Five EU member states have finally formalized toECHA (European Chemical Agency) a proposal to revise REACH(Registration, Evaluation, and Authorisation of Chemical Substances) Regulation EC No 1907/2006 to restrict the use of about 10 thousand perfluoroalkyl substances (PFASs). And thus safeguard One Health (public health, animal health and welfare, environment) from forever chemicals.
Exposure to these toxic chemicals is indeed associated with endocrine disruption, increased risk of contracting certain types of cancer, gestational disease, and damage to the unborn child. And it is time to take action at the source of the problem, no longer limited to the bland measures taken so far to contain only the dietary exposures of European citizens to PFAS (1,2). But the European Commission is stalling, and the disaster continues.
1) Forever Chemicals. Foreword
ECHA (European Chemical Agency) has long made it clear that PFAS, toxic chemicals that do not occur naturally:
- contain some of the strongest chemical bonds in organic chemistry (carbon and fluorine),
- Are capable of polluting ecosystems even at long distances from the source of the release, and
- resist the processes of thermal degradation, biodegradation, hydrolysis, and metabolization. In addition to being highly soluble in water.
2) Toxicity, persistence, bioaccumulation
ISPRA (2019) lists PFOS and PFOA-the ultimate degradation products of most fluorinated compounds, in the PFAS family-as the most hazardous contaminants. (3) They are in fact identified as PBT(Persistent, Bioaccumulative and Toxic) substances, in Annex XVII to REACH(Registration, Evaluation, and Authorisation of Chemical Substances) Regulation EC No 1907/2006.
PFOA and PFOS have been associated with a number of serious public health risks, which are in addition to the toxicity of PFAS-even at low levels of exposure (4)-to the immune system:
- PFOA. Kidney and testicular tumors (see supra, Sec. 2.1), thyroid disease, ulcerative colitis, hypercholesterolemia and hypertension during gestation,
- PFOS and other PFAS. Reproductive and developmental diseases, liver, kidney and thyroid diseases (see supra, Sec. 2.2).
2.1) Cancer risk
IARC(International Agency for Research on Cancer), the lead agency of WHO(World Health Organization) has classified polytetrafluoroethylene PFOA, as ‘possibly associated with cancers of the kidney and testis‘ (Group 2b).
2.2) Bioaccumulation in blood and liver
The Italian National Institute for Environmental Protection and Research (ISPRA) also clarifies that ‘human exposure to PFAS is mainly due to ingestion of contaminated food or water.’
Several studies have also shown a rather long half-life of PFASs in human and animal organisms, where they accumulate mainly in the blood and liver.
‘May cause hepatotoxicity, immunotoxicity, neurotoxicity, hormonal changes in reproduction and development.’ (3)
2.3) Gestational diseases, malformations, genotoxicity
The ‘study on maternal and neonatal outcomes in relation to perfluoroalkyl substances (PFAS) contamination‘ – by the Birth Registry, Veneto Region Rare Disease Coordination – confirms the ‘international scientific literature related to PFAS‘ in reporting on the increase of:
- pre-eclampsia (or gestosis, a complication that can develop during pregnancy),
- Gestational diabetes, with ‘clear gradient of risk that gradually decreases moving away from the red area‘ (for PFAS pollution levels)
- born with very low birth weight andSGA (Small for Gestational Age) births,
- ‘some major malformations, including abnormalities of the nervous system, circulatory system, and chromosomal abnormalities.’
3) Serious public health risks, poor protections in EU
The serious public health risks associated with PFAS exposure continue to receive little attention from the European Commission. Some ‘guidance’ hints in the
Waters Directive
, recent Brussels ‘recommendations’ on these and other contaminants, only most recently the maximum limits on some animal products (1,2).
Water contamination by PFAS has been detected in every corner of the globe in the largest study to date (Cousins et al., 2022). (5) However, the European Commission omitted the analysis of PFAS levels from the surface water monitoring plan updated to July 2022, as has already been reported. (6) Like the ostrich that throws its head in the sand to hide, DG Sante avoids risk analysis to avoid the burden of having to manage it.
4) PFAS, industrial uses.
Perfluoroalkyl substances have been used since the 1940s in numerous industrial applications. Although the REACH regulation has introduced restrictions on the use of some PFASs, thousands of unregulated substances are still being used. Industrial uses can be traced to three macrocategories:
- Coating treatments (aimed at achieving water, grease and oil repellency) of materials and objects intended for food contact (MOCA). (7) Paper and cardboard, disposable containers and dishes, non-stick cooking bottoms (e.g., Teflon), and pots and pans,
- surface treatments, particularly of textiles (carpets, stain-resistant upholstery, Goretex-type waterproof fabrics), leathers and photographic films,
- paints, fire fighting foams, packaging, furniture, etc.
