A Systematic Workflow for Compliance Testing of Emerging International Classwide Restrictions on PFAS
By Robin Vestergren, Anders Appelblom, Simona A. Bălan, Sicco H. Brandsma, Thomas A. Bruton, Ian T. Cousins, Jeremy R. Gauthier, Audun Heggelund, Jenny Ivarsson, Anna Kärrman, Lisa Melymuk, Chijioke Olisah, Amanda Rosen, Eleni K. Savvidou, Steffen Schellenberger, Lisa Skedung, Petteri Talasniemi, Tonie Wickman, Jonathan Zweigle, Christian Zwiener, Jonathan P. Benskin
Environmental Science and Technology
August 14, 2024
DOI: 10.1021/acs.est.4c06570
The poorly reversible risks to human health and ecosystems from contamination with per- and polyfluoroalkyl substances (PFAS) have led many researchers and regulators worldwide to call for a classwide ban of these so-called forever chemicals. As part of the EU Chemicals Strategy for Sustainability, the national authorities of five European countries submitted a broad restriction proposal on PFAS under REACH in January 2023. This restriction proposal is unique in its scope by including the vast majority of uses for >10 000 substances that meet the OECD definition of PFAS. (1) In parallel, several countries and multiple states in the United States have proposed or enacted broad PFAS restrictions for all non-essential uses or for specific uses and reporting requirements for a range of consumer products. Although the regulatory frameworks underpinning these restrictions contain many differences, the proposed restrictions have the common objective to ban the intentional use of all PFAS and thus avoid regrettable substitution with other PFAS. Given that the proposed restrictions apply to chemical products and articles (both hereafter termed simply “products”) that are imported from other states, countries, or regions, they may also trigger substitution and an increased demand for supply chain information on a global level. Direct communication with manufacturers and distributors is typically the primary approach for companies to ensure compliance with chemical regulations. Nevertheless, companies and authorities require reliable analytical methods to independently verify supply chain information and capture products that are noncompliant with PFAS restrictions.
A major challenge for compliance testing stems from the sheer number and structural diversity of PFAS, making it impossible for a single analytical method to quantify all PFAS individually. There are, however, a growing number of analytical methods that can indicate the presence of PFAS by leveraging certain characteristics of these chemicals. Building on the recent advances in the analytical chemistry of PFAS, we discuss the currently available analytical methods that can inform compliance testing of PFAS in different products under different regulatory frameworks while highlighting the advantages and remaining challenges associated with these methods. We then illustrate how these methods could be applied in a three-step workflow for the implementation of the PFAS restriction proposal under REACH (Figure 1). Notably, this Viewpoint is not intended to review or comment on individual or classwide PFAS risk assessments that have been carried out by different authorities but rather to present an approach for ensuring compliance with these new laws based on recent advances in analytical chemistry.
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