Document gbaY2Ked89oz3Og6kVn88LyNa

20230808 Appendix 1 Addional text for REACH PFAS restricon consultaon VEWIN / UvW Ad III, Non confidenal Comments Vewin, the Associaon of Dutch drinking water companies and the Dutch Water Associaon (UvW) strongly support the proposed PFAS restricon. PFAS measurements in drinking water, as reported by RIVM in October 2022 1, emphasize the need for acon to protect the sources of our drinking water, the water system in general and our consumers. PFAS is a serious risk for drinking water Based on the 2020 EFSA report on "Risk to human health related to the presence of perfluoroalkyl substances in food", the Dutch naonal instute for Public Health (RIVM) derived a health-based guidance value of 4,4 ng/l PFOA Equivalents. In the menoned study by RIVM, PFAS concentraons exceeded this threshold in over half of the measurements of drinking water produced from surface water. For drinking water from groundwater, this was the case for 1 in 10 measurements. These concentraons need to be brought down to ensure people's PFAS intake from drinking water does not become too high. Areas with the highest PFAS concentraons in drinking water are located in the Western part of the Netherlands, where drinking water is mostly produced from river water. Concentraons the environment slowly decline because PFAS are widely present, do not or barely degrade and are difficult to remove in water treatment. Given this fact, a precauonary approach based on sourceprotecon like a the proposed PFAS restricon, is the way forward. Projecons of future PFAS concentraons in ground- and surface water as a source for drinking water indicate that without tackling the source of PFAS all drink water sources will eventually surpass these threshold values 2. KWR research in 2022 on PFAS in European waters3 suggests that PFAS is raising similar high concern in other EU countries as well. PFAS is a risk for the water system in general In addion to the risks for drinking water specifically, it is important to stress that PFAS is a serious risk to the water system in its enrety. If people would only come into contact with PFAS through drinking water, the problem would be less serious. However, there are several other ways in which people are exposed to PFAS. Furthermore, several examples can be menoned in which PFAS has negave consequences for the water quality. Addional sources of PFAS in the water system, for example, are the supply of PFAS 1 htps://www.rivm.nl/en/news/pfas-levels-in-drinking-water-from-river-water-need-to-be-brought-down 2 589870 (wur.nl) 3 htps://www.rijksoverheid.nl/documenten/rapporten/2022/12/31/pfas-in-europees-water-een-verkenning from upstream rivers and the deposion of PFAS through the air. PFAS has a negave effect on ecology, including toxic effects, accumulaon in organisms and subsequently within the food chain. PFAS also has a negave impact on other water funcons like swimming, recreaon in general on or close to the water, fishing, irrigaon and livestock watering. We see waters in which the concentraon of PFAS is already ten thousand mes too high, and it is very difficult or even impossible to eliminate PFAS once it is present in the water system. PFAS also contains a risk to water soils and circular ambions. Dredging acvies are somemes necessary to preserve the water system including the water quality. When PFAS accumulates within water soils, the dredge should ulmately be disposed which is very expensive. When it comes to sludge which can be derived from sewage treatment plants, it becomes impossible to reuse the wastewater. In reference a circular economy this is an undesirable effect. TFA as an extreme threat Especially the occurrence of the ultrashort PFAS TriFluoroacec Acid (TFA) in surface water, groundwater and drinking water is an extreme threat. Data from Rijkswaterstaat and RIWA as stored in the Norman database (June 2023) show concentraons of TFA up to 3 microgram/l. The drinking water advisory threshold value for TFA as a single compound is set to 2200 ng/l (RIVM, 2023)4 , but combined with other PFAS the proposed threshold-value is in the Netherlands is 4,4 ng PFOA Equivalents (PEQ)/l. In which TFA is given relave potency factor of 0,002. Neuwald (2022) and Sadia (2023) found concentraons in the order of 1 microgram/l which exceed the limits as given by the European Drinking Water Direcve 5 6. In this direcve, which took effect on 12 January 2021, a limit of 0.5 g/l for all PFAS is included. TFA alone exceeds this threshold. This TFA originate from various industrial use, domesc use and degradaon products and are found in high concentraons in the environment and drinking water. illustrang once more that only a (global) ban can be the way forward to prevent the ubiquitous emissions of this compound and its precursors 7. The claim that TFA is of natural origin is convincingly refuted by Joudan (2022) 8 Clean, deeper groundwater reserves for drinking water will be lost in the future without a ban At this moment especially drinking water produced from river water is strongly affected by the PFAS polluon. Inevitability, drinking water from groundwater will also be affected without a ban. Given the ubiquitous presence of PFAS from air-emissions and deposion at the soil-surface, this amount of PFAS will gradually and connuously infiltrate to the deeper aquifers, pollung the previously unaffected reservoirs of clean drinking water for the Dutch and European costumers, leading to extreme purificaon costs and efforts. The infiltraon-rate of PFAS to the deeper underground is 4 DMG-2023-0011 Bijlage Advies 