ChemRegs Newsletter – April 2023
Poly- and perfluoroalkyl substances (PFAS)
There seems to be an increased awareness of PFAS chemicals. Not only within the chemical industry and manufacturing but the media seems to be taking an active interest in these chemicals.
PFAS chemicals, also known as per- and polyfluoroalkyl substances, are a group of man-made chemicals that have been used since the 1940s in a wide variety of industrial and consumer products. These chemicals are known, amongst other things, for their ability to repel water and resist heat.
PFAS chemicals are used in a wide variety of products, some of the most common products that use PFAS chemicals include:
- Non-stick cookware: PFAS chemicals are often used to make non-stick coatings for cookware.
- Stain-resistant carpets and furniture: PFAS chemicals are used to make carpets, furniture, and other textiles stain-resistant and fire proof.
- Waterproof clothing: PFAS chemicals are used to make clothing and outdoor gear waterproof.
- Food packaging: PFAS chemicals are used to make some food packagings, such as fast food wrappers and microwave bags.
- Firefighting foam: PFAS chemicals are used in firefighting foam to extinguish fires when an aircraft is on fire.
- Dental floss: Some dental floss brands use PFAS to make the floss glide more easily between teeth.
- Personal care products: PFAS chemicals can be used in personal care products, such as shampoos and cosmetics, as a foam stabiliser or to make them water-resistant.
One of the characteristics of PFAS chemicals is their persistence in the environment, which means they do not break down easily and can accumulate in soil, water, and wildlife. Some PFAS chemicals have been linked to health problems such as cancer, thyroid disease, and decreased fertility.
As a result of these concerns, some governments and industries are taking steps in an attempt to reduce or eliminate the use of PFAS chemicals in products and processes. However, because of their widespread use and persistence in the environment, PFAS chemicals are still present in many products and are a topic of ongoing research and concern.
The UK government has taken several steps to reduce the use of PFAS chemicals.
In 2021, the UK government launched a public consultation on the use of PFAS in products, with the aim of introducing a ban on the use of PFAS in certain products such as food packaging. The sheer number of substances within the broad PFAS class makes them a challenge to tackle and group, and there is no globally adopted definition of PFAS for human health or environmental regulation.
The Health and Safety Executive (HSE), acting in its role as the Agency for UK REACH and supported by the Environment Agency, has examined the nature of the risks posed by PFAS chemicals and the most appropriate options for management of these risks. This assessment is termed an Regulatory Management Options Analysis (RMOA).
An RMOA is not a legislative or legally binding document. It typically provides an assessment of the likely health and environmental risks associated with the use of a substance or group of substances, alongside the existing regulatory framework and any specific controls relating to them. If there is evidence of significant risks, it concludes with preliminary recommendations for any additional measures within REACH to manage them. Should action be considered appropriate, a detailed risk assessment and legislative proposal for regulatory action will follow an RMOA.
UK REACH is a regulation that applies to chemical substances that are manufactured in or imported into GB. UK REACH applies to all individual chemical substances on their own, in mixtures or in articles. Manufacturers and importers of substances are required to understand the hazards of the substances they are supplying to the GB market. If those substances meet the criteria for classification under the GB Classification Labelling and Packaging (CLP) Regulation or are identified as persistent, bioaccumulative and toxic (PBT) or very persistent and very bioaccumulative (vPvB), manufacturers and importers are required to recommend measures for safe use of those substances.
The RMOA on PFAS chemical s was published on 4 April 2023 and makes a number of recommendations including to limit the use of PFAS-containing foams used by firefighters to put out fires, as well as the use of PFAS in textiles, furniture, and cleaning products.
One of the key proposals is that, due to more comprehensive information being available, fire-fighting foams are prioritised for action. This will be founded on scoping work with stakeholders including industry, firefighters and those with expert knowledge of alternative foams. Similar exercises will take place for other commercial uses of PFAS substances.
HSE, as the Agency for UK REACH, will work with the Environment Agency and the Appropriate Authorities (Defra, Scotland and Wales) to consider the recommendations and how action on these recommendations will be set out in the forthcoming UK REACH Work Programme for 2023-24.
Overall, the UK government is taking a proactive approach to reduce the use of PFAS chemicals and limit their impact on human health and the environment. However, the sheer scale of the task is considerable, as harmful chemicals are found in such diffuse products as nappies to fertilisers.
Addenda to the 64th Edition of IATA DGR
Two addenda to the 64th edition of the IATA DGR have been issued. The addenda will remain effective until 31 December 2023. Users of the IATA Digital DGR will find the content of the addenda automatically updated in the publication.
Addendum 1 was posted 15 December 2022 and became effective from 1 January 2023. It mainly contains new or amended State Variations (Section 2.8.2) and Operator Variations (Section 2.8.4), plus revisions to various sections i.e 3.6.1.1, 4, 5, 8, Appendix D.1. It also amends statement 20 on the Dangerous Goods Checklist for a Non-radioactive Shipment
Addendum 2 was posted 31 March 2023 and became effective from 1 January 2023. It mainly contains new or amended Operator Variations (Section 2.8.4), plus revisions to various sections including Section 2.3.5.8 Portable Electronic Devices (PED) (Including Medical Devices) Containing Batteries and Spare Batteries and Section 5
Packing instruction 952.
Both addenda can be downloaded from https://www.iata.org/en/publications/dgr/
For more information on anything in this Newsletter, please contact us at info@chemregs.co.uk