Summary of public comments received on the Federal Environmental Quality Guidelines for perfluorooctane sulfonate
Comments on the Federal Environmental Quality Guidelines (FEQG) for Perfluorooctane Sulfonate (PFOS) to be addressed as part of the Chemicals Management Plan (CMP) were submitted by the Ontario Ministry of Environment and Energy, and the British Columbia Ministry of Environment and Climate Change.
| Topic | Summarized comment | Summarized response |
|---|---|---|
| Overarching comments | Federal Environmental Quality Guidelines (FEQG) for Perfluorooctoane Sulfonate (PFOS) would be useful and are welcomed. | Noted. |
| Overarching comments | The FEQGs are well done and followed the Canadian Council of Ministers of the Environment (CCME) protocols. | Noted. |
| Editorial changes | On the X axis of Figure 1, it is suggested that “higher” be changed to “high”. | No changes were made Figure 1 because it implies a relatively higher number of potentially affected taxa, rather than a specific high number of affected taxa. |
| Methodology | Species not found in Canada should be removed from the dataset. | Toxicity studies were conducted on a limited number of species. Additional species, including comparable foreign species that live in similar habitats, were used because they were found to strengthen the SSD dataset. |
| Methodology | Units are inconsistent across the different guidelines. For example, the Fish Tissue, the Wildlife Diet, and the Bird Egg FEQGs are reported, respectively, in mg/kg ww, ug/kg ww, and ug/g ww. Use similar metrics for the FEQGs where possible. | To avoid misinterpretations various metrics are required for the different FEQG mediums. Applying the same metric for all FEQGs could result in a high number of leading zeros before the first non-zero digit in a decimal and result in data interpretation errors. The units were not changed. |
| Methodology | Will these guidelines be validated with field data? | Yes. The FEQGs were used to interpret monitoring data in the Great Lakes and elsewhere in Canada. Results of this analysis are available online. |
| Methodology | Apply a maximum likelihood approach within the SSD method for guideline development rather than the non-linear least squares approach within the SSD method currently used in the development of this FEQG. | The non-linear least squares approach within the SSD method of guideline development will be retained for this FEQG. However, alternate approaches may be explored as appropriate when developing future guidelines. |