you are putting a toxic substance in the environment. Does that make sense?
It is for this reason that the Canadian Water and Wastewater Association is asking this committee to consider two sets of amendments to Bill C-32. The first is that the ministers take into account the concept of the net environmental and health impact in arriving at a decision to declare a substance to be toxic under CEPA. The second is to specify the concentration or quantities of concern at the time that substance is added to the List of Toxic Substances. Thank you very much.
Linda F. Duncan:
There are technologies that can make coal cleaner. You can scrub to reduce the sulphur. You can put on fixes to reduce the nitrous oxide. However, the mechanism we recommended in Alberta to reduce mercury will also reduce all other heavy metals. There are many other bad substances in coal-fired. We dealt only with the top five in Alberta: greenhouse gases, particulates, NOx, SOx and mercury. In this report, you will see there is another whole string of substances that we have not even started dealing with. Apparently, polycyclic aromatic hydrocarbons or PAHs are another one, as is hydrogen fluoride. Coal-fired plants emit more than aluminium refining does, yet the latter is regulated. Coal is an incredibly dirty source of power.
“Clean coal” is a moniker people throw out as if to say, “Is this not great? We can have clean coal.” You can have cleaner coal, but you can never have clean coal. Plus, we need to keep in mind that we will recover or capture the mercury, but what will we do with it then? The end objective has to be that we need to stop producing mercury. It would be great if we had more and more renewables and less coal, but in the meantime we need to ensure that we are at least not emitting it into the environment.
Canadian Liberty comments: I think the system is “broken” and it’s never fixed. Government doesn’t fix it and doesn’t protect us. We’re always depending on central authorities and experts to tell us what is good for us or bad for us and to monitor coal plants etc. (supposedly). Now well-meaning people are mixed up about the idea of clean non-polluting “greenhouse gases” as if they are real pollutants, which is nonsense. The issue is that the idea of government regulating substances doesn’t work and fails to protect us. What matters is whether harmful substances – like mercury and fluoride – land where they are not wanted, in someone’s body unwanted, or in someone’s air or drinking water unwanted, or on someone’s property unwanted. That should be a matter of choice and contract, and restitution, and people should be able to take some kind of legal action to protect their personal and property rights at the drop of a hat. Otherwise we’re at the mercy of bureaucrats and central planners whose priorities are out of sync with individual rights. The system is in place by design to protect the military industrial complex. The central planners hate property rights protections and started destroying them a long time ago so they could take decisions about pollution levels out of our hands. The ruling class who control the politicians are not making any movements in that direction, they will continue to undermine property rights with “greenbelts” and “smart growth”, and will leave things broken so they can keep offering “solutions” such as even greater central planning and
Every product introduced and every questionable chemical (see below) means that there is no reason to trust industry and government at all until the day comes (if it ever does) when we are all involved and informed in our own protection as individuals. A top down system where government and big business are integrated has FAILED ordinary people, but all these institutions do is become ever more tightly integrated with each other.
Scott Mabury, Professor of Environmental Chemistry and Chair, Department of Chemistry, University of Toronto:
…The topic today is CEPA. I was specifically invited to talk about perfluorinated chemical pollutants vis-à-vis CEPA. I am a researcher with a large group at the University of Toronto in the department of chemistry, working primarily with graduate students. We are trying to learn why the Arctic and humans are so contaminated with perfluorinated chemicals. There are specific perfluorinated chemicals called PFOS, also known as Scotchgard, and PFOA, and they are the two most widely recognized within the press and the larger community. They are also the ones with the highest concentrations in humans. Everyone in this room has these chemicals in their blood at reasonably high concentrations relative to some other chemical pollutants that are also in our blood. The question of why they are there and how they got there is important. Without knowing those things, it is difficult to address the problem…
The problem is significant concentrations of PFOS, PFOA and PFCAs in polar bears and humans. Those acronyms describe their chemical structure. They are in your blood and there are particularly high concentrations in the Arctic.
There are two theories. On the next slide are two ideas about how the Arctic got so contaminated. When I say the Arctic is contaminated, the concentrations in polar bears of these chemicals that were only discovered a half a decade ago are in the order of, and many times exceed, the concentrations of the other chemical pollutants that have been so infamous: DDT, polychlorinated biphenyls, all these other industrial compounds that we have been studying for decades that have been banned and not used for decades, at least in North America. More recently, the perfluorinated compounds were discovered in these animals and their concentrations often exceed any of these other pollutants — which was a bit of a surprise. The real surprise is the fact that PFOS and PFCAs, their chemical personality — and I often talk in personalities of chemicals. The personality is driven by the atoms in the molecule and how you put them together. Just as this building has a function and a personality, so would an igloo. You build it out of different materials, and it would function differently. Chemicals are that way as well. It is surprising because these chemicals will not fly — in other words, they could not have gotten to the Arctic as they are through the atmosphere. Given that polar bears do not wear Teflonized coats, do not have carpets in their homes and do not have Teflon frying pans, how in the world did these critters get contaminated? There are two ideas.
First, the industry, in the making of these fluorinated compounds, released these materials themselves directly into the environment, in and around industrialized portions ofthe world. There is a plant in West Virginia that was releasing 60,000 pounds of PFOA into the Ohio River every year, up until about 2000. Those are very large quantities. One idea is that the materials went down the Ohio River, down the Mississippi, into the Gulf of Mexico, up the Atlantic and made it to the Arctic. That is one idea.
The idea that we have been investigating — and scientists posit hypotheses; we must have a question to test, because that is the scientific method. Our theory is that the source is an indirect one, fluorinated precursors — and “precursor” will be an important word today — because it is the precursors that are actually used to make the materials that go on to carpets, fabrics and paper products. We believe it is those precursors that can fly because their chemical personality is such that they are very volatile and evaporate easily. I am sure we can measure them at reasonably high concentrations in this room’s air. Researchers have measured indoor air environments and we find these things. We have measured these outside all across North America in the atmosphere. They are there. We have hypothesized that they act as the travel agents for getting the basic structural unit to the Arctic and then in the atmosphere they degrade into the acids that we then measure in seals and polar bears. They move up the food chain.
Hence, there are two very different hypotheses. One is a legacy problem, meaning four or fives years ago industry said that it cannot put 60,000 pounds of PFOA annually into the Ohio River, that it will simply stop and divert that. The other idea is not a legacy problem, it is ongoing. It is endemic to the use and design of the materials. Therefore, testing, interrogating these two high hypotheses are appropriate because it will be a very different set of actions towards solving the problem of contamination of the Arctic, and ultimately contamination of humans, because we need to know mechanistically and practically how that contamination occurs, otherwise we cannot solve the problem.
At the bottom of the second page of my handout, the precursors are the compounds on the left-hand side, and they look differently. Whether or not you are a chemist, those houses do not look the same. The left-hand side of the molecule is the fluorinated portion, all those Fs in blue, is what imparts the properties we want. That fluorinated chain, because it looks like a piece of rebar, is very stable. If you coat the surface of this carpet here with it, we could dump water or wine on the carpet, throw grease onto it, but none of those materials would get into the carpet because they are repelled by those blue fluorines. Those blue fluorines repel water and oils. We refer to that as hydrophobic — it does not like water; and it is also lipid-phobic — it does not like lipids.
