In a review article published on June 23, 2021, in the peer-reviewed journal Environmental Science: Processes & Impacts, Ian Cousins from Stockholm University, Sweden, and co-authors outline chemical regulations on essential use and similar decision tools and give examples illustrating the application of the essential-use concept with a focus on per- and polyfluoroalkyl substances (PFAS).
Currently, most chemicals management follows a risk-based approach in which chemicals of highest concern are evaluated individually. Considering the high number of chemicals, this approach is very time- and resource-consuming. In contrast, the essential-use concept is seen as a way to help evaluate whether substances of concern, such as PFAS, are essential for a certain use, aiming to provide a more holistic approach. Cousins et al. emphasized that this approach “offers a more rapid pathway toward effective management or phase-out” of substances of concern. In the critical review, the scientists described the three aspects to be considered when determining the essentiality of a particular use case: (1) the function provided by the substance of concern in the use case, (2) the necessity of the function “for health and safety and [whether it is] critical for the functioning of society,” and (3) if the function is necessary, “whether there are viable [not regrettable] alternatives for the chemical for this particular use.”
The article illustrates this step-wise approach by giving several examples, one being the use of PFAS in cosmetics. In cosmetics, PFAS serve as a lubricant (aspect #1), but cosmetics are “not critical to health, safety or the functioning of society” (aspect #2), and chemical alternatives can provide the same function as PFAS (aspect #3). Accordingly, the article concluded that PFAS are not essential in cosmetics. Several brands have already phased out PFAS from their formulations, and a Danish retailer has banned PFAS in all cosmetics sold in its stores (FPF reported).
In one part of the critical review, the authors answer common questions regarding the application of the essential-use concept. When answering “who should apply the essential-use concept?”, the authors suggest not only regulators but also the private and public sectors. To the question “which uses of chemicals are critical for the functioning of society?”, the authors say that these include uses providing food, water, shelter, and security and thus fostering life’s basic conditions, but they also emphasize that further analysis is necessary and judgments on that question are to be made by each jurisdiction or organization.
As summarized in the article, considerations of essentiality of uses are already integrated into legal frameworks on chemicals such as the Stockholm Convention, the Montreal Protocol, REACH, and the EU Biocide Regulation. In addition, the EU’s Zero Pollution Ambition initiative and ambitions towards a circular economy prioritize limiting the use of substances of concern including PFAS. Strategies to implement the concept in practice are currently being researched. The authors believe that the “essentiality of uses as a concept is feasible” even considering the criticism from chemical manufacturers.
Cousins, I.T., et al. (2021). “Finding essentiality feasible: common questions and misinterpretations concerning the “essential-use” concept.” Environmental Science: Processes & Impacts (published online June 23, 2021).
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)