14434A02_Drinkwaterrichtwaarde TFA_07122022.pdf (rivm.nl) 5 htps://pubs.acs.org/doi/abs/10.1021/acs.est.1c07949 6 htps://pubs.acs.org/doi/full/10.1021/acs.est.2c06015 7htps://open.rws.nl/publish/pages/178609/eindrapp_brononderzoek_drinkwaterrelevante_stoffen_20221216 _1-1_opmized.pdf 8 htps://pubs.rsc.org/en/content/arclelanding/2021/EM/D1EM00306B modelled by KWR 9. This might take decades, but will, without a ban, eventually end up with the polluon of all exisng European Groundwater bodies up to levels that exceed the threshold values for PFAS that are proposed in the current revision of the Water Framework Direcve (WFD) and its daughter Direcves on Environmental Quality Standards (WFD-EQSD) and Groundwater Direcve (WFD-GD)), where Environmental Quality Standards (EQS) are proposed for a group of 24 PFAS on al level of 4,4 ng/l PFOA Equivalents. Banning PFAS in is crucial for several reasons Health Risks and Consumer Protection PFAS have been associated with numerous adverse health effects, including developmental issues, liver damage, thyroid disrupon, immune system impairment, and certain types of cancer. These substances can enter the human body through various routes, including drinking water. By banning PFAS in Europe, the aim is to reduce exposure to these harmful chemicals and protect public health. The Dutch Naonal Public Health Instute (RIVM) has already calculated that Dutch cizens take in too much PFAS already. A ban on PFAS is absolutely necessary to ensure a safe living environment for European cizens now and in the future. Water Treatment Challenges and Costs Removing PFAS from water sources is challenging and costly for drinking water treatment facilies. Due to their unique properes, PFAS are resistant to tradional water treatment processes, making their removal extremely difficult, and moreover, advanced treatment methods, such as acvated carbon filtraon or reverse osmosis, require 5-20 % more source water, where (groundwater) sources of drinking water are becoming more scarce as a result of climate change and drought. In addion to this, there are currently no efficient techniques available to eliminate PFAS from waste water through sewage treatment plants. In most cases, exisng techniques to reduce PFAS are very expensive and litle effecve in case of a small source, especially considering the high contribuon of addional sources of PFAS through the air and upstream supplies. These techniques are also require a huge amount of energy, which is not desirable in relaon to climate change. It is much more effecve and environmentally friendly to prevent PFAS from geng into the environment in the first place. As the vast majority of PFAS in river water (Rhine and Meuse) entering the Netherlands is emited somewhere in the internaonal river-basin, a European, cross-border approach is the only logical approach to minimize this polluon. PFAS removal techniques are insufficient and mostly moving PFAS from one medium to another PFAS is a very persistent group of chemicals with no natural decay. PFAS removal from drinking water is moving PFAS from one medium to another. Waste streams of PFAS containing acvated carbon or membrane concentrate is the result. Removal of PFAS from water might be the soluon for drinking water, but leads to extra polluon of (surface) water, air and landfills, as the waste-streams of standard purificaon (PFAS containing acvated carbon, sludge or concentrate) ends up somewhere in the environment. Verma at al. (2023)10 described low performance of thermal and non-thermal treatment technologies in large scale applicaons. 9 htps://edepot.wur.nl/589870 10 Recent advances on PFAS degradaon via thermal and nonthermal methods - ScienceDirect The need for a ban on PFAS Banning PFAS in Europe would lead to a reducon in their presence in water sources, easing the burden on water treatment facilies. This, in turn, can alleviate the costs associated with the specialized treatment required for PFAS removal. By prevenng further contaminaon, it allows resources to be focused on enhancing overall water quality and improving treatment efficiency. In conclusion, banning PFAS in Europe, parcularly in the context of drinking water producon, is essenal for protecng public health, safeguarding the environment, and liming public costs and even droughts. Droughts, because addional purificaon with for example membranes, requires extra source waters from rivers and aquifers that are threatened for over-exploitaon during long dry periods like the summer of 2023, where drinking water facilies throughout Europe feared for shortages. Furthermore, banning PFAS aligns with global efforts to regulate and restrict these substances. It demonstrates Europe's commitment to environmental protecon and encourages internaonal harmonizaon in the control of PFAS. By taking decisive acon, Europe can lead the way in creang a safer and more sustainable future, ensuring clean and healthy drinking water for its populaon and seng an example for the rest of the world. All PFAS are a threat As we have learned, PFAS are emited along various pathways and are ubiquitous: everywhere in the world PFAS are found. Unwanted emissions occur during producon, use, and disposal. The total occurrence and emissions of lots of PFAS and precursors are not well known. According to the Pubchem classificaon browser 11, there are more than 6 million various PFAS that fit the OECD PFAS definion of the Restricon dossier. Removal and remediaon is praccally impossible. Even burning leads to smaller PFAS-fragments and transformaon products like TFA. Claims of industry that there are less harmful PFAS