Document rxeo65LzRdJ61DMyL99JXV4ma

On the proposal for a restriction of Per- and polyfluoroalkyl substances (PFASs) 24th of September, 2023 Introduction As a concerned citizen of the Netherlands, I am a big supporter of the restriction of PFAS. In 2022 my husband was diagnosed with testicular cancer, a cancer associated with PFAS exposure.1 Another family member from Dordrecht has also been diagnosed with testicular cancer a few years ago. Though my husband has since been declared cured, we are now worried for the future health of our newborn daughter, due to the persistence and bioaccumulation of PFAS in our environment. I therefore have a personal interest in submitting this comment. My husband and I grew up and met in the city of Dordrecht, in one of the most populated parts of the Netherlands. Chemours Netherlands (formerly Dupont) is situated on the outskirts of the city. This plant emitted large quantities of PFOA in the surface water and air since the 70s. In 2012 Chemours replaced PFOA with GenX. GenX - a type of PFAS with a different formula - is still harmful for human health and the environment. As a result, it is no longer safe to consume crops grown on allotments in parts of the Dutch municipalities of Dordrecht, Papendrecht, Sliedrecht and Molenlanden.2 In 2023 the province of South Holland decided it was no longer safe to swim in the swimming lake `De Merwelanden' near the plant, due to high concentrations of PFAS in the water.3 My husband and I used to go swimming there regularly when we were younger. According to the National Institute for Public Health and the Environment in the Netherlands, the quantity of PFAS ingested for Dutch civilians through food and drinking water is above the health-based guidance value.4 I want to stress the importance of hearing people who have been effected by PFAS pollution during the examination of this proposal, especially given the fact that most comments for this proposal are submitted by chemical companies who are financially benefiting from the use of PFAS. I will substantiate this comment with scientific sources that have not yet been mentioned in the proposal. Comments: 1. Risks of differentiation between classes of PFAS While a class-based approach to chemical management of PFAS can pose challenges to the traditional paradigm of individual chemical risk assessment, the extreme persistence and potential 1 Barry et. al, `Perfluorooctanoic Acid (PFOA) Exposures and Incident Cancers among Adults Living Near a Chemical Plant', Environmental Health Perspectives Nov-Dec 2013; Vol. 121 (11-12): 1313-1318. Perfluorooctanoic Acid (PFOA) Exposures and Incident Cancers among Adults Living Near a Chemical Plant | Environmental Health Perspectives | Vol. 121, No. 11-12 (nih.gov) 2 P. Boon and J.D. te Biesebeek, Risk assessment of PFAS in crops grown on allotments in the Dutch municipalities of Dordrecht, Papendrecht, Sliedrecht and Molenlanden, Rijksinstituut voor Volksgezondheid en Milieu RIVM 2022. Reportnumber 2022-0010. Risicobeoordeling van PFAS in moestuingewassen uit moestuinen in de gemeenten Dordrecht, Papendrecht, Sliedrecht en Molenlanden | RIVM 3 M. Woutersen, Risk assessment of PFAS in recreational swimming lake Merwelanden in Dordrecht, Rijksinstituut voor Volksgezondheid en Milieu RIVM 2023. Reportnumber KU-2023-0013. Resultaat risicoanalyse PFAS in zwemwater Plas Merwelanden | RIVM 4 Schepens et. al, Risk assessment of exposure to PFAS through food and drinking water in the Netherlands, Rijksinstituut voor Volksgezondheid en Milieu RIVM 2023, Reportnumber 2023-0011. Analyse bijdrage drinkwater en voedsel aan blootstelling EFSA-4 PFAS in Nederland en advies drinkwaterrichtwaarde (rivm.nl) for harm from thousands of PFAS demand a more efficient and effective approach.5 A full ban of PFAS (RO1) Some chemical companies argue that certain classes of PFAS are not as harmful as others, for example fluoropolymers. But fluoropolymers are a group of PFAS too diverse to warrant a blanket exemption from additional regulatory review. Their extreme persistence and the emissions associated with their production, use, and disposal result in a high likelihood for human exposure as long as uses are not restricted.6 Let's not forget it was the production of fluoropolymers and the associated use and release of PFOA that led to the widespread contamination of the US mid-Ohio river valley.7 Some chemical companies say that short chain PFAS are less dangerous than long chain PFAS. But research shows that short chain PFAS are more widely detected than long chain PFAS, more persistent and mobile in aquatic systems, and thus may pose broader risks on the human and ecosystem health. Though conventional adsorption, ion-exchange, and membrane filtration can remove short-chain PFAS, these methods are less effective than the long-chain homologues, and are challenged with poor material regeneration efficiency and disposal of process waste residual.8 Managing PFAS as a class reduces the likelihood of replacing well-studied hazardous chemicals with poorly studied but structurally similar PFAS that have the potential to be similarly hazardous. A lack of full scientific certainty should not be used as a reason for abandoning measures. The persistence and bioaccumulation of PFAS in our environment warrant an strict application of the precautionary principle (article 191 TFEU). 2. Waste management during transition period and for exceptions. Though I recognize the importance of the use of PFAS in the production of certain products used for the energy transition or medical devices, we must prevent these substances from entering our environment at all costs. Exemptions are only to be made when absolutely necessary. If no alternative is available for essential products, waste from the manufacturing process should be stored or if possible, processed in a way no PFAS or their degradation products enter the environment. Products of which the production process requires the use of PFAS should be phased out as much as possible. During the proposed transition period of 18 months and time-limited derogations, an immediate EU wide ban for emissions of all PFAS in water and air is therefore necessary. Yours sincerely, Lisette van der Marel van Broekhoven 5 C.F. Kwiatkowski et. al, Scientific basis for managing PFAS as a chemical class, Environmental Science and Technology Letters 2020, 7, 532-543. Scientific Basis for Managing PFAS as a Chemical Class (acs.org) 6 R. Lohmann et. al, Are fluoropolymers really of low concern for human and environmental health and separate from other PFAS?, Environmental Science & Technology 2020, 54, 20, 12820-12828. Are Fluoropolymers Really of Low Concern for Human and Environmental Health and Separate from Other PFAS? | Environmental Science & Technology (acs.org) 7 Steenland, K.; Jin, C.; MacNeil, J.; Lally, C.; Ducatman, A.; Vieira, V.; Fletcher, T. Predictors of PFOA levels in a community surrounding a chemical plant. Environ. Health Perspect. 2009, 117 (7), 1083-8. 8 F. Li et al., `Short chain per- and polyfluoroalkyl substances in aquatic systems: Occurrence, impacts and treatment', Chemical Engineering Journal Vol. 380, 15 januari 2020, 122506. Short-chain per- and polyfluoroalkyl substances in aquatic systems: Occurrence, impacts and treatment - ScienceDirect