Five EU Member States have finally formalized a ECHA (European Chemical Agency) a proposal for a revision of REACH (Registration, Evaluation, and Authorization of Chemical Substances) Regulation EC No 1907/2006, to restrict the use of about 10 perfluoroalkyl substances (PFAS). And thus safeguard the One Health (public health, animal health and welfare, environment) come on forever chemicals.
Indeed, exposure to these toxic chemicals is associated with endocrine disruption, increased risk of contracting certain types of cancer, gestational disease and harm to the unborn child. And it is time to intervene at the source of the problem, no longer limiting ourselves to the mild measures adopted so far to contain only the food exposures of European citizens to PFAS (1,2). But the European Commission stalls, and the disaster continues.
1) Forever Chemicals. Premise
THROW (European Chemical Agency) has long clarified that PFAS, toxic chemicals not found in nature:
- contain some of the strongest chemical bonds in organic chemistry (carbon and fluorine),
- are able to pollute ecosystems even at long distances from the source of the release, e
- they resist the processes of thermal degradation, biodegradation, hydrolysis, metabolization. As well as being highly soluble in water.
2) Toxicity, persistence, bioaccumulation
ISPRA (2019) indicate PFOS and PFOA – the final degradation products of most fluorinated compounds, in the PFAS family – as the most dangerous contaminants. (3) They are indeed identified as PBT substances (Persistent, Bioaccumulative and Toxic), in Annex XVII to REACH (Registration, Evaluation, and Authorization of Chemical Substances) Regulation EC No 1907/2006.
PFOA and PFOS have been associated with a number of serious public health risks, which add to the toxicity of PFAS – even at low levels of exposure (4) – to the immune system:
- PFOA. Kidney and testicular tumors supra, par. 2.1), thyroid disease, ulcerative colitis, hypercholesterolemia and hypertension during pregnancy,
- PFOS and other PFAS. Reproductive and developmental diseases, liver, kidney and thyroid diseases (see above, par. 2.2).
2.1) Cancer risk
IARC (International Agency for Research on Cancer), the lead agency of WHO (World Health Organization) classified polytetrafluoroethylene PFOA, as 'possibly associated with kidney and testicular cancers' (group 2b).
2.2) Bioaccumulation in blood and liver
The Higher Institute for Environmental Protection and Research (ISPRA) also clarifies that 'Human exposure to PFAS is primarily due to ingestion of contaminated food or water'.
Several studies have demonstrated a rather long half-life of PFAS also in human and animal organisms, where they accumulate mainly in the blood and liver.
'They can provoke hepatotoxicity, immunotoxicity, neurotoxicity, hormonal changes in reproduction and development'. (3)
2.3) Gestational diseases, malformations, genotoxicity
Lo 'studio on maternal and neonatal outcomes in relation to contamination by perfluoroalkyl substances (PFAS)' – edited by the Birth Register, Veneto Region Rare Diseases Coordination – confirms the 'international scientific literature related to PFAS' referring to the increase of:
- pre-eclampsia (or gestosis, a complication that can develop during pregnancy),
- gestational diabetes, with 'clear gradient of risk which progressively decreases moving away from the red area' (for PFAS pollution levels)
- born very low birth weight and born SGA (Small for gestational age),
- 'some major malformations, including nervous system, circulatory system, and chromosomal abnormalities'.
3) Serious public health risks, poor protection in the EU
The serious risks health issues associated with PFAS exposure continue to receive little attention from the European Commission. Some hints of 'orientation' in the Waters Directive, recent 'recommendations' from Brussels on these and other contaminants, only recently the maximum limits on some products of animal origin (1,2).
The contamination of the waters from PFAS has been detected in every corner of the planet, in the largest study ever conducted so far (Cousins et al., 2022). (5) However, the European Commission has omitted the analysis of PFAS levels from the surface water monitoring plan updated in 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 they have been used since the 40s in numerous industrial applications. Although the REACH regulation has introduced restrictions on the use of some PFAS, the use of thousands of unregulated substances is still ongoing. The industrial uses can be traced back to three macro-categories:
- coating treatments (aimed at obtaining water, fat and oil repellency) of materials and objects intended to come into contact with food (MOCA). (7) Paper and cardboard, disposable containers and tableware, non-stick cooking bases (e.g. Teflon) and pans,
- surface treatments, in particular of textile products (carpets, stain-resistant upholstery, Goretex-type waterproof fabrics), leather and photographic films,
- paints, fire-fighting foams, packaging, furniture, etc.
5) REACH. Proposal for restrictions on the use of PFAS in the EU
Denmark, Germany, Holland, Norway and Sweden presented a proposal for the revision of the REACH regulation to ECHA on 13 January 2023. With the specific aim of restricting the conditions of use of around 10 PFASs at EU level and thus reducing their emissions into the environment, as well as making industrial processes and products. (8)
The proposal 'supports the ambitions of the EU Chemicals Strategy and the Zero Pollution Action Plan. Now our scientific committees will start evaluating and formulating opinions. While evaluating 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
scientific committees of ECHA dedicated to Risk Assessment (RAC) e Socio-Economic Analysis (SEAC) are now called to start the scientific evaluation of the REACH reform proposal, in view of the preparation of the two opinions on:
- adequacy of the proposed restrictions to reduce the risks to human health and the environment (RAC), e
- socio-economic impacts, ie the benefits and costs for society, associated with the proposal (SEAC).