have led to regretable substuons, for example from PFOA to GenX (HFPO-DA). Similar claims of harmless PFAS-subgroups like fluoropolymers are refuted in literature by Lohmann et al. 12. Somewhere in the process of producon, use and disposal PFAS will enter the environment and accumulate in water, soil, air and the foodchain. The supports the conclusion that the only way to prohibit further emissions and accumulaon of PFAS in our environment is a complete ban. Vewin strongly supports the broad scope of the PFAS definion in the restricon proposal. The need for a broad scope is also necessary as the health based drinking water advisory level as derived by RIVM has no limitaon and contains every PFAS (Including TFA) with an established Relave Potency Factor (RPF-value) translated to PFOA equivalents and should not exceed the level of 4,4 ng/l PFOA equivalents per litre. This list of PFAS is theorecally enormous. 11 htps://pubchem.ncbi.nlm.nih.gov/classificaon/#hid=120 12 Are Fluoropolymers Really of Low Concern for Human and Environmental Health and Separate from Other PFAS? | Environmental Science & Technology (acs.org) The need of fast implementaon and no exempons This restricon-proposal does not come as a surprise or unannounced. The societal risks and costs of the use of PFAS have been described many mes, for example by Chemsec in 2023 13. Given the me between the (announcement of the) proposal (2022) and suggested start of the implementaon (2025), there will be enough me for industry to prepare. Therefore exempons should not be tolerated and only be granted under very strict condions and for a period as short as possible Texle, paper and firefighng-foam industry have proven that there are always alternaves available for PFAS. It takes some years of a transformaon period, but it is possible, as proven by the H&M group during the ZeroPM workshop in February 2023 14. Recently (june 2023), Marn Scheringer published a comment in science, with the same conclusion 15. Claims that PFAS are essenal for societal favourable transions like the energy transion should be crically assessed, The fact that PFAS are used for "essenal" and high valued products, doesn't automacally mean that PFAS are essenal in these products. There will always be an alternave that will also beter fit with the European ambions of a circular economy. PFAS containing products are probably impossible to re-use. In order to prevent further polluon of the European environment and the sources of our drinking water a fast implementaon with no exempons is the way forward. Only restricon of emissions is an illusion Claims that the PFAS containing products are not the problem, but only the producon, and that the emissions during producon could be regulated is misleading. As stated by Lohmann (2020), emissions occur during producon, use and disposal 16. Removing of PFAS is an illusion. Removal of PFAS from air or water moves the PFAS from one phase to another, for example from water tot acvated carbon or membrane concentrate. These PFAS containing waste-streams ends up in landfills or are burned at standard temperatures, leading to new/other and unmeasured smaller PFAS compounds that will re-enter the environment by leaching to soil and air. Again supporng the proposal for a complete ban. Addional supporng documentaon Commissioned by Vewin, KWR has compiled an overview of recent relevant scienfic literature informaon that is important for the current restricon proposal. This report is atached as appendix 2. Relevant conclusions from this research are: - PFAS have documented adverse effects on human health and the environment, and that (drinking) water is an important exposure route for humans to PFAS; 13 htps://chemsec.org/reports/the-top-12-pfas-producers-in-the-world-and-the-staggering-societal-costs-ofpfas-polluon/ 14 htps://www.youtube.com/watch?v=opaJACkecJQ&t=11s 15 htps://www.science.org/doi/10.1126/science.adj7475 16 htps://pubs.acs.org/doi/full/10.1021/acs.est.0c03244 - The amount of literature and evidence on adverse health effects of PFAS is sll growing; - Many of reported removal methods have the potenal to efficiently remove PFAS from water. Nevertheless, it should be noted that these findings are novel and somemes promising, but it remains yet unclear if their implementaon on a large scale is feasible; - The restricon of PFAS can indeed result in lower exposure and thus risks to humans and the environment; - It is argued that all PFAS, including fluoropolymers, give rise to emissions of harmful PFAS at some stage of their life cycle. Therefore, some authors support the broad definion of PFAS used in the restricon proposal and the resulng ban on fluoropolymers and other PFAS alike. - It was noted that the authors supporng the exempon of fluoropolymers from a ban represent or are affiliated with PFAS-producing companies; - 97 % of China's PFOA/PFO emissions originated from the producon of fluoropolymers; - Emerging PFAS can induce toxicity like legacy PFAS like PFOS and PFOA; - The jusficaon for managing PFAS as a single chemical class to reduce PFAS-related risks is provided in the scienfic literature. It is argued that a class-based approach can be implemented to eliminate non-essenal uses of PFAS more effecvely, develop safer alternaves, and clean up highly contaminated areas. - A restricon of PFAS can indeed result in lower exposure and thus risks to humans and the environment; The overall conclusion of Vewin is that there is strong scienfic support for a complete ban of all PFAS according to the proposed PFAS definion, including subgroups as TFA and fluoropolymers.