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Context - PFOA is a compound used in the production of materials with water- or oil-repellant properties, such as waterproof fabrics and non-stick cookware.
Is its presence in finished products a risk?
This is a faithful synthesis and summary of several scientific consensus reports. For the full list of sources, see the references.
PFOA, or perfluorooctanoic acid, is a compound that is used in the production and processing of some plastics (fluoroelastomers and fluoropolymers). It is used mainly to make products with water and oil-repellent properties such as waterproof fabrics or non-stick cookware.
It is also formed by the decomposition of these fluoropolymers in their applications or in the environment. Because it contains very stable chemical bonds between carbon and fluorine, PFOA itself is not biodegradable in the environment.
PFOA is identified as a “substance of very high concern”, since it is classified as a “PBT”, or Persistent, Bioaccumulative and Toxic substance, as it indeed persists in the environment and can bioaccumulate in organisms . This leads to a situation where no safe levels of exposure can be established; therefore emissions of PFOA are to be minimised.
PFOA has been linked to a number of health problems in humans, including diagnosed high cholesterol, ulcerative colitis, thyroid disease, testicular cancer, kidney cancer, and pregnancy-induced hypertension, and animal studies indicated adverse developmental effects. For the US-EPA’s Scientific Advisory Board, there is “suggestive evidence of carcinogenicity, but not sufficient to assess human carcinogenic potential”, and in the European Union PFOA has a legally-binding classification as carcinogen (category 2) and reprotoxic (category 1B).
Even if the largest PFOA releases from use is reported for waterproof products like professional carpet-care liquids and household textiles, the general public is mainly exposed to PFOA by consumption of contaminated water and food. PFOA has been detected in human blood and breast milk and can stay in the body for a number of years.
Nevertheless, exposure to PFOA from consumer articles is considered to be extremely low (negligible), and according to the RAC/SEAC report PFOA, on the basis of existing data, risks have not been identified for non-occupationally exposed human populations due to direct toxic effects of PFOA.
Unclear adverse effects and uncertainties in dose-response on decreased birth weights or cholesterolemia, and epidemiology studies on other endpoints (e.g. immunotoxicity) were also considered not robust enough to be included in a quantitative assessment characterisation. Based on limited monitoring data there is however a potential concern for workers at fluoropolymer production sites.
For the environment, even if PFOAs can stay in the environment for a long time, there seems to be no risk for the aquatic, terrestrial and atmospheric compartment.
The groups of PFOA-related substances of greatest concern are fluoro-telomers and side chain fluorinated polymers, which are used in fire-fighting foams, grease-resistant food packaging, leather protectants, and stain-resistant carpeting and textiles. Consumer products for which PFOA-APFO is used in their production include non-stick cookware and kitchen utensils, tread sealants and tapes, water-proof textiles, dental floss and tape, some types of tubing.
The use areas of biggest concern when it comes to potential EU emissions of PFOA are (imported) textiles, and fire fighting foams. PFOA-based paints could also potentially be an important source of emissions to the environment during their application and service life.
PFOA uses have been observed to progressively decrease over time due to both implementation of previous regulations and the voluntary commitment among some producers to stop using so-called “C-8 chemistry”, including PFOA and the PFOA-related substances. However it does not cover all producers and clearly not the importers of treated textiles, which are considered to be a major source of emission of PFOA to the environment.
A restriction covering all emission sources is the way considered to be the most appropriate EU wide measure that can effectively reduce emissions of PFOA and PFOA-related substances , this restriction targeting in particular articles and mixtures.
The aim of the proposed new restriction is to stop all intentional uses of PFOA and PFOA-related substances, or reduce them below a defined threshold in products still in use and existing uses for which substitution is not technically feasible.
The restriction proposal includes ‘PFOA-related substances’, i.e. substances that, based on their molecular structure, are considered to have the potential to degrade or be transformed to PFOA. It would effectively capture the substances considered to be of concern, but exclude those that are not; the overall intention being to minimise emissions. The objective of the proposal is also to allow the use of the fluoropolymers when they are not manufactured with PFOA.
This restriction seems applicable in practice with the recommended changes in concentration limits, derogations and transitional periods, and the costs appear proportionate.
Many specific derogations were requested and the EU RAC/SEAC Committees admitted those for use in implantable medical devices and textiles, photographic and semiconductor (a.o. photolithography processes) applications, and for substances as isolated intermediates for further processing, provided they are transported and used under strictly controlled conditions. Existing fire fighting foams would be exempted from the proposal for 20 years, their normal lifetime.
There are now alternatives to PFOA. The main ones are shorter-chain length fluorinated substances and non-fluorine containing substances are also available for some applications, but they may be less efficient in some situations.
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