Both committees formulate their opinions on the basis of the information contained in the proposal of the five Member States and the comments received during the public consultation on the calendar for a period of six months, starting on 22 March 2023.
5.2) Perspectives
'If the PFAS releases are not minimized, people, plants and animals they will be increasingly exposed and, without any restriction, levels will be reached that will have negative effects on people's health and the environment.
Authorities estimate that around 4,4 million tonnes of PFAS would end up in the environment over the next 30 years if nothing is done' (ECHA. See footnote 8).
BigChem in any case, it has ensured at least a decade of continuation of the use of these and other toxic chemicals, as it has also denounced. By getting the European Commission to postpone the REACH and MMF reform proposals (Food Contact Materials) in time to postpone the political examination to the next legislature (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 countries of the European Union, as well as in England and Switzerland. (11) PFAS have been found in approximately 17.000 sites in the Old Continent. In high concentrations, >1.000 nanograms per liter of water at approximately 640 sites and >10.000ng/l at 300 sites.
6.1) Food safety at risk
'Levels of concentration worrying', commented Professor Crispin Halsall (environmental chemist, Lancaster University, UK) at The Guardian. (12). 'There is a risk that animals have access to these waters and PFAS thus enter the human food chain'. Even through fish and game.
'The presence of PFAS in groundwater it is a big problem because if the groundwater is abstracted for agriculture or more importantly for human beings as a source of water then there are PFAS in the drinking water and they are very difficult to remove' (Prof. Crispin Halsall a The Guardian). (12)
6.2) Urgent environmental remediation
Ian Cousins – Stockholm University environmental science professor who coordinated the largest ever research into planetary PFAS pollution (Cousins et al., 2022. See note 5) underlines that sites with values higher than 1.000ng/kg should be 'urgently' subjected to environmental remediation.
'In [highly] contaminated sites, local authorities should consider carrying out tests to ensure that PFAS levels are safe in local agricultural products. This would help determine whether local health advisories and awareness campaigns are needed to discourage regular consumption of wild fish, shellfish, free-range eggs, etc.' (Prof. Ian Cousins a The Guardian). (12)
6.3) Belgium, Holland, Germany, UK, Italy
The poison industries have contaminated and often continue to pollute ecosystems with i forever chemicals. Abnormal concentrations of PFAS are reported in particular:
- in England, on the River Wyre, above Blackpool. Waste from a local chemical company broke all records, poisoning fish with PFAS levels of up to 11.000ng/kg,
- in Flanders (Belgium), up to 73ng/l of PFAS in groundwater. The 3M factory in Zwijndrecht where Post-its are produced is responsible with impunity,
- in the Netherlands, near Schiphol airport and in Germany, near airports and military sites. Levels of soil contaminationextremely high’,
- in Italy the Miteni and Solvay industries have poisoned large areas of Veneto and Piedmont with PFAS, respectively (13,14).
7) Provisional conclusions
Environmental Responsibility Directive (ELD) No 2004/35/EC a piece of paper remains. 15 years of application of the directive have not even been enough to halt the advance of the most serious threats to public health and ecosystems.
Not just 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?
The institutions and their senior managers, in the European Union and in the Member States, must be held accountable for unacceptable omissions in the analysis and management of established and emerging risks. Without forgetting the microplastics, of which WHO has requested the risk assessment way back in 2019. (19)
Dario Dongo
Footnotes
(1) Dario Dongo, Andrea Adelmo Della Penna. PFAS, furans, glycoalkaloids, Alternaria. The European Commission 'recommends' rather than prohibits. GIFT (Great Italian Food Trade). 23.9.22
(2) Martha Strinati. PFAS, go to the 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 monitoring networks for perfluoroalkyl substances (PFAS) in surface and underground water 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 is urgently needed. GIFT (Great Italian Food Trade). 26.8.22
(6) Dario Dongo, Ylenia Desire and Patti Giammello. Water pollution. Antibiotics, drugs, pesticides in the new EU monitoring plan. GIFT (Great Italian Food Trade). 17.10.22
(7) Marta Strinati, Dario Dongo. Toxic chemicals in disposable tableware and packaging. Survey on PFAS in the 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. Approval of changes to REACH postponed. The chemistry lobby can cheer. GIFT (Great Italian Food Trade). 26.10.22
(10) Martha Strinati. Martha Strinati. Materials in contact with food, the slug reform still slips. GIFT (Great Italian Food Trade). 17.2.20
(11) The Forever Pollution Project it was initially developed by the publications Le Monde (France), NDR, WDR, Süddeutsche Zeitung (Germany), RADAR Magazine and Le Scienze (Italy), The Investigative Desk and NRC (Netherlands). With the financial support of Journalismfund.eu and Investigative Journalism for Europe (IJ4EU). Additional surveys were published by Knack (Belgium), Denik Referendum (Czech Republic), Politiken (Denmark), YLE (Finland), Reporters United (Greece), Latvian Radio (Latvia), Datadista (Spain), SRF (Switzerland), Watershed Investigations, The Guardian (UK). With the support of 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. The Mothers No PFAS publish the 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) Martha Strinati. Not just glyphosate. 33% of pesticides used in the EU are without risk assessment. GIFT (Great Italian Food Trade). 26.11.22
(16) Dario Dongo. Dioxins and PCBs in food, the big joke. 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) Martha Strinati. Dangerous chemistry, the European Commission's Restrictions Roadmap. GIFT (Great Italian Food Trade). 3.5.22
(19) Martha 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.
