Cosmetics Alliance just became aware of an Information request from the Consumer & Hazardous Safety Directorate (CHPSD) regarding polyfluoroalkyl substances (PFAS) in cosmetics based on the study Fluorinated Compounds in North American Cosmetics, published in June 2021 in Environmental Science & Technology Letters. We understand only stakeholders who’s products are mentioned in the report have been contacted. This is the study that we previously circulated to our members, when several news outlets in both Canada and the United States took up the story on these developments. Recall, at the time, we indicated that in Canada, PFAS is a large grouping of chemicals that is currently under assessment under the Canadian Chemicals Management Program (CMP) and that the Government of Canada has outlined a 2 year action plan, as published in April 2021; outlining a comprehensive approach to the review and assessment of this large class of chemicals. At the time, we urged (and we continue to urge) officials to proceed with the plan, including early engagement with stakeholders to define scope and direction of any corresponding activities.
In this regard, we are aware of on-going information initiatives that ECCC and HC were contemplating to initiate such information gathering activities. Further to discussions over the past couple of weeks with CHPSD, Cosmetics Alliance was under the impression that this survey was under development; however, we were unaware of their intent to formally start to socialize this information request so imminently. In fact, we were still awaiting on direction from CHPSD as to their next steps; hence we were very surprised to learn that this information request was formally circulated to stakeholders earlier today.
Regretfully, the wording (and associated timelines for response) for this request leaves the net impression of the need for potential urgent compliance action. This is not in line with the spirit of the information request that we have been discussing with officials. Correspondingly, we have reached out urgently to senior officials at CHPSD to get some clarity as to the scope and intent of this request, along with clarifications as to why this appears to take on a compliance and enforcement tone, when to our understanding, this was intended to be a cooperative information gathering exercise to help inform next steps in the 2 year plan, as referenced above.
RECOMMENDATIONS FOR ENGAGEMENT:
If you have received this information request, we would recommend that you:
- Confirm receipt with CHPSD; however,
- Indicate that you are a member of Cosmetics Alliance and are aware of on-going follow-up discussion between Cosmetics Alliance and CHPSD to clarify scope and intent of the request; and
- Confirm your interest in following up with the survey; however, indicate that you will need more time to respond to the request, as you await on clarifications from the follow-up discussions being pursued by Cosmetics Alliance
Once Cosmetics Alliance gets clarity on this request we will notify membership on how we would recommend our membership proceed with the information request, along with any corresponding follow-up communique stakeholders could expect directly from Health Canada.
As you are no doubt aware, PFAS is an emerging area of concern not just in Canada and the US, but across the world. We are presently engaged in global collaborative dialogues with industry partners around the world, to discuss the most effective strategy to support risk assessment/management activities related to this very broad subset of chemicals. Fundamentally, the key interest is to try to focus efforts on only those PFAS materials that present a true risk, and to avoid a broad generic sweeping of risk mitigation approach that is not underpinned by science.
Thank you to all those who quickly made us aware of these developments. It was through this fast action that we were able to pursue such rapid intervention with officials.
Stay tuned, as there will be lots of activity in this space, over the next few years.
