What are PFAS?

PFAS is an abbreviation for per- and poly-fluoroalkylated substances.

• They are a very large group of thousands of man-made chemicals that have multiple fluorine atoms attached to a carbon chain. 
• The Organisation for Economic Co-operation and Development (OECD) define PFAS as fluorinated substances that contain at least one fully fluorinated methly or methylene carbon atom (without any H/C/Br/l atom attached to it), i.e. with a few noted exceptions, any chemicals with at least a perfluorinated methly group (-CF3) or a perfluorinated methylene group (-CF2-) is a PFAS (see the OECD Portal on Poly Fluorinated Chemicals for a comprehensive Global Database of PFAS).
• PFAS have been used in industrial and consumer products since the 1950s due to their physical and chemical properties. These properties include water and oil resistance, chemical and heat stability, friction reduction and surface tension lowering (also known as surfactant properties - results in increased spreadability of materials).
• They can be found in many everyday products – outdoor clothing and equipment, textiles, paints, food packaging, photographic coatings, non-stick coatings on cookware as well as fire-fighting foam.
• They can have harmful effects on human and animal health and stay in the environment and in our bodies for long periods of time where they can increase in concentration. They are often referred to as “forever chemicals”.
• Some PFAS have been linked to an increased risk of cancer, high cholesterol, reproductive disorders, hormonal disruption (also known as endocrine disruption) and weakening of the immune system. For further details see the European Environment Agency briefing Emerging chemical risks in Europe — ‘PFAS’ — European Environment Agency (europa.eu) and the HBM4EU_Policy-Brief-PFAS.pdf.
• Human and environmental exposure to PFAS can arise from contaminated water and food, PFAS-containing consumer products, household dust and air as well as the reuse of PFAS contaminated sewage sludge as fertiliser resulting in PFAS pollution in soil and crops.

What is being done about the use of PFAS?

1. PFAS restriction

Three PFAS are currently restricted under the international Stockholm Convention on POPs and the EU POPs Regulation.

• PFOS (perfluoroctanesulfonic acid) and its derivatives since 2009/2010.
• PFOA (perfluorooctanoic acid), its salts and related compounds, as of 4th July 2020. The current list of PFOA and PFOA-related substances is available in the links below. Please note that this list is under review at a European level and will be updated when more information becomes available.
• Time-limited exemptions exist for some specific uses of PFOA including PFOA in fire-fighting foam, photolithography and in semiconductor manufacturing and in invasive and implantable medical devices, until July 2025. Further details of the allowed exemptions are provided in the table at the end of this page. If availing of an exemption, contact the EPA at pops@epa.ie.
• If you have stockpiles containing PFOA or PFOA-related substances on site, with an aggregate volume of >50kg and above threshold concentrations you must notify the EPA annually. The concentrations are:

>0.025 mg/kg for PFOA and its salts; and
>1 mg/kg for any individual PFOA-related compound or a combination of PFOA-related compounds.

The deadline for receipt of reports of stockpiles was extended to 30 November 2021. (Any stockpiles that have not already been reported to the EPA, must be reported as a matter of priority).  Access to the PFOA reporting system is via the EPA’s Environmental Data Exchange Network portal. The information requested includes details of:

• Stockpile nature/use – for example installed within fire suppression systems (including fire extinguishers), medical device etc., please note – may be a combination of uses;
• Concentration of PFOA and/or PFOA-related substance(s) within each stockpile component (the 50kg limit refers to an aggregate weight and so may be made up of “sub-stockpiles”);
• Location & quantity of stockpile;
• Contact details of person(s) making the notification;
• How the stockpile is managed and stored; and
• Disposal details where sent off site for disposal - the following contractors are licenced by the EPA to handle hazardous waste and may be able to offer physio-chemical treatment of POPs waste (there may also be others):
  • Indaver Ireland limited
  • Enva Ireland Limited
  • Veolia Environmental Services Technical Solutions limited
  • Rilta Environmental Limited

Further information on reporting can be found in the EPA’s factsheet on PFOA in fire-fighting foams and in our frequently asked questions. See our PFOA information leaflets for specific guidance for Suppliers and Users of Foam Fire Extinguishers.

