The European Commission has committed to phasing out man-made chemicals called per- and polyfluoroalkyl substances, also known as PFAS. Initially, the European Chemicals Agency was expected to submit its restriction proposal for firefighting foams this month, but the deadline has now been extended until January 2022. For other uses, the deadline is also2022.

On the other side of the Atlantic, the US Congress is attempting to achieve similar goals through the PFAS Action Act, which is now waiting for a final vote in the Senate. Unsurprisingly, the ban was pushed for by green groups, who tend to confuse hazard with risk, and favour the “ban them all” approach.

PFAS can be found – but not limited to – in household items and other consumer products, medical equipment, food packaging, and firefighting foam. Their popularity can be explained by their unique qualities, such as chemical resistance and surface tension lowering properties. PFAS’ effectiveness has made them hard and costly to replace.

“Forcibly removing these chemicals from the production process, especially because they present very little risk to humans, will drastically disrupt supply chains and inflate costs”

At the same time, the use of PFAS has been linked with various adverse effects, such as infertility, thyroid and liver diseases, when improperly dumped into the water supply. These concerns are justified and shouldn’t be understated or misrepresented. However, as with pretty much everything, it is the amount of exposure that counts towards a risk-based assessment, as opposed to complete hazard avoidance. Because there are more than 4700 chemicals that fall into the PFAS group, and they all carry different levels of risk and hazard, we have to be careful not to put them all in the same basket.

The European Union aims to divide these chemicals into two groups: essential and non-essential, but eventually all are sought to be banned. That said, PFAS have already been largely phased out from being used where they are not necessary. A 2018 Toxicological Profile for Perfluoroalkyls by the Agency for Toxic Substances & Disease Registry says that “Industrial releases have been declining since companies began phasing out the production and use of several perfluoroalkyls in the early 2000s.”

There is no guarantee that phasing out PFAS will make us safer. Both EU and US banned bisphenol A (BPA), a chemical found in plastics, in baby bottles on the premise that it carries health risks for kids. However, BPS and BPF that are typically used as substitutes have been found to be anything but harmless. In fact, even low exposure to BPS had a significant impact on the embryos’ development.

A complete ban on PFAS being used also doesn’t necessarily mean that these man-made chemicals will cease to be produced, it just means that other countries like China will likely ramp up their production. And given how necessary PFAS can be for both medical equipment, and consumer goods, an EU or US ban would be quite problematic.

For example, some of these chemical compounds are vital for contamination-resistant gowns and drapes, implantable medical devices, stent grafts, heart patches, sterile container filters, needle retrieval systems, tracheostomies, catheter guide wire for laparoscopy and inhaler canister coatings. To declare all these chemical compounds hazardous, without evaluating the risk associated with each use, puts lifesaving medical technologies in jeopardy and patient safety at risk.

“Policymakers on both sides of the pond should take a risk-based approach towards the regulation of PFAS rather than falling prey to green activists’ calls for complete avoidance”

On the consumer product side, as cell phones and 5G technology continue to grow and require faster speeds at smaller sizes, these compounds are involved in everything from producing semiconductors to helping cool data centres for cloud computing. Forcibly removing these chemicals from the production process, especially because they present very little risk to humans, will drastically disrupt supply chains and inflate costs for the 472 million Europeans who currently use a smartphone.

Policymakers on both sides of the pond should take a risk-based approach towards the regulation of PFAS rather than falling prey to green activists’ calls for complete avoidance. Although some of these chemicals might need to be banned, or restricted, banning them all might end up leaving us with even worse alternatives that might take a greater toll on our health and wellbeing. These chemicals need a very rigid and detailed regulatory approach, but one that avoids the “one size fits all” lens.

Originally published here

British showman and comedian John Oliver, known for his punchy and thorough rants on public policy, has set his sights on a new target: man made chemicals, known as PFAS. In his now viral rant, Oliver explains how PFAS chemicals are problematic for human health and wants all of these chemicals to be declared hazardous by law. This is, in fact, what Congress is attempting to do via the PFAS Action Act, which has passed the House and is waiting for a final vote in the Senate.

While Oliver’s rant does accurately explain some of the serious problems these man-made chemicals present, especially if dumped into waterways and contaminating the water supply, there is a lot that the late night show host misses in regards to how, or why, these chemicals should be regulated.

It is important to note that these chemicals have been largely phased out from being used where they are not necessary. A  2018 Toxicological Profile for Perfluoroalkyls by the Agency for Toxic Substances & Disease Registry says that “Industrial releases have been declining since companies began phasing out the production and use of several perfluoroalkyls in the early 2000s.” In addition to that, a CDC report shows that since 2000, “mean blood levels of PFOS have declined approximately 84 percent and mean blood levels of PFOA have declined about 70 percent,” and recent reports are showing that bodies of water contain only trace amounts of PFAS, and they have been steadily declining. These are all positive developments, and should be celebrated. 

The issue with the “one size fits all” approach, advocated by Oliver and being pushed by Congress, is that this fails to appropriately address the hazards and risks presented by each of the 5000chemicals that fall under the classification of PFAS. This is an important distinction, because the risk that PFAS presents for human health largely depends on how humans are exposed to these chemicals. 

The most popular example is when, decades ago, the man-made chemical C8 was dumped into waterways, causing an array of health issues and substantial lawsuits. This is of course problematic, never should have happened, and should never happen again. That said, the use of other man-made chemicals, which would be classified as hazardous if Congress proceeds down this path, are vital for medical technologies and consumer products, and are used in a way that presents very little, if any, threat to human health.

For example, some of these chemical compounds are vital for contamination-resistant gowns and drapes, implantable medical devices, stent grafts, heart patches, sterile container filters, needle retrieval systems, tracheostomies, catheter guide wire for laparoscopy and inhaler canister coatings. To declare all these chemical compounds hazardous, without evaluating the risk associated with each use, puts lifesaving medical technologies in jeopardy and patient safety at risk. In fact, Congressman Larry Bucshon, who was a heart surgeon, criticized the PFAS Action Act for failing to include a revision that would exempt PFAS use in medical devices, stating that the bill in its current form would jeopardize access to life-saving drugs.

Another major disruption that would occur if the act proceeds as written is it would significantly jeopardize the domestic smartphone market, used by the vast majority of  Americans everyday. As cell phones and 5G technology continue to grow and require faster speeds at smaller sizes, these compounds are involved in everything from producing semiconductors to helping cool data centers for cloud computing. Forcibly removing these chemicals from the production process, especially because they present very little risk to humans, will drastically disrupt supply chains and inflate costs that will hurt low-income people the hardest.

It should be said that lawmakers and late night talk show hosts (yes even them) must realize that regulations are enacted based on risk, and risk is the hazard a substance presents multiplied by the exposure to it. Banning PFAS from being used in the production process for smartphones is akin to banning mercury from being used in thermometers because it is harmful when ingested, or banning chlorine from being used in pools because it is harmful if you ingest it. 

Some bans/restrictions might very well be needed and justified but banning an entire category of evolving products won’t serve the consumer. A more appropriate response would be to evaluate these chemicals and substances based on the risk they present and how they are used, rather than lumping them all together and risk enacting bad policy that will have a myriad of consequences. 

Originally published here