They are wonderful materials with respect to keeping fabrics, carpets and ultimately paper products functioning well. Popcorn bags, for example, have coatings on the inside so that when popcorn is cooked in the microwave the grease does not go through the bag. It is that fluorinated tail that causes that repelling. It is a property we like. It is a multibillion-dollar industry in the context of consumer products. The polymers themselves that are put onto fabrics are worth a few billion dollars. I have understood that the products themselves are in the tens of billions. This is a major consumer market internationally.
There are ideas that these volatile precursors escape from carpets, fabrics and from manufacturing locations and get away. If you turn to figure 3 at the bottom, there are many ways we can incorporate — the blue at the top, fluorinated alcohols for fluorinated surfaces, all these blues are what cause these surface properties. We can incorporate them across the bottom into surfactants. Surfactants are nothing more than a special name for soaps. Surfactants are what we use on the inside of those popcorn bags on paper products. They are widely used.
In the picture on number 4, fluoroalcohol-based coatings are heavily used in consumer products. I am signifying that these are millions of kilograms per year, at least the top ones, thetelomer-based compounds. POSF-based production ended in 2000-2001, but it was millions of kilograms at the time. Different manufacturers use different processes. That is driven by patent protection of intellectual property, depending on the kind of process a company has.
In this picture, I show my carpet on the bottom, an individual carpet fiber, and we have coated that fiber. There is a question of whether residual materials, basically leftover starting material, are escaping. The alcohol is a precursor to the right. That is what escapes into the air. Or do these materials degrade in place? This is a significant scientific question. EPA in the United States mandated one of the major manufacturers to spend $5 million to answer that question. Do these compounds degrade in place in their process? It is a question we are also trying to answer. The bulk of these materials is still found in the polymers themselves. They will eventually end up in landfills or sewage treatment plants. It is a question of whether that very large amount of reservoir material will ultimately release these compounds into the environment.
We have looked at the residual question at the top and measured residual alcohols, precursors brought along in the process. No chemical synthesis is 100 per cent efficient. My best chemist at the University of Toronto Chemistry Department cannot get a 100 per cent yield on a reaction, no matter how good they are and no matter how good the reaction is. There will always be impurities, starting material left in that reaction. In industrial materials and in consumer products — Motomaster windshield washer fluid, for example — we have measured these residuals. We have measured them on a few per cent by weight basis. A few per cent does not sound like a lot, but if you take 2 per cent times 12 million kilograms, you will get a quarter of million kilograms released annually.
We have measured these compounds all across North America. If you calculate how much would have to be released annually to maintain those concentrations, it is on the order of a quarter of a million kilograms a year. We believe residuals are very important. These impurities — starting materials — that are brought along that serve no function in the material used by the consumer may be a significant or potentially even the most significant source of these compounds to the environment. We will talk later about what to do about the problem, but certainly a cleaner final consumer product would be part of that.
I will not read the hypothesis on the next page. I am showing out what the hypothesis is about these indirect routes. Also at the bottom, we must interrogate hypotheses. It is true that you cannot prove a theory, that you can only disprove it. One of the things a good scientist will do would be to try to disprove his or her own theory. Someone once said that it only takes one ugly fact to kill a beautiful theory. We can obtain more evidence that is consistent with a theory, but ultimately proving a theory is problematic. Therefore, we have interrogated what we call the PAART theory, the precursor alcohol atmospheric reaction and transport, because the atmosphere is important. We have been interrogating it. We have published in the orderof 40 peer-reviewed papers looking to see whether the evidence supports that theory about why the Arctic is contaminated.
I will run through some of that evidence. On the next page, the one headed “AtmoChem: greatly simplified. . . we have learned:” we have learned that these alcohols will live in the atmosphere for about 20 days. It does not sound like a lot, but that is a long time. Mother Nature is exceptionally good at cleaning the atmosphere. She has a detergent called hydroxyl radical, which reacts very quickly with most of the compounds we release into the atmosphere. Mother Nature is actually a much more profligate polluter than we are. Natural emissions represent 10 times the amount of organic compounds that humans release every year. Yet, other than the fact that it is cold this morning and there is snow in the air, visibility is actually quite good outside buildings. That is because the atmosphere is very good at cleansing itself.
Twenty days is actually a long time. Most organic compounds degrade in the atmosphere minutes to hours to at most a few days. Gasoline components, for example, degrade on the order of hours most of the time. The important point about 20 days is that these compounds can travel great distances. We have calculated at least 8,000 kilometres before this molecule would be degraded.
The good-news story is that 90 per cent of the time Mother Nature takes these industrial compounds that have great consumer uses and degrades them all the way down to their inorganic, natural constituents of fluoride and ion and carbon dioxide. That is a good thing. Mother Nature is very good at taking what we throw at her, even though she has never seen it before, and processing it back to the elemental constituents that are indistinguishable before we touch them.
What is problematic is that about 10 per cent of the time, which is the bottom action, in a relatively novel discovery that my research group has done, about 1 per cent to 10 per cent of these end up as the perfluorinated carboxylic acids. These are important because they are extremely persistent; no one has seen them degrade under any relevant environmental conditions at any rate. I have been quoted as saying they redefine persistence. Rachel Carson, in Silent Spring, wrote about chlorinated pesticides because they were so persistent. Persistence in DDT is measured in decades. Persistence here — I cannot give you a number because no one has seen it degrade under any relevant conditions. However, when I say it redefines persistence, I am talking many orders of magnitude longer than decades.
If you combine that with delivery to remote regions, it is combined with a sufficiently large molecule — that is, more than seven carbons with fluorine, and that will be important later on — these things will bioaccumulate. If they are less than seven, they tend not to bioaccumulate; if they are more than seven they tend to bioaccumulate. It is not accidental that the one that is in your blood at the highest concentrations has seven carbons with fluorine. They are of toxicological interest, at least at high concentrations.
Therefore, we have this idea that the atmosphere delivers these things to remote regions and then degrades them and inputs into the Arctic these final degradation products that then move up the food chain. How do we interrogate this? We measure these alcohols in the air, as I mentioned before. We have measured them all over North America. Five or six years after we first measured them, other people are now measuring them and publishing. That is the other thing that has to happen in moving science forward — results must be replicated by other independent groups. It is heartening that that is being done.
However, in this interrogation, we modeled how much could be delivered to the Arctic. We say it is about 400 kilograms per year into the Canadian Arctic of these compounds. In order to measure, I sent Cora Young, a grad student — and the next picture is of her on the Devon Ice Cap in April. It is a rather chilly place to be. It took them a week to dig a pit about seven metres into that ice cap because it is like chipping through solid ice, of course. We wanted to be able to drive our sample apparatus into the side of that wall because we could then sample the deposition from 1999, 2000 and 2001. Not only did we want to measure how much comes in every year from the atmosphere — and the reason we are in the middle of the Devon Island is that so we could measure what was coming in by the atmosphere — but we also wanted to know if those concentrations were changing over time. I will get to that again in a minute, but there have been drastic changes in industrial production of some of these compounds.