5) REACH. Proposed restrictions on the use of PFAS in the EU
Denmark, Germany, the Netherlands, Norway and Sweden submitted a proposal to ECHA to revise REACH on January 13, 2023. With the specific aim of restricting at the EU level the conditions of use of about 10 thousand PFAS and thus reducing their emissions into the environment, as well as making industrial processes and products safer. (8)
The proposal ‘supports the ambitions of the EU Chemicals Strategy and the Zero Pollution Action Plan. Now our scientific committees will begin to evaluate and formulate opinions. Although the evaluation of such a broad proposal, with thousands of substances and many uses, will be challenging, we are ready‘ (Peter van der Zandt, ECHA, director for risk assessment).
5.1) ECHA, the next steps.
ECHA’s scientific committees dedicated to Risk Assessment (RAC) and Socio-Economic Analysis (SEAC) are now called upon to begin the scientific evaluation of the REACH reform proposal, with a view to preparing the two opinions on:
- Adequacy of the proposed restrictions to reduce risks to human health and the environment (RAC), and
- socio-economic impacts, that is, the benefits and costs to society, associated with the proposal (SEAC).
Both committees will formulate their opinions based on the information contained in the proposal of the five member states and the comments received during the public consultation timetabled for a period of six months, beginning March 22, 2023.
5.2) Perspectives
‘If PFAS releases are not minimized, people, plants and animals will be increasingly exposed and, without any restrictions, levels will be reached that will have adverse effects on people’s health and the environment.
Authorities estimate that about 4.4 million tons of PFAS would end up in the environment in the next 30 years if no action is taken‘ (ECHA. See footnote 8).
Big Chem
has in any case ensured at least a decade of continued use of these and other toxic chemicals, as also reported. Getting the European Commission to postpone its proposals for reform of REACH and FCM(Food Contact Materials) regulations in time for their political consideration to be postponed to the next legislative term (2024-2029. See notes 9,10).
6) PFAS pollution in Europe, the current scenario.
The Forever Pollution Project
is an investigative journalism project developed by 17 newspapers in 13 European Union countries, as well as in England and Switzerland. (11) PFAS have been found at about 17,000 sites in the Old Continent. In high concentrations, >1,000 nanograms per liter of water at about 640 sites and >10,000ng/l at 300 sites.
6.1) Food security at risk
‘ Disturbingconcentration levels,’ commented Professor Crispin Halsall (environmental chemist, University of Lancaster, UK) to The Guardian. (12). ‘There isa risk of animals having access to these waters and PFASs thus entering the human food chain.’ Also through fish and game.
‘The presence of PFAS in groundwater is a big problem because if groundwater is extracted for agriculture or, more importantly, for humans as a water source, then there are PFAS in drinking water and they are very difficult to remove‘ (Prof. Crispin Halsall at The Guardian). (12)
6.2) Urgent environmental remediation
Ian Cousins-the professor of environmental science at Stockholm University who coordinated the most extensive research ever done on planet-wide PFAS pollution (Cousins et al., 2022. See footnote 5) stresses that sites with values above 1,000ng/kg should undergo environmental remediation ‘as a matter of urgency’.
‘At sites [altamente] contaminated, local authorities should consider testing to ensure that PFAS levels are safe in local agricultural products. This would help determine whether local health advisories and outreach campaigns are needed to discourage regular consumption of wild fish, shellfish, free-range eggs, etc.‘ (Prof. Ian Cousins at The Guardian). (12)
6.3) Belgium, Holland, Germany, UK, Italy
Poison industries have contaminated and often continue to pollute ecosystems with forever chemicals. Abnormal concentrations of PFAS are reported in particular:
- England, on the Wyre River above Blackpool. Discharges from a local chemical industry broke all records, intoxicating fish with PFAS levels of up to 11,000ng/kg,
- in Flanders (Belgium), up to 73ng/l of PFAS in groundwater. Responsible unpunished 3M industry in Zwijndrecht where Post-it notes are produced,
- in the Netherlands near Schiphol Airport and in Germany near airports and military sites. ‘Extremely high‘ levels of soil contamination,
- in Italy, the Miteni and Solvay industries have poisoned large areas of Veneto and Piedmont with PFAS, respectively (13,14).
7) Interim Conclusions
Environmental Responsibility Directive
(ELD) No 2004/35/EC remains a piece of paper. Fifteen years of implementation of the directive has not even been enough to halt the advance of the most serious threats to public health and ecosystems.
