Wood UK E&IS
Liz is a Senior Consultant within the Wood UK Policy team and has over 5 years of chemical toxicity experience. She specialises in the sources, fate and effect of chemicals in the aquatic environment and has delivered projects for the UK Environment Agency, the European commission and ECHA. Liz has knowledge and expertise ranging from chemicals policy legislation such as REACH and the Stockholm Convention to wider chemicals risk management considerations including alternatives assessment. Liz is currently managing projects for ECHA and the European Commission which focus on the assessment of PFAS in fire-fighting foams and their use in textiles.
Emerging policy landscape concerning PFAS in the EU – example concerning their use in firefighting foams
Recent concern over regrettable substitutions of per- and polyfluoroalkyl substances (PFAS) highlights the importance of a systematic alternatives assessment and drives a need to rethink conventional substitution approaches. Ten years ago, a global restriction for perfluorooctane sulfonate (PFOS) was agreed under the Stockholm Convention on persistent organic pollutants and this was followed in 2019 with a ban on perflurooctanoic acid (PFOA) (with specific exemptions) due to risk posed to the environment. Now, evidence emerges that a similarly regrettable substitution of PFOA with perfluorohexane sulfonic acid (PFHxS) has occurred and as a result PFHxS is currently being recommended for listing under the Stockholm Convention. Thousands of additional PFAS substances are known to be in circulation, with current estimates by the OECD listing >4000 individual PFAS related substances, many of which display a similar chemical profile and could be considered as possible “drop in” replacements. However, very limited data on their toxicity and public health risk are available to assess each one in turn, single-chemical-by-single-chemical. Since the 1960s, one of the largest uses of PFAS has been within the manufacture and use of firefighting foams. PFOS/PFOA were extensively used in these products due to their thermal and chemical stability but a number of fluorine free alternative foams are now available and in use globally. Wood is currently undertaking work for the European Commission and the European Chemicals Agency to look at the use of PFAS in fire-fighting foams, to assess the possible fluorine-free alternatives and the socio-economic impacts of substitution. This presentation will give a comparison of policy approaches being explored in the EU regarding a grouping approach to PFAS regulation and the current US position on PFAS use in fire-fighting foams. Some regulators and NGOs support the idea of increased use of grouping to promote substitution to safer chemicals, however no formal conclusion has been reached on whether a collaborative approach to address chemicals by groups is an efficient or effective way to speed up the substance evaluation processes. Emphasis will be placed on the current data gaps that exist with PFAS (and their alternatives) that could be addressed through enhanced communication and research at the science-policy interface. Key gaps remain for PFAS regarding the body of data on exposure and toxicity of these chemicals, which need to be expanded for the purposes of future risk assessment. Building this research capacity and technical support to provide relevant data for an alternatives assessment will help inform policy decisions around the regulation of PFAS and work to avoid regrettable substitutions in the future.