The problems were that, in doing this, these concentrations are very low. They are a real challenge. Most modern camping gear, because of functionality, contains fluorinated materials. We could not have any of them anywhere near this sample site because they would contaminate the samples and there would be a systemic bias to being able to measure what is actually coming in through the atmosphere.
My student had to call up her uncles and go into the attics of various families and find sleeping bags and Arctic gear orcold-weather gear that was pre-fluorinated coatings. As she reported, they do not quite work as well. She did not stay quite as warm as she needed to, nor as dry as she needed to, but at least in terms of the tests we did on our blanks we were able to get samples without contaminating them.
The next slide is a data side. I show it in part so that you see we were able to measure back to 1996. We could measure year by year the flux, which is a fancy term for how much is delivered per square centimetre in mass per year. The top four panels are going up, but the bottom panel, PFOS, goes up in the 1990s and then goes down rapidly after 1998, 1999.
On the bottom right-hand side, we measured in three locations in over two years between 114 and 586 kilograms per year as calculated for the whole Arctic. The model prediction is 400.
This is an example of positing a hypothesis, modelling everything you know about the environment and then making a measurement. Anyone involved in the debate about climate change and global warming has been debating how good the models are. Of course, the models will actually be tested when you are able to go through time and test how predictive and how accurate those models were. We did a reasonable job. It means we understand most of what is going on in the atmosphere and that if we make the right assumptions they will come close to what is actually measured. We took heart from that. That research is currently being evaluated for publication.
Is contamination changing with time? On the next page, you have a picture of a seal, a map of northern Canada with a red dot at Resolute, concentrations on the Y axis and different chemicals along the X axis. The blue is doubling time. PFNA — “N” isfor 9 nonanoic acid, that is nine carbons. The first four increase from 1972 to 1993 to 2000 to 2004. They may have gone down between 2004 and 2005. We do not make much of that change because it is only a one-year observation.
I point out PFOS, that is Scotchgard, on the right-hand side. It had a doubling time of seven years — that is, every seven years it doubled, from 1972 to 1993 to 2000. Then something dramatic happened. Between 2000 and 2004, there was a reduction and between 2004 and 2005 there was a reduction.
We published at that point because we have a separate location, Arviat at Hudson Bay, that showed a very similar trend with respect to PFOS. We saw a two-year reduction. The evidence suggests that it is real. We took samples in the spring of 2006. We will be analyzing those sometime in the next month, to see if the reductions continue. We felt that the evidence is consistent that the reduction is real.
Why is that important? Over 2000 and 2001, 3M, the primary if not the sole major producer internationally, ceased production.In fact, over the course of 2000, they had reduced on the order of 90 per cent.
It is truly phenomenal that there could be an industrial change in the year 2000 — the first publication of contamination in the Arctic was in 2000 — and that by 2004, we see a reduction, an actual change, a positive impact in the environment. I view that as an incredibly good-news story. DDT and PCBs, which were first noted by Rachel Carson in the early 1960s and bannedin 1972 — you may read in the paper now and then that there seem to be lower concentrations in the sediment in Ontario or lower concentration in meat eaters among the human population; however, we are still quite contaminated.
The summary of testing for indirect route, the PAART theory, I simply take all of the experiments and measurements we have done that directly test the theory. We have found the precursors in the atmosphere. Are they sufficiently long-lived to be transported long distances? Yes. Does atmospheric transformation, in other words, does Mother Nature degrade these compounds into these pollutants that we are interested in? Yes. Do we understand the mechanism? Yes. Does the model output suggest significant production? Yes. Are they in rainwater? I have not shown you the data, but we published a paper finding these acids in rainwater and, more important, finding the intermediates. We do not go from one chemical directly to the other. There are a lot of intermediates that we have found. Again, it does not prove the connection, but it is strongly indicative and supportive of a connection.
Just as humans have different fingerprints, depending on who the manufacturer was, we can often tell who made these chemicals because the isomeric signature will be different. That is also consistent. Are the actual measured delivery flux values in the Arctic consistent with the model? Yes. What are the temporal trends in these biota? They are also consistent. At the bottom, I say all published experimental evidence is consistent with this precursor theory being the major source of Arctic contamination.
There is an alternative theory, that the legacy gross contamination by industry of the environment with these compounds directly into the pipe, which was going on until at least 1999, is the source. There have been two papers published that in a model suggested that that is important. As I said before, it leaves the plant in West Virginia, goes down the Ohio River, down the Mississippi River to the Gulf of Mexico, up the Atlantic coast, to the Arctic, and then moves up the food chain. The problem is that there have been no measurements to support that theory. Many of the things I show on the top of this slide, evidence for PAART, are actually directly contradictory to a direct source.
Let us turn to a more pertinent question. What about us? I have a picture of the local skating mecca. What I show at the bottom is published data — author, the year, and the location — for these compounds measured in human blood.
The first compound PFOA and the last compound PFOS have been measured in every human blood sample ever tested anywhere in the world, I understand. Concentrations in remote regions of South America are very low. Concentrations in the industrialized world are largely similar, but it is endemic and it is consistent across basically the industrialized world.
…They are there. How did they get there? The next picture spells out the possibilities. Again, we have an indirect route and we have a direct route. The right-hand side is the direct route. Really, this is ingestion of food and water. PFOA, perfluorooctanoic acid, is used to make the world’s Teflon; it is required as a processing aid. The West Virginia plant was a Teflon plant. The PFOA is what was released out of the end of the pipe. We could get PFOA from food and water, and I am sure we do. You have the direct route.
You also have an indirect route, meaning we are exposed to something that will be degraded or metabolized into PFOA. I show that right in the middle. These precursor alcohols — the OH means alcohol — in fact, the right-hand side of that molecule looks just like ethanol except we put a fluorinated tail on it. We will metabolize those alcohols into the acids if we are exposed to the alcohols. How can we become exposed to the alcohols? At the bottom, fluorinated polymers, or residual alcohols, escape from those carpets. Dr. Tom Harner, with the Meteorological Service of Canada, has measured these inside Ottawa homes, I think on the order of a few hundred Ottawa homes, and I do not believe the data is published yet, but he has measured very high concentrations of these alcohols in pretty much every home he has tested. Some homes are higher than others. It varies by a couple of orders of magnitude, hundreds of times, but every home has some. If you are breathing inside that home, you will be exposed to that alcohol and you are going to metabolize those alcohols into these compounds that we measure in blood.
There is another source, one we have been looking at, fluorinated surfactants or food packaging. These are phosphates. As I said, you place these phosphates with the fluorinated tail onto pizza boxes, fast food wrappers and popcorn bags. It is quite extensive. FDA assumed three things. FDA assumed they would not move into the food, that they would stay on the paper. They assumed if it did move into the food, it would not be bioavailable — that is, that it would not enter the bloodstream, it would simply go straight through. The third assumption was, if it was bioavailable, it would not actually metabolize and release the alcohol; it would be persistent and stay in there.
