An article published on June 17, 2019 by Natacha Cingotti, Senior Health and Chemicals Policy Officer at the non-governmental organization (NGO) Health and Environmental Alliance (HEAL), discussed the concept of “essential use” proposed to be used “as a driver to more health-protective and efficient regulation of per- and polyfluoroalkyl substances [(PFAS)].” The proposal was put forward by an international group of twelve scientists in a manuscript published in the peer-reviewed journal Environmental Science: Processes & Impacts on May 28, 2019.
Currently, PFAS “encompass no less than 4700 substances” which are used because of their water and grease repellent properties in a wide variety of products “from textiles to food contact materials, cosmetics, medical devices, or firefighting foams.” However, PFAS are “highly persistent in the environment” (FPF reported) and exposure to PFAS has been linked to “a number of serious health impacts such as lower birth weight and size, reduced hormone levels and delayed puberty, decreased immune response to vaccines, obesity, testicular and kidney cancer, liver malfunction, hypothyroidism, [and] high cholesterol,” Cingotti summarized. A few PFAS are banned through the Stockholm convention, however, in general the pace of PFAS regulations has been slow (FPF reported).
The scientists propose to define the following three use categories: (1) “uses not essential for health, safety, or functioning of the society,” (2) “uses performing important functions but for which equally performant and safer alternatives exist,” and (3) “uses considered essential because they are necessary for health, safety, or other important societal purposes AND alternatives are not yet available.” Evaluating PFAS from this perspective could help speed up the issuing of PFAS regulations, as it allows quickly identifying substances that could be eliminated (non-essential use) or substituted (essential use with safer alternatives available), as well as substances that could be subject to exemptions (essential use with no safer alternatives available).
HEAL praised the “essential use” approach and commented that it “could inspire current discussions on the identification of PFAS and the future regulation of other groups of substances of concern.” In contrast, the PFAS trade association FluoroCouncil criticized the proposal due to “flawed assumptions about PFASs,” as editor Andrew Turley summarized in an article published on June 20, 2019 by regulatory news provider Chemicals Watch. According to Turley, FluoroCouncil’s executive director Jessica Bowman said that “this ‘essentiality’ argument perpetuates the inaccurate and misleading notion that all PFASs are the same, and that all PFASs present some inherent risk.” Bowman commented on defining the PFAS use in medical devices as “essential” and the use in dental floss as “non-essential” and said that “both use fluoropolymers, which – because of their physical and chemical properties – are inert and are not bioavailable, and thus present no significant toxicity concerns, regardless of their end use.”
Natacha Cingotti (June 17, 2019). “Scientists propose concept of ‘essential use’ to organize phase out of PFAS and other groups of chemicals of concern.” HEAL
Andrew Turley (June 20, 2019). “Exempt ‘essential uses’ to accelerate PFAS phaseout, experts say.” Chemical Watch
Cousins, I.T., et al. (2019). “The concept of essential use for determining when uses of PFASs can be phased out.” Environmental Science: Processes & Impacts (published May 28, 2019)