On 17 October, a stakeholder consultation led by the Netherlands, Germany, Denmark, Sweden, and Norway on the use of PFAS (per- and polyfluoroalkyl substances) closed. By 2022, the European Chemicals Agency is expected to submit its restriction proposal for the use of PFAS in firefighting foams and other products. Combined with pressure from green groups calling for complete avoidance of these chemicals, the European Union is on the brink of a very costly and unfeasible policy move: a complete PFAS ban.
PFAS are man-made chemicals that can be found in a variety of consumer products. Some popular uses include medical equipment, food packaging, and firefighting foam. In the case of medical equipment, for example, these chemical compounds are vital for contamination-resistant gowns and drapes, implantable medical devices, stent grafts, heart patches, sterile container filters, needle retrieval systems, tracheostomies, catheter guide wire for laparoscopy, and inhaler canister coatings.
However, that is not to say that all of these chemicals are safe. When improperly dumped into the water supply, or when the exposure exceeds specific threshold levels, they do pose a danger. These concerns are justified and shouldn’t be understated or misrepresented. At the same time, they shouldn’t direct our attention away from the benefits of PFAS in certain production processes.
Because of their chemical resistance and surface tension lowering properties, PFAS are hard and expensive to replace. A complete ban would put the production of these vital consumer items in jeopardy and patient safety at risk. Declaring all PFAS hazardous without first considering risks associated with each use, and considering the feasibility and safety of alternatives, is a dangerous policy path.
In the United States, calls for a complete ban are also dominating the discourse. The PFAS Action Act, which is currently under review in the Senate, fails to consider that all these chemicals carry different risks depending on their use and exposure levels. The European Union’s approach aims to achieve similar outcomes. The idea is to divide PFAS into two groups: essential and non-essential. However, eventually, all are sought to be phased out.
Both strategies turn a blind eye to the uncomfortable evidence-based truth about these chemicals. PFAS have already been largely phased out from being used where they are not necessary. A 2018 Toxicological Profile for Perfluoroalkyls by the Agency for Toxic Substances & Disease Registry says that “Industrial releases have been declining since companies began phasing out the production and use of several perfluoroalkyls in the early 2000s.”
A complete ban on PFAS being used also doesn’t necessarily mean that these man-made chemicals will cease to be produced or sold. The unintended consequence of extremely restrictive policies is a spike in production elsewhere. Bans in the EU and US will likely result in China ramping up their production. And given how necessary PFAS can be for both medical equipment, and consumer goods, an EU or US ban would be simply shifting production to countries who largely fail to meet general standards for environmental stewardship.
It is crucial that while assessing PFAS, policymakers on both sides of the Atlantic do not fall prey to calls for complete avoidance. PFAS are diverse and while some of them might need to be restricted or banned, others are crucial and necessary, as in the case of medical equipment. One size doesn’t fit all, and the necessary uses of PFAS, especially when they don’t pose a risk to human health, shouldn’t be left out of the discourse.
By Maria Chaplia, Research Manager at the Consumer Choice Center and David Clement, North American Affairs Manager at the Consumer Choice Center