They are wrong on all three counts. An FDA scientist published a paper showing these surfactants actually do move out of popcorn bags into a food simulant.
Is there a difference when they are heated or not heated?
Yes. The heat and activity of cooking helps facilitate that movement. Frankly, extensive investigation or testing of how and how much and how you can modulate that has not been done yet. It is only a does-it-happen-or- not level of understanding.
We have done some experiments. We have synthesized those surfactants and dosed some rats with them. We have a paper in review now that basically shows that the surfactants used on popcorn bags are converted to FTOHs, which are in turn converted. You are exposed to the phosphates. You metabolically convert them to the fluoroalcohols. The fluoroalcohols are metabolized, just like you metabolize ethanol to acid aldehyde and then acetic acid. You metabolize these fluoroalcohols to some intermediates, some of which are very reactive. I put a big box around that and a star on reactive intermediates because that could be problematic.
Finally, PFOA: Our evidence suggests that some of the PFOA in human blood comes from this route — that is, a metabolic route. We make them. There are some references down at the bottom. We think this is important because the intermediates are potentially toxic.
To draw this to a close, what have we learned? There is substantial evidence for significant indirect pathways. What is the practical difference? The practical difference is that the indirect pathway is not a legacy problem, but it is ongoing.
Reactive metabolites of FTOHs are a different ball game. The world scientific community, because of all the interest around perfluorinated pollutants in human blood, has been testing in a significant effort to find out if PFOA is toxic, the ultimate degradation products. Are they toxic, and how toxic are they? We know little about the longer chain versions. We were the first group to discover these in the Arctic. They go up to 15 carbons with fluorine on them. The seven-carbon fluorinated PFOA is the most popular one, and you will read about it in the press all the time, but the longer chains are there as well. People who did not observe them did not look for them. That does not mean they were not there. We know relatively little about their toxicity. In my view, that is not nearly as important as the fact that if they are made within us, it is the intermediates that are of toxicological interest to a much greater extent.
Would you expand on that? You highlighted the importance or significance or possible significance of the reactive aspect of this. I gather that is what you mean. We are synthesizing these components and making bad stuff.
I think we are making things that any toxicologist would look at and say, “Wow, that would be interesting to study,” because it has the chemical personality of being highly reactive. It has the same structure as many chemicals we know to be highly toxic, that we know to be cancer causing, for example, and that we know are problematic. No one has studied those. We are studying them. A scientist wants to work on problems that are hard, that have significance and that will be important. I am not the slightest bit interested in working on the toxicity of the final degradation product because I do not find it interesting. I am very interested in looking at investigating those reactive intermediates because, from my way of thinking, it is a more important problem. It is certainly intellectually a more interesting problem. We think it is more important.
Solving the problems requires different actions. There are at least three possibilities, and it is useful to go through these.
I have a picture here. The blue ones are the ones that are bound down, are stuck on the carpet. The red ones, as you can see, have no tether. They are not stuck, so remove them. If you go to the next slide, they are not there.
If residuals are a significant proportion — and I said before if it is a few per cent, a few per cent represents a quarter of a million kilograms per year. If a quarter of a million kilograms per year is the major burden in the atmosphere, then it suggests that, if you remove residuals, you will change the air concentrations and ultimately solve problems. We think that is important. We do not know if it is the only source and, in fact, I doubt it, but we do think it is significant.
What to do? Number 2? Shorten the perfluoro chains. Six or less carbons will result ultimately in PFCAs that are not expected to bioaccumulate. If you shorten them enough, even if they get away, even if they get transferred to the Arctic and they will be degraded into the acids, they will go into the Arctic at hundreds of kilograms per year, but they will stay in the water.
Will they still be effective?
Certainly some industries say no, and others say yes. 3M has put their reputation on the line in the structure at the bottom. I suggest 3M is not a risk-taking company to take Scotchgard, a popular and well-known trademark, and start marketing a chemical that will not work. Their new Scotchgard only has four carbons with fluorine on it. Why? Because the ultimate degradation product, perfluoro butane sulfonic acids, PFBS, will not bioaccumulate. You can put it in the water and put fish in the water, and you will not measure PFBS in the fish. If you put PFOS, eight carbons, in the water and let a fish swim in it, you will measure high concentrations in the fish.
You cannot have toxicity without exposure. That is what they are banking on. They will still be making a degradation product that will not degrade under any environmental conditions we know, and so will be around for a long time, but if you do not have exposure, you cannot have toxicity.
We as a society have said that the CFC replacements, the fluorinated HFC-134a that we use in our refrigerators and air conditioners, is a huge plus over the ozone-depleting chemicals that came before. The fact is that that chemical comes back in rain as trifluoro acetic acid in significant qualities. Trifluoro acetic acid does not degrade under any known environmental conditions. It will be out there for 100,000 years. Does it matter? We, as a scientific society and regulating society, say no, it does not matter, because it sits in the water and nothing ever happens. Probably the same will be here.
Does it work? 3M thinks it will work, and I have heard of and been asked to do contract research, which I tend to not do, on those shorter analogs. Will they also do all these things? All I have to do is look at the structure and say, yes, they will still make the acids, but we have already published two papers saying less than seven carbons will not bioaccumulate. It is scientifically and intellectually not interesting for me to do. If they do work, then they are better, in my view, from an environmental contamination problem because the degradation products will not bioaccumulate.
What to do? Use stable linkage chemistry. If it turns out that the polymers themselves, the reservoirs, slowly degrade in sewage-treatment plants, in the sediment of Lake Ontario or in waste landfills, that is a problem because it is a long- term emission of low levels of these compounds. We do not know that yet, but if it is shown that that degradation does occur, and we have preliminary evidence that it does, then how you take your fluorinated material and bind it to the surface will matter. Different companies have different processes. An organic chemist will know that an ether is not the same as an ester is not the same as a urethane. They are different. The strength of that handshake is very different. The one on the far right-hand side is firm. If you shake that person’s hand, you will be shaking it again consistently between now and the next 10 years. With the one in the middle, the ester, if you throw a little hot water on it, it will break. That will be a more sophisticated approach.
The take-home message is that we largely understand the chemical pollution problem. We are debating, and debate is good. In fact, the only way science moves forward is really through vigorous debate. However, we largely understand this problem. We are not arguing about how; we are arguing and debating about how much and the relative importance of different processes. We understand a lot. There are obvious steps to maybe not entirely solving it but certainly making it a lot better.
PFOS itself appears to be declining in remote environments three years after industry acted. That is a fabulously good-news story. I have the data on the next page. Chemists should be good enough chemical architects to design materials that provide desirable properties without adverse pollution problems. As a chair of chemistry at the University of Toronto, I know that in my soul, and I believe it to be true. I certainly believe it should be the goal.
Can we see progress? Here is the data that I find most interesting. If you look at the right-hand side, the seals in Resolute again, PFOS — that is, Scotchgard — peakedin 2000, and it dropped in 2004 and 2005. The year 2000 was the peak year for production by 3M of these materials. By the end of 2002, it was done. By 2001, we had a reduction of 80 to85 per cent.
