Today, the high level Conference “Human Biomonitoring for science and chemical policy” is being held in Berlin, under the German EU presidency. It has been organised as part of the HBM4EU research initiative which is generating evidence of the actual exposure of citizens to chemicals and the possible health effects in order to support policy making.
CHEM Trust’s Head of Science, Ninja Reineke, will be speaking at the conference on the theme: “Human Biomonitoring – Moving from late warning to early action”. In her presentation, she stresses that human biomonitoring studies are necessary in particular to check the effectiveness of current regulations and identify needs for policy action.
Results from human biomonitoring studies have shown the need to:
- Avoid future exposures and protect health by stricter chemical controls, but policy action should not depend on the availability of human biomonitoring data.
- Avoid the impression of ´acceptable´ levels of harmful chemicals in people; as these levels tend to be lowered with increasing knowledge about a substance.
- Address the reality of the combined body burden of a mixture of synthetic chemicals.
- Focus on restricting groups of substances such as PFAS.
The group of per- and polyfluoroalkyl substances, PFAS, also known under their nickname ‘forever chemicals’ due to their extreme persistence, is currently high on the policy agenda, due to increasing concerns over health and environmental impacts. An EU action plan on PFAS is expected to be published in the upcoming EU Chemicals Strategy for Sustainability.
EU Human biomonitoring data show that action is long overdue
In 2005, during an EU-wide family biomonitoring survey, WWF found that all participating children had PFOS in their blood, and many of them PFOA.
A recent German Environmental Survey, carried out between 2014 and 2017 on children and adolescents, showed that – although levels had decreased over the last years – there is still considerable exposure of the young generation to the now phased-out chemicals PFOS and PFOA. PFOS was found in 100% of the participants and PFOA in 86%. The youngest participants were born after the restriction of most uses of PFOS in the EU. The presence of the chemical in their blood demonstrates how exposure to PFAS continues even after emissions have ceased, due to their extreme persistence.
This illustrates why every year of delay in the regulation of these highly persistent chemicals means an increasing burden for future generations.
However, so far, only two PFAS out of the 4,730 PFAS substances on the market have been restricted globally via the Stockholm Convention, PFOS in 2009 and PFOA in 2019, and a handful more are restricted at the European level.
Only the tip of the PFAS iceberg
Research suggests that the real total PFAS exposure might be currently underestimated. It is increasingly reported that a significant fraction of organic fluorine occurring in the environment is not accounted for by the targeted PFAS suite routinely monitored. This suggests that more PFAS, than the ones routinely monitored and currently regulated, are present in the environment and in our bodies. Therefore, only a blanket ban on the whole PFAS family could account for all possible PFAS emissions.
EFSA lowers the tolerable daily intake
Experience with the most studied PFAS, eg. PFOA and PFOS, shows that with increasing knowledge, the evidence for harm increases. For instance, looking at the evolution of the estimated tolerable daily intake (TDI) for PFOA by the European Food Safety Authority, the value firstly estimated at 1500 ng/kg bw/day in 2008 was lowered by over 1700 fold in 2018 to 0.86 ng/kg bw/day.
And now EFSA has recommend that the TDI is 0.63 ng/kg bw/day for the sum of 4 PFAS chemicals: PFOA, PFOS, PFHxS and PFNA. This means that what was once considered a safe level of exposure is now considered unsafe.
A PFAS group restriction is the only way forward
Gathering the similar amount of hazard data for all 4,730 PFAS as for PFOA or PFOS would take decades. Allowing these potentially harmful chemicals to build up in our bodies and in the environment while we wait for the data to be generated would be contrary to the precautionary principle.
In CHEM Trust’s response to the call for evidence to support an analysis of restriction options for PFAS under REACH launched by five EU Member States, we emphasise that swift regulatory action is required to put an end to the never-ending cycle of regrettable substitution within the PFAS group and account for all potential PFAS emissions.
In our view this can only be achieved by:
- A group restriction covering all PFAS substances;
- Giving as little derogations as possible;
- Keeping permissible concentration levels as low as possible.
Ninja Reineke, Head of Science at CHEM Trust said:
“Human biomonitoring research has an important role to play to help understand the body burden of people. Regulators need to ensure these findings are swiftly followed by policy action.
In the case of PFAS, considering the irreversible nature of the contamination and the extreme persistence of these chemicals, potential adverse effects related to their exposure could last for generations.
The only way to prevent the exposure of future generations to potentially harmful levels of PFAS mixtures, is to minimise all PFAS emissions as much as possible now by restricting all non-essential uses for the whole group.”
Progressive companies on the move
Progressive companies are already committing to end all non-essential PFAS uses in their products and supply chains and are supporting legislative action on PFAS through the corporate pledge launched by Swedish NGO ChemSec.
CHEM Trust is a signatory to the “Zürich Statement on Future Actions on Per- and Polyfluoroalkyl Substances (PFASs)” (2018).