A new Health and Safety Executive (HSE) report recommends limiting the use of Poly- and perfluoroalkyl substances (PFAS) or ‘forever chemicals’ which are found in the foams that firefighters use to extinguish fires.

In what has been described as being ‘the most comprehensive British analysis’ of these slow to degrade chemicals, the report has identified the most common and most harmful uses of PFAS and sets out control measures to improve their management.

Published on 4 April under the UK REACH framework, the HSE’s Analysis of the most appropriate regulatory management options (RMOA) report also recommends limiting the use of PFAS in textiles, furniture and cleaning products.

As the report notes, PFAS are a ‘broad class of more than 9,000 synthetic, fluorinated organic chemicals’, which can remain in the environment for decades. Not only are they very persistent chemicals, but they are used across hundreds of global products posing a major challenge for those who have to manage them.

‘Due to PFAS being detected in human blood samples, there has been growing concern about both widespread environmental contamination and human health risks from PFAS exposure,’ notes the report.

The HSE, which is the regulator for UK REACH, has worked closely with the Environment Agency to gather information and evidence on how PFAS are used in Britain and to identify what the priorities for action should be, so that the regulators can better control the exposure to people and the environment.

The joint regulatory management options analysis (RMOA) is a preliminary step that is used in the UK REACH framework.

As the report explains, ‘The RMOA aims to collect, combine and analyse information on the intrinsic hazards, uses and routes of exposure to PFAS, as well as consider relevant domestic legislation and international approaches to the management of PFAS. This information enables a clearer view of the risks of PFAS to human health and the environment and derivation of potential regulatory options to minimise the identified risks. While the options suggested focus primarily on the UK REACH framework, others are suggested where appropriate.’

According to the UK REACH database of registered substances which the HSE used to gather information about PFAS manufactured or imported into Great Britain, it is estimated that there are 2,600 to 36,700 tonnes of PFAS substances, across all groups, present on the domestic market.

However, the report notes that this excludes substances that are manufactured or imported at less than one tonne per annum, substances still subject to transitional provisions following the UK’s withdrawal from the EU, and substances incorporated into articles (finished products).

There is evidence of occupational exposure and environmental harm that can come from current firefighting foams, and we can understand the concerns among firefighters. We encourage all affected to work with us in the scoping exercise.

‘The reality is that PFAS substances, due to their persistent properties, will continue to be detected for many years – despite measures being taken to limit, restrict or ban their use,’ explained Dr Richard Daniels, director of HSE’s chemicals regulation division.

‘We will now look at the availability and risks posed by alternatives to ensure maximum long-term protections can be gained.’

Environment Minister Rebecca Pow added: ‘The HSE’s analysis is a key part of our efforts to protect us from these persistent chemicals – our Plan for Water recognises this and we will begin developing proposals to restrict PFAS in firefighting foams this year.

‘This will build on our action to increase monitoring and support a ban or highly restrict specific PFAS both domestically and internationally, so that we can reduce the amount of PFAS entering our natural environment.’

The report notes that the greatest volume of PFAS potentially available on the domestic market come from three main groups, one of which is polyfluoroalkyl substances, including fire suppression systems and firefighting foams.

On the decision to prioritise firefighting foams, the plan is to undertake scoping work with stakeholders, including industry, firefighters and experts with knowledge of alternative foams. The regulators note that similar exercises will take place for other commercial uses of PFAS substances.

Dr Daniels added: ‘There is evidence of occupational exposure and environmental harm that can come from current firefighting foams, and we can understand the concerns among firefighters. We encourage all affected to work with us in the scoping exercise.’

On the issue of finding alternatives, the report concludes that although only a high-level analysis has taken place, the HSE does recognise that there are potential alternatives to PFAS for many uses.

‘However, more performance and socioeconomic information will be required to ensure that alternatives are technically and economically feasible and able to meet performance standards.’

The report notes that hazard information for alternatives also needs further investigation to avoid ‘regrettable substitution’.

‘Potential risk management measures will need to take into account the challenges of substitution and the need for this to take place across different pathways and timescales, in accordance with the releases and exposures across sectors and uses,’ says the report.

The HSE says it will work with the EA as well as the Department for Environment Food & Rural Affairs (Defra) in Scotland and Wales to consider the recommendations and how any action relating to them will be set out in the forthcoming UK REACH Work Programme for 2023-24.

Comment: "The substitution of the current product to reduce or mitigate occupational exposure and environmental harm, will be beneficial in the future."

Source: IOSH Magazine