Is there a connection? We believe the data suggests and is consistent with a connection between that production in the phase-out and what we see in a remote environment in a very short time period. Of the two hypotheses, the indirect route and the direct route, only the indirect route can explain that response, because it has a fast response aspect in it. The alcohols escape and take 10 days to fly to the Arctic. They degrade on their way and go into the superficial part of the Arctic where the food chain is most active, and they move up the food chain.
We were surprised at how fast we saw a reduction. If that is true, we do not understand as much about the Arctic biology as we thought, so there is probably good science to be done there as well. However, it is suggestive of a connection. If there is a connection, it says that either industrial action or regulatory action has the ability to quickly influence chemical pollution. The good-news story about that is that, although the public is tired of this subject and will read over stories about another chemical pollutant that we will be reading about for decades, I believe this one has potential because of industry, scientists and regulators responding with actions that we would like
Finally, who does the actual work? I do lots of talking; they do all the work. Graduate students, post-doctorates, the ones in blue, are the ones with the data I talked about. As to funding, NSERC has been our major funder. We have had some industry funding as well. Our collaborators include Derek Muir and Brian Scott from Environment Canada, academics from Guelph, and industrial scientists. We do all our atmospheric work at the Ford Motor Company and it has been a very nice collaboration…..
We have been joined by Senator Sibbeston, who represents the Northwest Territories and therefore has a particular interest in the Arctic aspect of what you are talking about, and by Senator Milne, who was attending a caucus meeting of the environment committee.
Does the timeline during which these things last argue against the direct route in that they would go away too fast for the direct route to happen?
You said that there was stuff in here that serves no real function in the consumer products it is in. Why is it there?
That is because of synthesis. When you make the polymers to put on the carpet, it is not a 100 per cent efficient reaction. Some in industry did not believe that they had unreacted starting material in their products until we measured and said that there was. I would guess that it costs money to take it out. It would certainly cost me money to purify a product. We purify things when we have to and do not purify things when we do not have to when we are doing our own chemistry.
Prior to when this unreactive starting material was recently identified as a potential significant source of emissions in the environment, no one paid any attention to it. It is now recognized. In the agreement between EPA and the major manufacturers of fluorotelomer, they have agreed to remove, by 2010, 90 per cent of these residuals from materials and, by 2015, essentially all residual precursors from the materials. We are moving in the right direction.
A major company announced on their website the day before yesterday that they have done most of that already. Clearly it was possible. Clearly it was simply an engineering problem and an effort problem.
So the material that is there that does not serve a function is incidental?
Yes. It is left over, if you will.
Have the companies that have done these good things done so out of the goodness of their hearts or out of coercion, or a combination of the above?
I can talk more knowledgeably about 3M, because the public record is clear. There was an invention by John Fenn in about 1987 for which he won the Nobel Prize a couple of years ago. It is called electrospray and is a measurement technique. You could not buy an instrument that utilized electrospray until about 1992. By 1993-94, the chairmanof 3M said that they thought PFOS was out of the environment, because this new instrument allowed them to measure it for the first time. They did not know how it got there or what it meant, but they were going to study the problem.
3M spent a lot of money and engaged the best scientists in the world throughout the 1990s to figure out whether it was really out there. They did not learn how it got there until we figured it out.
However, by May 16, 2000, they knew that everywhere in the world that a sample was taken there was Scotchgard — PFOS. They knew that in every human blood sample they tested anywhere in the world they would find PFOS. They also had some toxicological evidence that suggested it may be problematic, at least at high doses.
That is what it took for them to say, “We are done. As of May 16, 2000, we are not going to make it anymore.” It was a half-billion-dollar-a-year market for them, in Canadian dollars.
EPA knew little about that prior to about a year before that announcement. Most regulators had no idea that these compounds were in the environment, mostly because we did not have the measurement tools to be able to detect them. It was a bit of a surprise. I do not think it should have been a surprise, but it was.
I give 3M a lot of credit for being proactive. Perhaps they could have gone a bit sooner, but let us be realistic, they are making a lot of money. At the end of the day, it is very different than what the flame retardant industry has done, for example, which is a much different business model.
The telomer manufacturers have been active since 2001-02 in the context of study. The regulators of the world woke up. I mean that positively in that they had information that they needed to work on — Environment Canada, the Europeans, EPA, et cetera. They have been much more attentive, so there has been much more regulatory influence. Industry is not doing anything now that regulators have not thought about and are not already encouraging. It is harder to parse out what is goodwill initiative and what is simply seeing the regulatory landscape. It is harder for me to answer that question. As I understand it, 3M was operating in a vacuum for most of the time with little regulatory input.
In any event, they did the right thing, which others frequently do not. I hope they get a medal.
On the same topic, when the factory that used to dump 58,000 pounds of this stopped doing so, did they go out of business? Was it the end for them?
No, not at all. They simply stopped. They found a way to not release it.
An example of what you said is that chemists can, given the challenge, find a way to make this work without putting the bad things in.
I believe so.
I will continue on with the 3M company. There must be other companies looking at ways and means of trying to eliminate Teflon and these other substances. Is that so?
The major manufacturers are under agreement with EPA now to reduce the residuals and reduce the release of these chemicals. Two days ago, DuPont announced on its website that it has essentially achieved what it had to do
only by 2010.
The whole landscape of manufacturers has changed dramatically. Everyone is looking for alternatives. They are looking to clean up their own act. That is all good.
There is an effort amongst some industry groups to say that what they are doing now does not matter. We are not debating the mechanisms any longer; we are debating how much. A few companies argue that it is a legacy problem, that the contamination of the Arctic actually occurred back in he 1990s and that it is not happening any more. That is the difference between a legacy direct route and the indirect route that continues. That is just a delaying tactic in some ways. These are the companies that are trying to find solutions. To remain competitive in this market, you must be nimble. I have seen dramatic changes. With regard to residuals, there are companies that said that there are no residuals in their materials. My response is that they did not look, because they are there. We are not 100 per cent efficient. No chemist is.
For example, 3M in its public submissions to EPA in1999-2000, when these issues began to come out, admitted that they have 1 per cent to 3 per cent by-product — these original incidental materials — in their materials. Some of the other manufacturers said that they have 0 per cent. That was not true. Everybody now realizes that. It is the case that all the companies are pulling in the right direction in that regard.
When do you think this started? You say you have seen dramatic change. How long has it been since you have seen this change?
2004 was the first field data in which we observed a change in a sample in a remote region, in seals. It was not necessarily something we expected. If we had hypothesized, we would have thought it would take a decade or so before starting to go over the hump. We were surprised at how fast it happened.
We have a paper, which I am reviewing while I am here, measuring air samples in Toronto of these precursorssince 2002. We also measured them in 2001. We measured higher concentrations in 2001 than in 2002. We thought it was pretty fast. When 3M stopped making the stuff, less of the alcohols, which are very volatile, are getting away. That does not say they are not still being released. It started up high, it dropped, and stabilized at a relatively low level. These compounds are still in use. Just because 3M stopped making them did not mean everyone tore up their carpets.
We find that the ones on paper products dropped faster because, of course, those products have a smaller lifetime in the marketplace than do carpets and fabric. It is an explanation for the observation, but it is hard to prove that connection.
