HSE call for evidence — PFAS firefighting foams

The HSE is gathering information and evidence relating to firefighting foams which contain per- and polyfluoroalkyl substances (PFAS).

PFAS 

These substances are highly fluorinated aliphatic molecules. They are stain, water and grease repellent chemicals. Along with firefighting foams PFAS are present in a wide range of every day products including fast food packaging, non-stick kitchenware, fabric waterproofing treatments and cosmetics. They are extremely stable compounds meaning that they are persistent in the environment and break down very slowly. 

Concerns over possible health and environmental effects relating to the production and use of PFAS surfaced in the early 2000s. A US EPA spokesman stated that PFAS could potentially pose a risk to human health and the environment for the following reasons: evidence of prolonged environmental persistence; detection of PFAS in human and wildlife tissues; and demonstrated toxicity in rodent studies. Humans are exposed to PFAS through contamination of water sources and accumulation in animals consumed. When ingested PFAS are easily absorbed through the gut and are not metabolised. Exposure may also occur through directly touching consumer products followed by hand to mouth contact or by ingesting indoor dust. 

Consultation background 

In April 2023 the HSE published a regulatory management option analysis (RMOA) in relation to PFAS. This document concluded that PFAS pose a concern to the environment and human health because of their persistence in the environment, the potential for a high level of mobility leading to widespread dispersal, and risk of contamination including to the water environment, and long-term adverse impacts to the environment and human health.  

Due to significant emissions to the environment arising from the use of PFAS in firefighting foams, this issue was prioritised first. A primary recommendation within the RMOA was the initiation of a restriction proposal.  

In March this year the HSE (as the agency for UK REACH which regulates the access of chemicals to the Great Britain market) received a request from Defra to prepare an Annex 15 restriction dossier assessing the risks to the environment and human health from PFAS in firefighting foams. This will be prepared in collaboration with the Environment Agency. The dossier will include information on the hazard and risk, as well as alternatives, and will examine whether a restriction should be introduced into Great Britain covering the use of PFAS in firefighting foams. 

A restriction can be taken under UK REACH to manage the risk from a substance. The first step is to produce a dossier of technical information (Annex 15 dossier). As part of this, the HSE will gather data regarding hazards, uses, exposures etc. with the call for evidence part of this data-gathering.  

Call for evidence 

The HSE’s call for evidence is targeted at manufacturers, importers, distributors, retailers and professional users of firefighting foams, trade associations, environmental organisations and consumer organisations.  

The HSE states it is interested in: 

• Manufacture of firefighting foams: substances used, process, quantities

• Import of firefighting foam products of all types: quantities, suppliers

• Use: quantities, sector of use, frequency, storage on site, products used

• Alternatives to PFAS in firefighting foams: availability, cost, performance in comparison to PFAS-containing foams, barriers to switching

• Hazardous properties: safety data sheets, new studies on intrinsic properties and exposure, recommended risk management measures

• Environmental fate: what happens to the foam after it is used, where does it go?

• Waste: disposal requirements, recycling opportunities, remediation

• Standards: including product specific legislation, performance, certification.

The information provided by stakeholders will be used to support the development of a UK REACH restriction report on risks to human health and the environment, or unintended consequences, arising from the use of PFAS in firefighting foams. The HSE states it is aware that there are certain classes of fire where effectiveness and availability of alternatives are a concern. The HSE requests details on this so information can be used.  

The consultation closes on 24th June 2024. Further information can be found here.