• PFHxS (perfluorohexane sulfonic acid), its salts and PFHxS-related compounds, as of 28^th August 2023.

The current list of PFHxS and PFHxS-related substances is available in the links below.

• • Unlike PFOA, no time-limited exemptions exist for PFHxS, therefore production and use of PFHxS is prohibited.
  • Where PFHxS is not intentionally included in the manufacturing process but rather arises as an impurity or unintentional by-product the following Unintentional Trace Contaminant (UTC) levels for PFHxS apply:
    • Substances, mixtures and articles - 0.025 mg/kg for PFHxS (including it salts) and 1 mg/kg for individual PFHxS-related compounds or a combination of those compounds.
    • Where present in concentrated firefighting foam where the above limit values cannot currently be met, a higher UTC currently applies as follows: 1 mg/kg for PFHxS, its salts and PFHxS-related compounds. It is planned that this UTC for firefighting foam will be reviewed by the EU in 2026.
  • If you use firefighting foam or have stocks of firefighting foam (including handheld foam fire extinguishers), you are required to ensure that:
    • the foam was not intentionally manufactured with PFHxS. This information should be available from the manufacturer/supplier. Use of such foam is prohibited and you should arrange for it to be disposed of using a waste contractor licensed to handle hazardous waste. You are advised to replace it with a fluorine-free (PFAS free) foam.
    • the foam does not contain unintentional concentrations of PFHxS above the UTC of 0.1 mg/kg. You may need to get the foam tested if test results for PFHxS are not readily available from the manufacturer/supplier of the foam. If the foam contains PFHxS above the permitted concentration, it’s use is prohibited and you should arrange for it to be appropriately disposed of using a waste contractor licensed to handle hazardous waste. You are advised to replace it with a fluorine-free (PFAS free) foam.

Other PFAS are restricted or are being evaluated for under the UN Stockholm Convention and the EU REACH Regulation with some summary information below. For full details and updates refer to the websites of the European Chemicals Agency and the Stockholm Convention.

• Canada has proposed to list long-chain perfluorocarboxylic acids (PFCA’s) (C9-C21), their salts and related compounds in the UN Stockholm Convention. Further details are available on the Stockholm Convention’s website.
• Germany, the Netherlands, Norway, Sweden and Denmark, are proposing a ban on all PFAS, except for essential uses under the REACH.  This is referred to as the proposed Universal PFAS restriction.  
• Germany has proposed to restrict PFHxA under REACH. The proposal is now being scrutinised by the European Parliament and Council before it can be adopted.
• ECHA submitted a proposal to restrict the use of PFAS in fire-fighting foams in January 2022. EU Member States and the European Commission will make the final decision on the restriction.
• Certain long-chain perfluorocarboxylic acids (C9-C14 PFCA’s) have been restricted under REACH. The restriction started applying from February 2023.
• A number of PFAS are on the REACH candidate list of substances of very high concern (SVHC). Most recently HFPO-DA (GenX), PFBS and PFHpA were added.
• The EU Green Deal Chemicals Strategy for Sustainability has prioritised the regulation of PFAS as a chemical group.

2. POPs National Implementation Plan

The EPA’s Action Plan on POPs within the POPs National Implementation Plan includes several tasks relating to PFAS that are designated as POPs which are completed or underway including:

• Determine the extent of the risks posed by PFAS in fire-fighting foam or PFAS in landfill leachate.
• A Priority and Priority Hazardous Substances Scoping Study carried out in 2017 and 2018 detected PFAS in some rivers, lakes and fish.
• Since 2019, the EPA routinely monitors water for PFOA, as well as PFOS, as part of the Water Framework Directive monitoring of rivers and lakes. Findings are reported on through the Chemical Chapter in the EPA Water Quality Report and data available on www.catchments.ie
• In 2020, the EPA monitored groundwater and detected very little PFAS.
• More detailed analysis of potentially higher-risk waterbodies for PFAS is underway.
• A coordinated approach across the EPA and with external public bodies in monitoring the environment for PFAS.
• Awareness raising across the EPA, with other public bodies and stakeholders and with the public about POPs, in particular, newer POPs such as PFAS.

