On August 9, 2024, Health Canada updated its Objective for Canadian Drinking Water Quality for per- and polyfluoroalkyl substances (PFAS). Due to growing concerns and new data on the health risks posed by these “forever chemicals”, Health Canada accelerated the release of an interim objective to mitigate PFAS exposure in drinking water. This updated Objective is an interim solution that will remain in place until final revised guidelines are published, which will take “many years to finalize”.
The updated Objective sets a “precautionary group-based” threshold of 30 nanograms per litre (ng/L) for the sum of 25 specific PFAS, replacing previous drinking water guidelines that set screening values for only 9 individual PFAS. The Objective states that PFAS concentrations in drinking water should be maintained “as low as reasonably achievable”. Although the Objective is an unenforceable national benchmark, Health Canada encourages all jurisdictions to strive towards it.
The Objective recommends that utilities should characterize their source water to assess PFAS concentrations, particularly if source waters are impacted by firefighting training areas, military bases, airports, manufacturing sites and/or waste disposal sites. If PFAS is detected in treated drinking water, the summed value of the 25 PFAS should not exceed 30 ng/L. If treatment is required, the source should be sampled in conjunction with compliance monitoring.
In cases where PFAS levels exceed the Objective of 30 ng/L, Health Canada recommends that responsible jurisdictions should engage in a collaborative process with stakeholders to assess and manage the risks. Corrective actions could include but are not limited to: resampling, assessing the profile of the PFAS detected, protecting or changing source waters, and evaluating water treatment strategies such as selecting or combining different treatment technologies based on water quality and resampling results.
Brief Comparison to U.S. PFAS Regulation
Canada’s approach contrasts with the U.S. Environmental Protection Agency (EPA), which in April 2024 designated two widely used PFAS–PFOA and PFOS–as “hazardous substances” under the Comprehensive Environmental Response, Compensation, and Liability Act. The EPA also set legally enforceable Maximum Contaminant Levels for six specific PFAS in drinking water under its final National Primary Drinking Water Regulation.
While U.S. regulations apply to fewer PFAS, they carry legal weight, unlike Health Canada’s broader but voluntary and aspirational Objective. Ultimately, Health Canada’s update is an important measure for intervening protection against PFAS exposure while more comprehensive guidelines are finalized in the coming years.
This blog post was written by Michael Hebert and Nathan Adams (primary author), members of the Mann Lawyers Environmental Law Group. Michael can be reached at 613-369-0360 or at michael.hebert@mannlawyers.com and Nathan at 613-369-0380 or at nathan.adams@mannlawyers.com.