Not only PFAS but also pesticides, dioxins and dioxin-like PCBs (15,16). As well as a myriad of ubiquitous toxic chemicals. (17) And the fateful Restrictions roadmap, (18) when?
Institutions and their senior management, in the European Union and member states, must be held accountable for unacceptable omissions in the analysis and management of overt and emerging risks. Not forgetting microplastics, which WHO called forrisk assessment of back in 2019. (19)
Dario Dongo
Notes
(1) Dario Dongo, Andrea Adelmo Della Penna. PFAS, furans, glycoalkaloids, Alternaria. European Commission ‘recommends’ rather than bans. GIFT (Great Italian Food Trade). 23.9.22
(2) Marta Strinati. PFAS, off to limits in meat, fish, eggs and other foods of animal origin. GIFT (Great Italian Food Trade). 20.1.23
(3) ISPRA (2019). Guidelines for the design of perfluoroalkyl substances (PFAS) monitoring networks in surface and groundwater bodies https://www.isprambiente.gov.it/files2019/pubblicazioni/rapporti/R_305_19_Progettaz_PFAS.pdf
(4) NTP, National Toxicology Program, USA. (2016). Monograph on Immunotoxicity Associated with Exposure to Perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS). Research Triangle Park, NC: National Toxicology Program. https://ntp.niehs.nih.gov/ntp/ohat/pfoa_pfos/pfoa_pfosmonograph_508.pdf
(5) Marta Strinati, Dario Dongo. PFAS in rainwater and food, a global ban urgently needed. GIFT (Great Italian Food Trade). 26.8.22
(6) Dario Dongo, Ylenia Desireè Patti Giammello. Water pollution. Antibiotics, drugs, pesticides in new EU monitoring plan. GIFT (Great Italian Food Trade). 17.10.22
(7) Marta Strinati, Dario Dongo. Toxic chemicals in disposable packaging and tableware. PFAS investigation in EU. GIFT (Great Italian Food Trade). 29.5.21
(8) ECHA publishes PFAS restriction proposal. https://echa.europa.eu/-/echa-publishes-pfas-restriction-proposal Communication ECHA/NR/23/04. 7.2.23
(9) Alessandra Mei. Postponed approval of changes to REACH. The chemical lobby can rejoice. GIFT (Great Italian Food Trade). 26.10.22
(10) Marta Strinati. Marta Strinati. Food contact materials, reform-slug slips again. GIFT (Great Italian Food Trade). 17.2.20
(11) The Forever Pollution Project was initially developed by the newspapers Le Monde (France), NDR, WDR, Süddeutsche Zeitung (Germany), RADAR Magazine and Le Scienze (Italy), The Investigative Desk and NRC (Netherlands). With financial support from Journalismfund.eu and Investigative Journalism for Europe (IJ4EU). Additional investigations have been published by Knack (Belgium), Denik Referendum (Czech Republic), Politiken (Denmark), YLE (Finland), Reporters United (Greece), Latvian Radio (Latvia), Datadista (Spain), SRF (Switzerland), Watershed Investigations, and The Guardian (UK). With support from Arena for Journalism in Europe for international collaboration
(12) Rachel Salvidge, Leana Hosea. Revealed: scale of ‘forever chemical’ pollution across UK and Europe. https://www.theguardian.com/environment/2023/feb/23/revealed-scale-of-forever-chemical-pollution-across-uk-and-europe The Guardian. 23.2.23
(13) Dario Dongo. Veneto. No PFAS Moms publish list of contaminated foods. GIFT (Great Italian Food Trade). 22.9.21
(14) Dario Dongo. Human rights and pesticides, PFAS, hazardous waste. OHCHR Audit in Italy. GIFT (Great Italian Food Trade). 1.1.22
(15) Marta Strinati. Not just glyphosate. 33% of pesticides used in EU lack risk assessment. GIFT (Great Italian Food Trade). 26.11.22
(16) Dario Dongo. Dioxins and PCBs in food, the great hoax. GIFT (Great Italian Food Trade). 4.12.22
(17) Dario Dongo, Toxic chemicals in everyday objects, the English report. GIFT (Great Italian Food Trade). 20.7.19
(18) Marta Strinati. Dangerous chemicals, the European Commission’s Restrictions Roadmap. GIFT (Great Italian Food Trade). 3.5.22
(19) Marta Strinati. Microplastics in drinking water, WHO calls for risk assessment. GIFT (Great Italian Food Trade). 22.8.19
Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.
