Translating science into policy

Persistent

The EEA’s main cause for concern is the extreme persistence of single PFAS chemicals or any of their degradation products. This causes these chemicals to accumulate in humans, other living organisms and the environment. This means that more substances are added than removed, and that the PFAS will ultimately reach levels at which they pose risks. The risk of health effects is determined by the toxicity of a chemical and the likelihood of exposure to it. That likelihood increases as more of a chemical is released into the environment and humans face greater exposure to PFAS from consumer products. The majority of substances investigated are toxic to some extent – to humans or the environment or the earth’s systems, such as greenhouse gases.

PFAS pollution is very high around factories that produce PFAS or use them as part of the manufacturing processes, and also at locations where PFAS directly end up in the environment, as is the case with fire-fighting foam or polluted fertiliser. In these environments, humans can be exposed to high concentrations of PFAS. 

Convenience over sustainability

As a society, we have put convenience before sustainability for a very long time. We began to consume more and more, without paying enough attention to the cost. Now it is becoming apparent how this affects the environment.

It is like running a bath. If the inflow of water is greater than the outflow, the bath will eventually overflow. Various PFAS have already filled most of our metaphorical bath. We are at a point where the bath will overflow and the toll will become visible. This is happening in particular in regions with a large number of polluted sites. Here, blood levels of PFAS are so high that residents are experiencing health effects. This is true for sites in countries including Belgium, Denmark, Italy and Germany. 

A different way is possible

If we wish to avoid these effects for our society, we must switch to the manufacture of products that have a lower environmental impact. In this regard, it is essential that we consider both the risk of exposure during use and the emissions during the lifecycle of PFAS. This is a challenge because the number of permitted uses of PFAS is high. Some of these are crucial to health, safety or the functioning of society. Rather than simply discontinuing those applications, a wiser approach would be to permit them until an alternative has been found. PFAS-free alternatives are already available for a significant number of uses, including waterproof clothing, food packaging materials and cosmetics. A lack of alternatives means there is scope for innovation. I have every confidence that by searching hard enough we will find equivalent alternatives.  

There is a nice example of this in relation to packaging materials. A manufacturer who did not want to sell microwave popcorn in packaging containing substances harmful to children adapted an existing material they could use instead. For a long time, it was believed that PFAS were indispensable in fire-fighting foam. Yet alternatives have now been found and tested. There are even some firefighters who claim that foam actually works better without PFAS. In any event, the fact that they no longer face exposure to PFAS also promotes a feeling of safety. 

Practical and clearly defined limits

It is the hope of Member States and scientists working in this area that the ban will eliminate most of the production, processing and use of PFAS. In the meantime, it is important for us to ensure that the PFAS being banned are not substituted with other PFAS or chemicals that cause similar harm. This means we will need to focus more on testing the persistence and toxicity of chemicals before allowing them to be marketed.

In an ideal situation, this should also be done for small volumes of chemicals since these will also add to the mix of chemicals we are exposed to. The ban will cover products manufactured in Europa, as well as imported products. The introduction of practical guidelines and clearly defined limits that apply to enforcing agencies as well as manufacturers will be key to ensuring a level playing field. It will also be important to develop methods of enforcement and for commercial parties to have access to chemicals required for calibrating instrumentation. 

Is there still time to prevent global PFAS pollution?

Unfortunately, no. PFAS can already be found all around the globe, including in the Himalayas and on the South Pole. And although most developed countries have institutes capable of addressing or even removing PFAS, which is possible to some extent, many other countries do not. They lack the systems and institutes to protect their citizens and environment against pollution from PFAS, which is still ongoing. Examples include China and India, where many of the world’s PFAS are currently being manufactured. Another issue is that PFAS is not only found in many products but that they are also used in small quantities and those add up too. How, for example, are chemicals from lithium batteries recovered when they are reused? Even if the quantity used in each product is small, the PFAS from all of those products will add up. Once PFAS have caused pollution, it is often irreversible or impossible, for practical or cost reasons, to completely remove them from the environment.  

In comparison with other chemicals, we moved relatively quickly to bring in laws and regulations from the moment the concerns around PFAS received wide recognition. In some cases, manufacturers of PFAS have been aware of the harmful effects for decades. And they then failed to act or withheld this information from the authorities. But new PFAS are being introduced on to the market even now. For the vast majority of PFAS, the risks and the levels present in the environment or products have not been fully investigated yet. As part of the category-wide ban on PFAS, EU Member States are furthermore collaborating on precautionary measures for PFAS that we currently know little about. Legislating for entire groups or categories of substances is a comparatively new development now being applied by countries and the EU.

A lack of data no longer means no action will be taken. Simply because a lack of data does not mean to say there is no harm. We hope to accelerate legislative actions in order to prevent pollution from substances of concern whose intrinsic properties are likely indicators of harmfulness. This means it is not necessary to provide evidence for each substance individually. Although this group-based approach is unique, a number of states in the US have also shown interest.

What will the future look like?

The EEA notes that our world is changing rapidly and instability is on the rise. Climate change and political instability can lead to conflict. This increases the likelihood of incidents, for example as a result of extreme weather events, fire, floods or disruptions to the electricity supply. These may cause flooding of polluted sites, affect the treatment of wastewater or result in the release of toxic smoke. The melting of polar ice is also a contributing factor. It is becoming increasingly difficult to prevent the dispersal of PFAS. We will see an increase in these types of disasters. The global depletion of natural resources will furthermore require us to increase the reuse of these resources, including water. As long as we continue to add harmful chemicals to these resources, this will only increase their levels and human exposure to them. Given the state of our planet, it will be wiser to avoid toxic substances in products wherever possible. This is precisely what the Chemicals Strategy for Sustainability calls for and the Netherlands has taken a lead role in – driving the transition to safe and sustainable chemicals and products.