I am pleased to hear you say the PFOAs already appear to be declining in remote environments three years after industry acted.
In your view, is the federal government using CEPA1999 effectively to begin addressing the many PFCs on the domestic substances list and in use today in our country?
Yes. I am not an expert on CEPA or regulatory matters. I am a scientist, but here is what I know. EPA is one of the world’s regulators. I have been to EPA several times and have been asked to give a talk and provide feedback. I read what they are doing. I have been to the OECD and talked to the Europeans. None of them is able to move as quickly and as nimbly as Environment Canada. CEPA has allowed them to recognize the problem and to incorporate the latest research into it. They tell me they are more constrained in what they can do. They are still focused on PFOA, despite the fact that in your blood PFOA is 8 carbon acid; there is 9, 11, 12 and 13 there. They are not able to address those, apparently. I think it is more toxicologically interesting, because we know little about those higher chains. They have not been able to move quickly on the precursor idea.
Environment Canada in the context of one of their major actions was to preclude the importation of four fluorinated polymers. The evidence suggests there is a link between these fluorinated polymers and either residuals or degradation of the polymers themselves, releasing alcohols that as precursors degrade into the acids that contaminate remote environments. It is the only explanation in my mind that will explain the long chain acids in polar bears.
Humans are heavily contaminated with 8 carbon. Polar bears and seals are most contaminated with the much- longer 11, 12 and 13 chain acids. We can draw a consistent connection between fluorinated polymers and those long chain acids. It is not definitive, because as I said before you cannot prove it, but the evidence is consistent with that connection. The fact that they can move on that suggests a nimbleness and an ability to act very quickly in the public’s interest. The public interest, as defined by, from my view, a contaminated environment and contaminated humans clearly is connected to these fluorinated materials.
Is it a legacy problem or ongoing problem? They have been acting prudently in that regard. From what I understand about CEPA, from my vantage point, they have been able to act appropriately. I put an emphasis on that.
This has taken me back to my days in the chemistry laboratory at the University of Guelph. That was a long time ago.
I find it very difficult to think that if a chemist can make these long chain molecules, alcohols, they could not immediately test for them. How do they know they had them if they could not test for them?
Certainly, there is one way of testing in a laboratory when you have a gallon of this stuff. I should point out that we measure tens to hundreds of picograms in a metre cubed of air. You go from grams to milligrams to micrograms to nanograms to picograms. Each one of those is ten to the third. It would be three cubic metres of air. There would be 300 picograms in there. That is a really low thing. It took us a good six months to figure out how to do it at those low levels, how to capture them, because they are so volatile.
In the normal air sampling that goes on by Environment Canada and EPA, there are huge efforts in taking air samples every 12 days all around the Great Lakes. Those samplers would not have captured these compounds. They are so volatile they go right through.
Intellectually, this has been intriguing because these are huge molecules, yet have small personalities. One would think that because they are very large they must have vapour pressures along the lines of some of the PCBs so if we look for them here we should see them. However, they did not find them there because they are so volatile they went right through the sampler. They were never trapped.
We had to develop a trapping method and analytical methods. Think of a gas chromatograph in the Olympics, testing for illicit, performance-enhancing drugs. A gas chromatograph is one of those things. We put these molecules through the gas chromatograph and never saw anything come out the other end. We thought they must be stuck inside the machines so we kept raising the temperatures. We raised it some more. It turns out that even at the starting temperature they were going through so fast they were being missed. It was a systematic bias. For some of the chemicals we measure, we must cool down the gas chromatograph to minus 40 Celsius to start. No one has done that before for chemicals that weigh such as these. People who deal with big molecules do not expect them to be so volatile; people who deal with small molecules never expect something so big to be in the same mixture. We have learned a lot.
In 1968, a dental professor in Rochester was interested in fluoridation of water. He wondered if there were any organofluorine compounds — that is, F minus connected to a carbon compound — in humans, and he started testing human blood. He did it in a gross fashion. He took the blood, measured fluoride, and then burned it at 3,200 degrees Fahrenheit, and then measured the fluoride again. He said that the difference must be organically bound fluorine. In every human blood sample he tested, he said there was organofluorine. It turns out there was not a connection to fluorinated water at all; that reaction does not occur.
In the late 1960s, in a publication of the best journal of time, nature and science, he said humans that humans have organofluorines in their blood. The lack of technology did not allow us to measure that until the early 1990s, simply because we were not smart enough to be able to analyze, with precision and accuracy, the identity of those molecules. We were not smart enough early enough.
How easy would it be for industry to follow 3M’s example or to start by removing the residuals? Is that an expensive process or an easy process?
The record indicates that all the world’s manufacturers of these materials agreed to remove about 90 or 95 per cent by 2010. I do not believe they would have agreed unless they could do it. The fact that DuPont announced two days ago, on their website, that they have essentially done it already tells me that it was certainly doable. I do not know that their products cost any more than they did before removing the residuals. I am not privy to the costing of industrial mediums like that, but it does not seem to have any negative impact on their ability to continue to produce materials. The evidence suggests that it was not as hard as it was suggested it would be.
DuPont is already following 3M?
That is a different thing, because 3M ceased production of an eight-carbon compound and about four years ago brought out a four-carbon compound. In their announcement two days ago, DuPont said, “We have done what we were to do by 2010 already.” They have removed the vast majority of residual by-products of unintended materials in there. Reading between the lines, it seems they have alternatives so that they no longer will be in the long- chain business. I am trying to read between the lines. It would have been inconceivable to me that the largest company in the world, certainly the company with the longest experience with fluorinated compounds in general, did not already have an active alternative research market.
Bruce Smart, one of the smartest people at DuPont, was quoted in Chemical & Engineering News, C&EN, a trade magazine, saying that alternatives were possible, and that was three years ago. I took that as an indication that they are clearly working on alternatives.
DuPont is a company that ultimately did the most to solve the ozone depletion problem by coming out with alternatives that allowed us to replace freons. Up to that point, industry was saying that it would be difficult. One day, however, it was no longer difficult. That is industrial news.
On sheer speculation, do you suspect these long-chain alcohols may be responsible for what they now call the 21st century disease, where people cannot go out of their house because they are allergic to everything around them? That is, the house must be made of wood and all natural materials, and so on.
I have no idea. I doubt seriously that these are connected to those. Although the concentrations are substantial, they pale in comparison to exposure to other things. I do not know what to make of that.
I find what you said about CEPA to be encouraging and that some of these companies in the United States, namely DuPont and 3M, in spite of the fact that the EPA is lagging on this, are voluntarily doing this sort of thing. That is very encouraging.
I was suggesting EPA is not as nimble and free to follow all the research and evidence as Environment Canada is. They have still been doing good things. They took the approach that there are individuals within EPA that believe these residuals are important; we need to address those. It was a voluntary action, so it does not require regulatory sorts of things.
There is much litigation in and around that West Virginia plant, for example, because a lot of people in that area have a lot of PFOA in their blood — higher than anywhere else. This is the United States we are talking about, so there is a lot of litigation underlying all of that. I cannot remotely parse what all that means. I think there are positive indications all around.
