The report “Analyse des risques de présence de per- et polyfluoroalkyles (PFAS) dans l’environnement” (“Risk Analysis for the presence of per- and polyfluoroalkyles (PFAS) in the environment”) (1) was finally published on April 14, 2023 and said that the subject of potentially concerned pesticides is very poorly documented “which would justify arranging a survey of manufacturers”. Robin des Bois has already noted that the ECHA (European Chemicals Agency) in its document covering the restrictions on the use of PFAS (2) and in particular in its Annex (3) cites in the Biocides and Pesticides categories 49 active substances approved by the European Union and covered by the current definition of PFAS (listed below). For pesticides, the ECHA estimates that 5,479 tonnes of PFAS are used each year in the European Union. The prohibition of PFAS in pesticides would remove 200 products from the market, which is not currently advised by the ECHA.
The report does not mention PCBs or other highly persistent substances such as organobromines. Isolating PFAS among industrial problems amounts to fall victim to the Top Ten mania and refuse to consider the “cocktail effect” of all the immunosuppressants, endocrine disruptors, carcinogenic, mutagenic and reprotoxic poisons. When Robin des Bois was heard by the authors of the report, it underlined the need to put in parallel and synergy PFAS and PCBs in the introductory remarks. But the authors attribute exceptional mobility in the environment to PFAS and underestimate the mobility of organochlorines (including PCBs) and organobromines (including PBDEs used as flame retardants). Yet, for more than 20 years, scientific reports have accumulated and prove that terrestrial and marine animal species such as otters, polar bears, sea birds and their eggs, eagles, sea turtles, sharks, eels, seals, whales, are contaminated by PCBs, PFAS, and PBDEs all over the world and even in the most remote regions and oceans.
The report highlights that the Seine-Normandy Basin, the Orge River and the Marne River are contaminated by PFAs. These tributaries of the Seine and the Seine from Paris to the estuary are also known to be contaminated by the PCBs, and for this reason they have been subjected to bans on fishing and fish marketing for the past 15 years. The singling out of PFAS goes against the innovative doctrine of the exposome, which aims to quantify the cumulative effects of persistent pollutants in both humans and animals.
The report falls into the trap of media coverage by saying the only documented case was unveiled by a television program aired in May 2022. In fact, the case of Pierre-Bénite (near Lyon, France) and PFASs is the subject of at least 3 scientific reports and studies in 2011 (4), in 2012 (5) and in 2016 (6) by experts from Anses (French Agency for Food, Environmental and Occupational Health Safety). The 2012 study suggests that annually, 14 tonnes of PFAS are dumped [into the Rhône], while the one from 2016 suggests that annual total is 6 tonnes. The problem is that, in keeping with an old French retention habit, the names of the river and the village were blurred in this document, thus the communities and the population concerned were not informed at the moment of publication. This shared omerta between the scientific and political world has, in this particular case, impeded the mayor of Pierre-Bénite from fulfilling his obligations. The PFAS report points out that, pursuant to the order of July 21, 2015, the mayors or presidents of Public bodies for Inter-municipal Cooperation have the obligation to implement within their territory the principals of preventing and reducing pollution at its source, particularly with regard to micropollutants. In the case of Pierre-Bénite and the two factories Arkema and Daikin producing PFASs in the industrial park, the mayor was not informed until 2022. The Rhône basin has also been affected by PCB contaminants for many years and a share of fishing restrictions and bans. Recreational fishers, who despite the prefectoral orders, consume fish from the Rhône and many other tributaries ingest at the same time PCBs and PFASs.
(1) Analyse des risques de présence de per- et polyfluoroalkyles (PFAS) dans l’environnement (Analysis of the risks of the presence of per- and polyfluoroalkyls (PFAS) in the environment), Hugues Ayphassorho, Alby Schmitt, IGEDD, published on April 14, 2023
(2) Annex XV Restriction Report. Proposal for a Restriction. Per- and polyfluoroalkyl substances (PFASs), ECHA, published on March 22, 2023
(3) Annex to the Annex XV Restriction Report. Proposal for a Restriction. Per- and polyfluoroalkyl substances (PFASs), ECHA, published on March 22, 2023
(4) Rapport sur la Campagne nationale d’occurrence des composés alkyls perfluorés dans les eaux destinées à la consommation humaine. Ressources en eaux brutes et eaux traitées, Anses – Laboratoire d’hydrologie de Nancy (Report on the national campaign for the occurrence of perfluorinated alkyl compounds in water intended for human consumption. Raw and treated water resources, Anses – Nancy Hydrology Laboratory), published in May 2011
(5) Relationship Between Industrial Discharges and Contamination of Raw Water Resources by Perfluorinated Compounds. Part I: Case Study of a Fluoropolymer Manufacturing Plant, Xavier Dauchy, Virginie Boiteux, Christophe Rosin et Jean-François Munoz, published on June 16, 2012 inBulletin of Environmental Contamination and Toxicology, volume 89
(6) The impact of two fluoropolymer manufacturing facilities on downstream contamination of a river and drinking water resources with per- and polyfluoroalkyl substances, Cristina Bach, Xavier Dauchy, Virginie Boiteux, Adeline Colin, Jessica Hemard, Véronique Sagres, Christophe Rosin et Jean-François Munoz, published on December 17, 2016 in Environmental Science and Pollution Research, volume 24
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