3. PFAS in fire-fighting foams

PFAS are commonly used in fire-fighting foams, particularly ‘Class B’ foams which are used to combat flammable fuel fires but this is now changing with a phased switchover to fluorine-free foams.

• • The EPA carried out a desktop study and survey in 2020 on the use of PFAS foams in Ireland which highlighted the wide-range, and often large volumes of PFAS-containing foams used by industry and fire services. This report includes information on PFAS-free and PFAS-containing fire-fighting foams and is available below. Read some examples of PFAS-free foams.
  • The EPA also undertook in 2020 a study to investigate potential hotspots for PFAS contamination from fire-fighting foams. Water, soil, sediment and vegetation samples were obtained from four fire-training sites. Exceedances of adopted human health, environmental quality and ecological screening criteria were detected, mainly in water samples.
  • The EPA are continuing to engage with industry and the fire services about the use and disposal of PFAS foams.  Read more about the PFOA concentration of selected fire-fighting foams.
  • Further work is underway by the EPA to assess the risks posed by the release and disposal of PFAS-containing foams and to identify additional high-risk sites.
  • The European Commission DG Environment and ECHA published a report on the use of PFAS and fluorine-free alternatives in fire-fighting foams in 2020.
  • ECHA submitted a proposal to restrict the use of PFAS in fire-fighting foams in January 2022. EU Member States and the European Commission will make the final decision on the restriction. Up to date information on the status of the proposal is available on ECHA’s website.

   

   

4. EPA-funded PFAS research

Several EPA-funded research projects have assessed the risks posed by PFAS to human health and the environment in Ireland. For example:

• The ELEVATE study investigated human exposure to PFAS with PFAS being identified in indoor air and dust, drinking water and human milk samples. Levels of PFAS in human milk did not represent a health concern for nursing infants but modelling indicated that adult exposure for PFAS may exceed the provisional EFSA tolerable weekly intake value or TWI. The researchers recommended further studies on dietary exposure to PFAS in Ireland.
• The FUEL study investigated the risk posed from PFAS in landfills. Landfill leachate and the surrounding air, soil & groundwater were investigated for PFAS. A potential risk of PFAS contamination from landfills to the surrounding groundwater was identified as well as to waterways and land from disposal of leachate via waste water treatment plants. Further monitoring of landfills was recommended.

Find out more

PFOA restriction under EU POPs Regulation

EU report on the use of PFAS and fluorine-free alternatives in fire-fighting foams

EEA Emerging chemical risks in Europe - PFAS

ECHA - Perfluoroalkyl chemicals (PFAS)

European Green Deal Chemicals Strategy

EU Drinking Water Directive (EU) 2020/2184

EPA Water Framework Directive Datasets

EPA report on PFAS in fire-fighting foams

EPA report on PFAS and BFR monitoring at fire-training sites

EPA-funded POPs research projects: ELEVATE, FUEL, SAFER, WAFER

Current list of PFOA and PFOA-related substances

Current list of PFHXs and PFHxS-related substances

Examples of PFOA concentrations in selected foams

Living healthily in a chemical world — European Environment Agency (europa.eu)

Examples of fluorine-free foams

EPA’s water Quality Report 2016-2021

Information for Suppliers of Foam Fire Extinguishers – PFOA information leaflet 1

Chemical Information for Users of Foam Fire Extinguishers – PFOA information leaflet 2

For any queries relating to PFAS, please email pops@epa.ie

Specific exemptions on PFOA, its salts and PFOA-related compounds