We are now looking at CEPA and what we can do to make it more effective. You say it is working well in this area. Do you have any suggestions to give them even more flexibility and nimbleness?
There is nothing obvious. I have not parsed the act itself, but Canada is getting a lot of good press. Looking at all the thousands of chemicals and prioritizing what needs to be studied and regulated is a huge plus. Europe and the United States are trying to do that. Europe is a far more bureaucratic entity than Canada; they are way behind in prioritizing what chemicals to look at.
When I go to meetings, people say Canada is way ahead of the game on these things. In my view, regulators in Canada have the tools they need to do the job they do. The challenge comes more with some of our technologies that are not as up to speed as they could have been. It took really clever people to discover a method to detect these compounds with the confidence we need to have.
Some of them are just endemic problems that we must overcome. Nothing comes to mind to change the act that would give regulators extra powers. In my view, they seem to have the tools they need to get a good job done.
I am realistic about how fast government entities move on things and my view is they move quite nimbly.
I take it you do studies just out of scientific interest. That is, there is nothing compelling you to do that. Is the federal government doing similar studies in the North?
All of my northern work has been funded by Canada through the various funding agencies that getus up North. Each trip up to the North costs approximately $30,000. My operating grant is $42,000; you cannot do it on that. They have all been in collaboration with Environment Canada scientists, one of whom was here last week. He is a co-supervisor with most of the students I send up there. We are interested in the Arctic by a scientifically driven interest.
The cold condensation hypothesis on why the Arctic is so contaminated with chemicals is that vapour pressure varies with temperature. In the chemistry lab, if you want to get solvent off and concentrate a chemical, you would put it in a round-bottom flask, with lots of solvent, and you would pull a vacuum on it and heat it up in a hot water bath. You would not want it released into the room so you would trap it in a cold trap on the side. The globe works in the same way. Temperate regions are very warm, so chemicals there have higher vapour pressures that escape into the atmosphere. The Arctic is very cold and chemicals do not want to be in the lower vapour pressure so they condense. Thus, in the Arctic, the Inuit have a higher contamination of DDT in their adipose tissue than we in the South have. It is scientifically interesting because these chemicals tend to partition there, preferentially. The fact that the perfluorinated acids are in such a high concentration and that, in my view, they could not have gotten there by themselves as the final product, makes it an interesting scientific problem. We have a theory and we must test it. Therefore, we go to the Arctic to make the measurements that we have predicted because the only truly good science that can result is when you have predictable and testable theories. You have to be able to make a prediction so that you can test it to know whether it is valid.
There is a practical element to this as well. It is inappropriate for modern industrial society to contaminate remote parts of the globe that derive little or no benefit from those materials — and the Arctic fits that philosophical judgement perfectly. I live and work in Canada and the Canadian Arctic is becoming contaminated so it makes sense for us to do some work there.
In the North, studies have been completed on various contaminates such as mercury. In studying the perfluorinated chemical pollutants, are you discovering that there are more of them in the Arctic and the people there than there are in the South?
Certainly, there are more perfluorinated pollutants in northern mammals, such as polar bears and seals, than there are in similar animals in more southern areas. According to the Health Canada data that I have seen, humans in the North do not seem to be any more contaminated than they are in the South. However, the compounds are still up there and some of them seem to be on the order of the similar kind of contamination that we have here. That makes me wonder how that can be possible in the context of exposures. I would not have expected an equivalency kind of contamination in humans but, I understand, it is roughly the same.
As the North develops and materials, in particular rugs, and various foods from the South become more readily available, I suspect that the same kinds of pollution that we have in the South would become more apparent. While the sources of some pollutants are air and water, perhaps other contaminants come from those other materials.
You have captured perfectly what the evidence suggests and what I believe — that is, that humans are contaminated differently than polar bears are contaminated and the source of that is our consumer goods. The personality of these chemicals is such that, in the polar bear and in the seal, they do not reside in the fat and muscle. Rather, those chemicals reside in the blood, liver, spleen and other blood-rich areas, and humans eat very few of those elements. The contamination for animals lies in the fact that they eat many blood-rich portions, where humans tend to eat more of the uncontaminated portions of the animals. The source of much of the contamination is exactly as you have described it — our consumer materials. If they are consumer materials, then they are precursors, which means we have to make them in our bodies and, therefore, we have to go through the reactive intermediates that are on the pathway to the final material. That is why we are scientifically interested in that process and that pathway.
Based on mere curiosity and because I am not a scientist, I need to ask about these slides. You are putting pipes into the ice in order to collect evidence from various years. Does the pipe go down lower to go back in years?
We dug down 6.8 meters, which took us back to 1996. We cleaned off the side wall of the hole, drove down the stainless steel pipe, which has very low contamination potential, into the side of the hole, retrieved an ice sample and put the sample into bags and bottles that we knew were clean.
I should have a picture of the wall after the core-sample taking so that you could see the many holes all the way down, year by year by year. That allowed us to isolate 1998 ice and deposition. We bring that sample back to the lab, melt the ice, take the water, extract the compounds that we are looking at and, on a half-million-dollar instrument, we detect these compounds.
…The fact that today we can measure that in picograms per litre, pg/l, of water is amazing because we could not have done that five years ago.
It is only recently that we have been able to measure these substances. How much longer will it be before the toxicology studies tell us whether the amounts found in humans is dangerous for our health?
I do not know.
I cannot predict success in toxicology studies because it is simply too difficult. I can say that 3M was being a smart company when, on May 16, 2000, it said that the chemical is everywhere, that it does not degrade; some studies on rats and monkeys were making the company uncomfortable, and they were quitting. A company does not quit a product line of that magnitude without severe risk benefit to its bottom line.
My view is that whether current concentrations of long-chain acids in human blood will be shown to be significant in compromising human health is beside the point. Nobody wants these things in their blood in those kinds of concentrations and, in my view, they should not have to be there.
I do not know if toxicology will drive that ultimately. Studies are being done, but, ultimately, it will be driven by a cost-benefit analysis and companies determining that they cannot have their material showing up in humans. We will never know with enough certainty because it is not like global warming.
I have another clarification because I missed the first part of your presentation. I am looking at your bar chart that shows the flux in how much is delivered to the Arctic. Is that measured in nanograms, ng, per square metre?
Yes. People can visualize square centimetres and the flux at the bottom right-hand side indicates how much we did in the Canadian Arctic per year. Essentially, 500 kilograms per year is not a great deal, but it seems enough to cause contamination.
It causes bioaccumulation in some species.
Yes. The alternative theory of a direct route, the one I spoke to before, suggests that eventually, if not already, there will be many thousands of kilograms per year making it into the Arctic, which is more than 10 times 500 kilograms. That is a scary thought. I do not know whether that will happen, but it is predicted. That is why some of the temporal studies need to be done.
We have seen PFOS plummet. The models suggest that the direct route will deliver these materials there over the next few decades and that they should rise again. I do not know if that is the case; I hope it is not, but it might be.
