According to TWI technology fellow Alan Taylor, who held a recent webinar about the current PFAS situation, some PFAS have long been known to be hazardous. In particular, UK REACH legislation bans PFOAs, and environmental regulation of ‘persistent organic pollutants’ restricts PFOS, PFHxS and eliminates PFOAs. The UK drinking water inspectorate guideline limits for PFAS compounds is 100ng/L, or 0.1ppb. He cites results of a UK research project as part of a risk management option analysis which confirmed the persistence of PFAS beyond UK REACH standards, but in many areas found more questions than answers. It found it impossible to reach a definitive conclusion about the human health and environmental effects of most PFAS. Nor was it clear that all PFAS degrade into harmful forms. For fluoropolymers in particular, data regarding harm is scarce.
Remediation is becoming one of the key challenges, Taylor reports, as once PFAS are in the natural environment, they are difficult to remove, and don’t break down, because of the strength of the carbon-fluorine molecular bond (see also diagram above from environmental charity Fidra about how PFAS spread and accumulate in the environment). In the US in particular, Taylor reports that product liability cases are on the rise. In June, 3M, which has included PFAS in firefighting foam, agreed to pay up to $10.5bn to 300 water authorities; Chemours, DuPont de Nemours and Corteva are to pay $1.19bn to settle claims of public water contamination at 300 water authorities.
In related news, 3M recently announced it will exit PFAS manufacture – including fluoropolymers, fluorinated fluids, and PFAS-based additive products -- by the end of 2025. It said that its decision is based on careful consideration and a thorough evaluation of the evolving external landscape, including multiple factors such as accelerating regulatory trends focused on reducing or eliminating the presence of PFAS in the environment and changing stakeholder expectations.
Elsewhere, Ricardo has developed what it claims is the world’s first tool to improve the assessment of chemical persistence in the environment. This software-based Persistence Assessment Tool is said to provide a structured and clear methodology to systematically capture and store information on persistence, evaluate data quality, conduct a robust and transparent weight of evidence determination and assess persistence in line with global regulatory frameworks.
Taylor points out that PFAS are diverse chemical compounds produced in hundreds of thousands of tonnes per year worldwide for many uses in sectors such as textiles, food contact materials, transport, construction products and electronics (see table, right).
And the landscape is shifting. A big driver of that shift is the European PFAS phase-out proposal, which is deliberately intended to cover all PFAS to prevent industry substituting one for another. (However, it does allow a five-year derogation for food contact materials and 12-year derogation for implantable medical devices). In detail, Denmark, Germany, the Netherlands, Norway, and Sweden have drawn up a proposal to restrict PFAS in Europe (currently more than 10,000 substances). The EU proposal sets out two options, explains Richard Luit, Policy Advisor at the Dutch National Institute for Public Health and the Environment (RIVM).
The first, he says, is “a full ban on PFASs which takes immediate effect after a transitional period of 18 months. This is standard and considered reasonable within REACH; it’s like selling out of stock.”
“Option two is a ban with use-specific derogations, which will be underpinned based on information from industry and other stakeholders. Option two will be based primarily on analysis of alternatives and the possibilities or impossibilities to transition within a certain timeframe and other socio-economic considerations. And we will have reasonable timeframes for switching to alternatives.”
After the end of a six-month consultation process in September 2023, a final decision is expected to come into force in 2025 and the restriction is expected to come into force in either 2026 or 2027.
DISAGREEMENTS
An important disagreement is whether fluoropolymers should even be included within the definition of PFAS. (A prominent example is PTFE, also known as Teflon). Taylor quotes a 2020 paper from the point of view of environmental groups and regulators: “A variety of PFAS, including monomers and oligomers, are emitted during the production, processing, use, and end-of-life treatment of fluoropolymers. There are concerns regarding the safe disposal of fluoropolymers and their associated products and articles at the end of their life cycle. Fluoropolymers’ extreme persistence; emissions associated with their production, use, and disposal; and a high likelihood for human exposure to PFAS.”
On the other hand, a 2023 research paper cited by Taylor indicates an opposing position taken by industry: “Fluoropolymers have documented safety profiles; are thermally, biologically, and chemically stable, negligibly soluble in water, non-mobile, non-bioavailable, non-bioaccumulative, and non-toxic. Fluoropolymers are a distinct and different group of PFAS and should not be grouped with other PFAS for hazard assessment or regulatory purposes. Fluoroplastics and fluoroelastomers satisfy the widely accepted polymer hazard assessment criteria to be considered polymers of low concern.”
Whatever their opinion, manufacturers should identify the use of PFAS in their products, processes and supply chain, and if so consider substitutions, according to Taylor. In some areas, such as food packaging (pictured, top), industry has been championing moving away from PFAS products, he says. But others, such as the textile industry, are struggling to find suitable substitutes. Gore-Tex is a prominent PFAS example.
Trelleborg, a manufacturer of seals and gaskets, predicts that the current transition from PFAS-based compounds to viable engineered alternatives and the development of new bio-based and regenerated materials to support demanding industry applications will reshape industry. The company recently hosted a webinar that highlighted alternative materials and applications.
Meanwhile, Wayne Rose (pictured) of the marketing commission Secretariat of trade association Europump, and newly-appointed CEO of the BPMA, states the pump sector’s resistance to banning PFAS, which are used as seals, bearings, cable sheaths, coatings, pump inserts and membranes.
He says: “In certain pump (and other related product) applications the use of PFAS remains essential, due to safety, efficiency, and functionality concerns. And given that no suitable substitutes for these specific applications are currently available, the use of PFAS materials should remain possible, so that pollution of the environment by other acutely hazardous substances can be prevented, and any harm to humans avoided.”
BOX: TAKING ACTION
Ricardo’s National Chemical Emergency Centre (NCEC) recommends simple steps for those using PFAS to prepare for future rules. These include:
- Identify all PFAS in the portfolio and supply chain
- Consider the functionality of those PFAS and, through supply chain communication, begin to seek alternative substances or product redesign options that would support the phase out of PFAS
- Explore innovative solutions and alternatives to the use of PFAS. Ask questions to your upstream suppliers to encourage innovation and a market for alternative chemistries
- Stay up to date with the developing regulatory landscape for PFAS and understand the implications for your substances and/or products
- Where appropriate, participate in consultations such as ECHA’s upcoming consultation on the proposed universal restriction of PFAS in the EU
- Seek expert help to remain ahead of the market and retain your market access.
