Non-polymer PFAS can build up in blood protein of animals, and is not always removed quickly. This means that predators eating PFAS-contaminated food will have higher levels in their bloodstream, and concentrations can increase up the food chain. Studies suggest that build up of PFAS is similar to those of other Persistent Organic Pollutants such as DDT.PFAS are estimated to be settling in arctic regions at rates of tens to hundreds of kilograms per year (25-850kg per year), depending on the specific PFAS chemical in question. Certain PFAS are released as gases to the environment and are blown a long way by wind and air currents in the atmosphere,. These gas PFAS will over time degrade to more persistent chemicals like PFOS and PFOA. This may be one reason why PFAS of environmental concern have been found in remote regions such as the Arctic as well as near PFAS production sitesPFAS including PFOS and PFOA have been found in air samples around Europe. The chemicals are found in small quantities, but appear in almost all samples tested. PFAS enters the atmosphere both from factories and the air inside our homes. PFAS is found in treated waste water from industrial and domestic sources and has been found in both rivers and groundwater. Conventional drinking water processes will not remove PFAS.PFAS-coated clothes that are thrown away will often end up either incinerated or in landfill. Unless incinerated at very high temperatures (>1000oC), fluorinated polymers could release more harmful PFAS during burning. PFAS of environmental concern have also been found in landfill leachate. Non-polymer PFAS are used in the production of fluorinated polymers. The manufacture of stain-resistant finishes generally releases these PFASs into the environment, both by air and water emissions. They are very hard to remove during water treatment. Workers in textiles factories are some of the population most exposed to these potentially harmful chemicals. Small quantities of PFAS will be removed during wash and wear of products containing PFAS. This includes fluorinated polymers used on stain-resistant coatings, and non-polymers that remain on clothes after production (Lassen et al. 2015).Most UK waste still ends up in landfill, and this includes PFAS-containing products. Studies have shown that the liquid coming from landfills (known as leachate) often contain non-polymer PFAS chemicals. In the USA the total quantities were estimated at 563-638 kg in 2013. To properly break down PFAS chemicals high temperature (1000oC or more) incineration is recommended. Incineration of municipal waste does not necessarily reach these temperatures (min temp. required is 850oC), and the incomplete breakdown could release non-polymer PFAS.Wash and wear of clothing that contains PFAS-based stain-resistant or water repellent finishes release PFAS to the environment. Coatings are thought to lose effectiveness after 20-30 washes. This can include non-polymer PFAS, remnant from production or as a break-down product of side-chain polymers (Lassen et al. 2015). The manufacture of stain-resistant finishes releases PFAS into the environment, both by air and water emissions. PFAS are very hard to remove during water treatment. Industrial emissions are estimated to be the biggest source of these chemicals to the environment.

UK recommendations to combat PFAS pollution are finally published but are just the first step

The long awaited PFAS Risk Management Options Analysis (RMOA) was finally published earlier this month by the UK’s Health and Safety Executive, working in partnership with the Environment Agency[1].  This has been the culmination of several years work, and makes recommendations of measures to manage PFAS, which have been accepted in principle by the UK Government.

The publication of the RMOA has been welcomed by Fidra, and acknowledged as the first extensive piece of work towards regulation of PFAS by the UK. While the recommendation for PFAS to be grouped and restricted by UK REACH is welcome, Fidra is concerned the definition of  PFAS being used is narrower than in the US or EU, or the broadly accepted OECD definition. This provides the potential for loopholes to be exploited, for example with specific PFAS being restricted but related PFAS such as those used in their manufacture or produced via degradation not being restricted.

Call for wider action on PFAS to include food packaging

Although the approach of addressing groups of PFAS in certain areas such as firefighting foam is welcomed, Fidra is concerned that the range of sectors considered by the RMOA should be wider. In particular, it has not addressed food packaging adequately, with recent research raising concerns about these forever chemicals migrating into food[2]. Rather it has defaulted responsibility for PFAS in food and food contact materials to the Food Standards Agency and Food Standards Scotland, but presently there are no specific restrictions by them on PFAS in the UK. This is a missed opportunity, especially with a wide availability of alternatives already apparent, and a well-established precedent set by Denmark in 2019[3].

There is also a question over whether any coating is needed on a lot of food contact materials. In 2019, The Global PFAS Science Panel released a report on the concept of essential and nonessential uses of PFAS and concluded that “non-fluorinated alternatives have been historically available for all applications of paper-and-board food packaging and the use of fluorinated protective coatings has never been essential”[4].

While it doesn’t preclude action being taken in the future by the relevant agencies, it could have been addressed in the RMOA and therefore removed a source of PFAS into our environment, our food and ourselves. Increasing action is being taken in other nations and by individual companies, and the UK risks falling behind internationally[5].

Time for a detailed timeline

There have long been calls for the UK administrations to move towards a full phase out of PFAS use and production, with the eventual goal of a PFAS-free economy[6]. The Plan for Water released alongside the PFAS RMOA commits to starting a UK REACH restriction proposal on PFAS in firefighting foams this year[7], however this only applies to England, and is just one section of the multitude of areas in which PFAS features.

Fidra and other NGOs would like to see a clear timeline and detailed plan for action to phase PFAS use out of all sectors. With many safe and sustainable alternatives already available, this would encourage the development and adoption of more. The UK Government needs to play a pivotal role in supporting the research and innovation needed to develop and adopt PFAS-free alternatives.

While the RMOA does recommend the development of statutory standards for PFAS in drinking water, this only applies to England and Wales, and only addresses one environmental compartment. Any plan of action going forward must also address the regulation of PFAS in other environments by setting exposure levels for wildlife and people from sources such as food, water and air. Monitoring must also be increased alongside increased regulatory action[8].

The RMOA on PFAS is just a first step onto a long and winding road, and Fidra urges the UK Government to go further, not just through increasing action on these forever chemicals but also through the development of a robust and thorough UK Chemicals Strategy[9]. Strong and definitive action is urgently needed to address the increasing risk from the chemical cocktail in our environment.

References and links


[2] Schwarz-Narbonne, H. et al (2023) Per- and Polyfluoroalkyl Substances in Canadian Fast Food Packaging, Environmental Science & Technology Letters, 10, pp 343-349.


[4] 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, 21, 1803.






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