Last reviewed 11 January 2022
The Royal Society of Chemistry has issued a policy paper on risk-based regulation of per and poly-fluoroalkyl substances (PFAS).
PFAS represents a large group of thousands of fluorinated chemicals used globally since the 1940s in a multitude of different products and processes for their unique water, oil, heat and stain-resistant properties. However, due to their high stability in the environment and resistance to biodegradation, all PFAS are persistent, and many are highly mobile in global waters. PFAS are present in groundwater, freshwater systems, the marine environment, in wildlife and in our human bodies. Regulations aiming to control exposure to PFAS and mitigate the risks are now emerging around the world to prevent potential harms from accumulative pollution from multiple chronic and diffuse sources. Indeed, the UK, Welsh and Scottish Governments have asked the Health and Safety Executive and the Environment Agency to prepare a regulatory management options analysis (RMOA) for PFAS.
The RMOA will investigate the risks posed by PFAS and recommend the best approach to protect human health and the environment from any identified risks.
To support this, the HSE has issued a call for evidence as it seeks to gather information and evidence on all aspects of the manufacture, import, hazard profile, use and exposure of PFAS. This consultation closes on 30 January 2022.
The RSC paper, meanwhile, proposes a regulatory framework based on a multi-step “traffic-light” decision-tree approach around PFAS use in society and on the basis of safety risk and impact assessments. It proposes a green, amber, and red list approach to take appropriate regulatory action based on a defined level of acceptable risk according to an agreed set of criteria, as defined by the regulator working with science advisory mechanisms within government. This approach is designed to be proportionate, iterative, and agile, to ensure it accounts for evolving scientific evidence on PFAS.
The RSC is also urging the Government to invest in a Science Hub for Applied Research in Chemicals Regulation and Standards. Such a hub would support the advancement of scientific knowledge, foster innovation and global collaboration and develop a strong skills base, for PFAS science and other challenging issues for chemicals used in society. World-class scientific know-how in the use of new approach methods for toxicity testing and other new risk assessment technologies such as physiologically based kinetic modelling and biomonitoring, would help assess the safety of PFAS but indeed for application to any other new chemicals arriving into the market. This will require significant new investment but result in the development of highly trained scientific and technical specialists in chemicals regulation for all chemicals not just PFAS, supporting innovation at the same time as ensuring human health and environmental protection using sound science.