On 3 February, the UK government revealed its ‘PFAS Plan’ – setting out the country’s approach to monitoring and regulating per- and polyfluoroalkyl substances (PFAS). The government’s main aims are to improve monitoring and get a better idea of where and how PFAS are entering the environment (and hence who should be held liable for cleanup costs); work with industry to better understand where and how PFAS are used, with a view to reducing non-essential applications; and to prioritise risks and actions that will limit ongoing exposure to PFAS from existing sources – for example drinking water, food and consumer products.
The policy is broadly aligned with measures being negotiated in the EU – although environmental campaigners are disappointed that the UK has not committed to match EU proposals to restrict many PFAS uses, particularly as some other European states are already implementing their own restrictions, ahead of the broader EU decisions.
A January study from the European Commission suggests that the EU’s proposed full ban on PFAS could lower health and environmental costs by €110 billion (£95 billion) between now and 2050 (with total costs amounting to €330 billion, rather than €440 billion under a ‘business-as-usual’ scenario). The largest portion of this reduction is in health costs, predicted to drop from nearly €40 billion/year in 2024 to around €0.5 billion/year in 2050 (compared to €30 billion/year in 2050 under the business-as-usual scenario).
The commission’s report also underlines the significant difference in cost between preventing environmental emissions in the first place and trying to clean them up later. Its scenario that involves treating soil and wastewater to bring PFAS contamination levels in line with extremely stringent proposed EU Environmental Quality Standards (without a ban on production) would cost around €1.7 trillion – the vast majority of which is remediation and wastewater treatment, while health costs would decline more rapidly than in other scenarios, owing to faster drops in exposure.
The Royal Society of Chemistry has been campaigning for the UK government to overhaul its approach to PFAS – particularly in drinking water – for several years, collecting evidence on remediation and monitoring methods, as well as advising on frameworks to better quantify the collective hazards and risks posed by mixtures of various PFAS in the environment, rather than considering each compound individually.
The realistic solution probably lies somewhere between these extremes. Tighter controls on monitoring, reporting and reducing environmental emissions – both in industrial effluents and from products during their use – are clearly needed. Many uses of PFAS could potentially be substituted with other materials. Harsher penalties for PFAS contamination (alongside support for developing alternatives) could encourage users to make changes, even if it means a small drop in performance or cost increase. However, there are critical industry sectors where PFAS are unlikely to be replaceable, owing to their unique combination of properties. In those cases, focusing on containment and remediation of contamination risks at their source will be paramount, given the hugely higher cost of remediation once contaminants reach environmental ecosystems.
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