That comes back to Senator Sibbeston’s question and the fact that we were told earlier that the levels in humans in the Arctic are really no different than the levels in humans in southern Ontario.
I think they are more similar than dissimilar. I do not think any of that is published yet, but I have seen it in presentations at meetings.
When you dig down 6.8 metres, you can see the strata and it clearly identifies —
Yes. We use a number of ways to figure out what year we are talking about. One, you can see the strata, because the ice is different in the different times of the year when it is deposited; it will look different whether it is cold or warm.
We back that obviously subjective observation up with ion analysis. We can measure the chloride and sulphate ions and those change over the course of a year depending on what kind of deposition it is — summertime versus wintertime. You will get peaks during the summertime and they drop in the winter.
We overlay those to have confidence in placing the years on that particular sample. We rely on Fritz Koerner, one of the deans of glaciologists in Canada; he works for the Geological Survey of Canada. I think he is officially retired now, but you would not know that. He goes up every year and tromps all over the Arctic. He has been a huge help for us and that is who we rely on. He climbs down in the pit and says there is a year, and another one and another one. We test him by doing ion analysis and he is correct.
Glaciologists know wonderful things. I know you are a scientist and not a politician. One of the questions that we are addressing, in a large and general sense, is that we have no doubt the capacity exists within CEPA to do the things that ought to be done; in that regard, should CEPA be more prescriptive?
In other words, when it talks about things which the department “may” do, would it be more efficacious — in terms of removing things that we do not want to have in our blood, or in the air and water — to say that there are triggers in the event of which the government “shall” do something? That is an oversimplified explanation, but this is apropos the question you were asked earlier by Senator Milne about the present state of CEPA.
One of the reasons that we ask that question is that, despite all we know, the list of chemicals that have been flat-out banned under CEPA consists of exactly one out of the 27,000 that have been identified on the priority list that you are talking about. Some part of that surely derives from the fact of wait until we know what the truth is, until we have better evidence and until we are able to test the theories. Our concern is that some of it might also come out of other impediments to action.
Do you have an opinion in that respect?
People have been suggesting I have opinions about lots of things, so yes, I probably have an opinion.
Responding to the word “prescriptive,” I think it would be ill-advised to be prescriptive around targeting certain chemicals, because you cannot anticipate problems you do not know about now. It is like trying to prescribe to Canadian scientists that they should work on a certain problem. That has never proven to be a wise decision. Scientists are best left to follow what they believe in their own creative minds and ambitions are the most important problems. No government, no politician can anticipate better than the people on the ground what is important to work on.
That is one view.
Correct. John Polanyi is in my department, so I get a certain view on that.
From the perspective of being prescriptive in the context of what kinds of properties or presence of chemicals are in humans, for example, I think the public does not have the time or willingness to parse, “Well, it is there, but it is not a problem.” How do you know it is not a problem? I do not think the public wants these chemicals in their blood at certain concentrations. The problem is you have to define “concentration.” I do not care how low it is, some chemist someplace can measure it down to a molecule.
We get better at it.
Yes. Single molecule detection is possible now in very constrained, specific kinds of situations. That are many tens of tens lower than what we are measuring now. We do not want to say it is not detectible, because that is purely a charge to chemists to move the detection limits.
However, I do think the public wants a more proactive stance. We do not want these things in our blood or our bodies — this is me talking, Scott Mabury, a citizen. I think the public does not want substantial concentrations in their bodies, so you have to define “substantial.” You cannot say “detectible,” because it is just a challenge to move the detection limits lower.
Basically, if it is in commerce, you will probably find it in everyone’s bodies someplace if you want to look hard enough. Does it mean anything? No. That is the problem. Where does the literally meaningless move into the “Well, we do not know”? Somewhere in there is a level that I think would serve the public and would not overly constrain industry.
Not just talking about industry, in the natural products world, there are more natural products in your body than there probably are industrial compounds; it just depends on what we choose to look for. We tend to look for industrial compounds because that is what gets press and publications.
As I said before, Mother Nature puts out about 10 times as many organic compounds in the atmosphere as humans do; it is almost exactly 10 times. We cannot lose sight of that.
Humans have survived, though, and increased in number.
I am wishy-washy on that response, but I do think that there should be some sort of triggers. A look at all the hundreds of thousands of chemicals, winding them down on certain properties — a certain amount of persistence, bioaccumulation potential and somewhere the potential for toxicity — is a prudent course of action, because it is not the specific chemical but the personality of the chemical that drives those properties. It is the properties and triggers on those properties — the lifetime, for example — that will trigger regulatory interest. I think that is appropriate.
I have two final questions. As regards the possibility of toxicity and the extent of the toxicity, do you agree that the precautionary principle is a wise one to apply? For decades, and presently, that has been the policy of the government as regards most things.
Second, CEPA sees, or at least contemplates, a resolution of some of the problems that it addresses in the phrase “virtual elimination.” However, as you have just discussed, what was virtual elimination 10 years ago is not what it is today, simply because we can detect smaller and smaller concentrations. Therefore, it is a moving target. Could you talk about those two things?
I will deal with the second part first. You will have to grapple with defining that term. The current concentrations of PFOA in your blood would not have been measurable 10 years. Therefore, they would have been virtually eliminated. Now they are driving substantial litigation and regulatory interest worldwide because of our ability to detect them. Certainly, we recognize they are there now. You have to grapple with what does that actually mean in a quantitative manner.
Of course, the precautionary principle is an appropriate, commonsensical approach. It only disturbs me when it is used to almost celebrate ignorance about things. I do not know that there is any problem left about which you could say we know nothing about. That is simply ignorance on the part of the speaker in the context that they do not know the literature. In the vast expanse of human inquiry, scientific or otherwise, curiosity driven or otherwise, I believe people have been looking at most problems and can say lots of intelligent things about them. It is when I hear an oversimplification of what that means I am reminded we actually do know a lot.
I hope the 165 kids coming out of my third-year environmental chemistry class have the expertise to be able to say intelligent things about any chemical structure I put in front of them. They can tell you roughly how long a chemical will last in the environment and in what sphere — whether it will be in the atmosphere, the lithosphere, the hydrosphere or the biosphere. I expect them to be able to make reasonable, accurate predictions about whether the chemical will be toxic or not, and that is without ever having seen the structure or know whether it is even real. Therefore, in the context of the precautionary principle of an intelligent assessment of that, I am very supportive of it.
Mr. Claude Duplain (Portneuf, Lib.):
Mr. Speaker, I would like to extend my congratulations today to Alcoa Canada Primary Metals, and in particular its Deschambault smelter, a major economic engine in the riding of Portneuf.
This evening, the Canadian Council of Ministers of the Environment will award the Pollution Prevention Award in the large company category to Alcoa Deschambault. It will join the illustrious ranks of former winners such as Novapharm and IBM Canada.
The Deschambault team of 570 employees contributes, along with Quebec’s other aluminum smelters, to the economic spin-offs of over one billion dollars annually in Quebec.
I would like to pay particular tribute to the initiative of the workers of this company for recognizing the importance of taking care of the environment and for taking an active role in a project to reduce fluoride emissions. They are with us in the House today to hear my congratulations….