Document LoEMrM6D8e1GJwzX9V8axmeaQ
Risk management of PFASs at the European Chemicals Agency
PFAS Global 2022
24 March 2022
Restriction Process Coordinator European Chemicals Agency
Overview
PFASs as a hot topic for EU risk management Risk management of PFASs based on
`arrowheads' Proposed REACH restriction for all PFASs in
firefighting foams
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PFAS concern
PFAS contain (numerous) carbon-fluorine bonds
Very stable - resist (bio)degradation
Some are highly soluble and mobile (i.e. surfactants)
can be readily transport once in the environment frequently observed to contaminate groundwater, surface water
and soil
Some bioaccumulate
notably `long chain' perfluoroalkyl substances
Some met REACH criteria for persistent, bioaccumulative and toxic (PBT) or very persistent, very bioaccumulative (vPvB)
3
Existing regulation of PFASs in EU
Some PFAS already subject to [or pending] restrictions on manufacture/use under REACH or POPs regulation in EU (some also Stockholm Convention)
Perfluoroalkyl sulfonic acids (PFOS; [PFHxS])
Perfluoroalkyl carboxylic acids (PFOA; C9-C14 PFCAs; [PFHxA])
Some identified as SVHCs
E.g. HFOP-DA (GenX), PFBS, PFHxS
Some undergoing REACH substance evaluation or have a harmonised classification under CLP regulation
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Arrowheads and related substances
Risk management has typically focused on specific `arrowheads' and their `precursors'
Arrowheads are `terminal' degradation products with hazardous properties (typically PBT/vPvB)
e.g. PFOA, PFHxS, C9-C14 PFCAs, PFHxA
`Precursors' or `related-substances' transform to arrowhead
A single restriction can cover many different substances as long as they can degrade/transform to the arrowhead
Effective but have lead to regrettable substitution
PFOS PFOA PFHxA ????
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F F
F
FF
FF
FF
FF
F
F O
S X
O
PFHxS sulfonic halides, X = F, Cl, Br
F
FF
FF
F
FO S
F
FF
FF
F
O
O
R
PFHxS sulfonic ester, R = alkyl, olefin, aryl
F F
F
FF
FF
FF
FF
F
F O
SR N
O
R'
PFHxS sulfonamides, R, R' = H, alkyl, olefin, aryl
hydrolysis or radical processes
F F
F
FF
FF
FF
FF
F
F S
O
O OH
PFHxS
+
radical processes
F
FF
F
O
F
FF
F
F
+F
OH +
... F
FF
FF
F
OH
F
FF
F
O
PFCAs
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PFASs in firefighting foams
Image: iStock.com
PFASs in firefighting foams
Around 18 000 tonnes of PFAS firefighting foams sold in the EU each year
500 tonnes of PFAS Oil/(petro-)chemical sector is the
largest user Most sectors have examples of
users that have substituted to fluorine-free foams (typically training)
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https://pubs.acs.org/do i/pdf/10.1021/acs.est.1 c06896
9
Hazard assessment
PFASs assessed as a group
Persistence is the common property of the group
Various supporting concerns
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Hazard conclusions
Persistence combined with supporting concerns
Quantitative risk assessment is not reliable or practicable Not possible to demonstrate safe use Continued use would inevitably result in accumulation to
levels causing adverse effects Restriction applied as a `safety net'
`Case-by-case' risk assessment according to Annex I (section 0.1) of REACH
Risks of PFASs are non-threshold Releases are a proxy for uncontrolled risk Risk management to minimise releases
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Restriction option analysis
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Evaluation and decision making
Proposal being evaluated by ECHA's committees for:
Risk Assessment (RAC) Socio-Economic Analysis (SEAC)
Six-month consultation of interested parties
Stakeholder information session 5th April
Evaluation documented in `opinions' Commission and Member States decide on
implementing the restriction in REACH Committee Scrutiny by Council of the EU and European Parliament
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Thank you!
@echa.europa.eu