US AAFA submits comments to Canada on PFAS management
The American Apparel & Footwear Association (AAFA) recently requested Canadian Minister of Environment and Climate Change Terry Duguid to include an exemption for products that test below the 100 ppm total organic fluorine (TOF) threshold under prohibitions for intentionally-added per- and polyfluoroalkyl substances (PFAS) in textile products.
In California, Vermont and other US states, the intentional addition of PFAS in textile articles is regulated through a limit on TOF, which helps ensure a consistent and easily understood regulatory framework applied across textile products.
AAFA members have for several years now been diligently working to ensure products are below the established TOF threshold of 100 parts per million (ppm) currently in place in California.
US trade body AAFA has requested Canadian Minister of Environment and Climate Change Terry Duguid to include an exemption for products that test below the 100 ppm total organic fluorine threshold under prohibitions for intentionally-added PFAS in textile products. It also requested Canada to include an exemption from PFAS regulation for products made with at least 50-per cent recycled content.
While it is possible to manufacture new, general consumer products without intentionally adding PFAS, it is not possible for textile, apparel or footwear companies to completely eliminate trace contamination that can occur as part of production, AAFA noted.
AAFA also requested Canada to include an exemption from PFAS regulation for products made with at least 50-per cent recycled content. Such an exemption is absolutely necessary to enable the industry's transition to a more sustainable and circular sourcing and production, AAFA observed.
In a letter to the minister, it urged the Canadian regulatory authorities to consider worker safety when seeking to regulate PFAS and remove personal protective equipment (PPE) from the scope of the proposed Phase 2 prohibition of PFAS in textiles.
The requests were part of AAFA's feedback on Canada's 'risk management approach' for PFAS, excluding fluoropolymers, an AAFA release said.
Although the 'risk management approach' states that 'alternatives appear to be broadly available to impart waterproof properties to textiles, including in personal protective equipment', it is worth noting that the Washington State Department of Ecology last year declined to propose restrictions on PFAS in PPE because they were unable to identify safer alternatives, AAFA noted.
Similarly, California and other jurisdictions that have or are seeking to prohibit the use of intentionally added PFAS in products have created flat exemptions for PPE.
Maintaining an exemption for PPE creates regulatory harmonisation and consistency for manufacturers and PPE buyers, AAFA added.
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