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‘Forever chemical’ bans face hard truth: Many can’t be replaced
(www.japantimes.co.jp)
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this post was submitted on 21 Oct 2023
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It feels to me like a missing piece in this conversation is any consideration at all for balancing private profits against public costs when weighing whether or not a particular chemical or technology ought to be sold or used.
Yes, they're better for solving the narrow use case of being a fire retardant now and that'll save someone a little bit of money while it's in use vs. using more water or soaps, but what of the costs thereby put on everyone whose drinking water now has that stuff in it and their increased cancer risks over time? Or what if instead of non-stick aluminum cookware, we used seasoned steel and iron cookware and nobody has to die of cancer because DuPont dumps its manufacturing waste in nearby waterways?
I remember having this conversation about fracking fluids and how "economically important" fracking was to the economy at the time, but those wells are tapped in a matter of a year or two and if the neighbor's water is rendered undrinkable, that's a spoiled resource that will remain spoiled for a long, long time- long after the profit is all gone and the well operators have abandoned those wells. If the mess costs more in externalities to others than it creates in profit and value for the people doing it, the thing has net negative value and probably ought not to be done.
The situation is much more nuanced than that. PFAS chemicals are in (almost literally) everything. Your nonslip shoes, your water proof jacket, your stain resistant table cloth, and your fire retardant mattress. On top of that the list of PFAS chemicals that the EPA is looking at is around 70 compounds long and only scratches the surface of all the compounds. The test to detect PFAS is in its 4th draft and can't reliably detect low enough to reach the levels of concern, except in nearly pristine waters, so you can't even detect if you have it in most water. The levels of concern that are being discussed are in the single digit PPT for individual compounds or 70 PPT total PFAS for some health advisory levels. Detection levels on normal waste water are generally somewhere between 50 and 4000 because the test is so sensitive other compounds fry the machine and it has to be diluted.
Another problem is that the thresholds are so low that it's hard to draw any conclusions definitively. It's associated with so many things you could write a novel: altered immune and thyroid function, liver disease, lipid and insulin dysregulation, kidney disease, adverse reproductive and developmental outcomes, cancer, decreased birth weight for infants, infertility, and more. The thing is that the only way to make a more conclusive connection is observing high exposure areas where people were drinking it at thousand times higher than the risk levels, so interpolating down smaller values has a lot of theoretical connections, but few smoking guns.
In general industries are trying to move away from PFAS, but the areas where they can't include things like AFFF foam used for fighting jet fires. Some areas, particularly the military, are unlikely to make concessions as they want the best option available even if a close substitute is available. Your average PFAS using company; however, is moving away from PFAS in general.
EDIT: also the quantity of PFAS in most items is so small that it actually is below the threshold on an SDS for requiring it be reported, so trying to find out if a product you use has PFAS means you have to call the manufacturer. Maybe they can tell you, maybe they don't want to tell you, or maybe they don't know because it's not listed on the SDS for the raw ingredients they use. In the industry it's gotten into a near legal situation where companies are telling their suppliers and vendors to look for PFAS and certify that their products don't have it, only for the vendor to turn around and do the same for their vendors and suppliers. The portion at the end of the article captures this well, an example would be, "Well we don't use PFAS, but our machine has gaskets which probably have PFAS. This doesn't touch the final product so are we able to use it?"
Yes, this is more or less the circumstance we arrive at when the burden of proof for consumer safety is on injured parties to prove the particular thing unsafe, or its use negligent after the fact, in courts against often powerful corporations with lots of money to spend defending themselves, as opposed to the burden being on would-be sellers to prove its use safe and environmentally responsible before bringing it to market.
I appreciate your post, it really is informative, and it explains how problematic it will be to connect injured parties with the people that harmed them, how now that some people depend on those things and will accept no substitute and will continue emitting more of it into the environment, that the rules as they are don't provide real remedy or solutions for problems that were perfectly legal to create and everyone involved did nothing wrong.
That right there, really, prompts the question- would we really be that much worse off if we had consumer safety rules that put the burden of proving a product or technology's safety and sustainability on the seller, or on some sort of product safety testing system?
If that were to mean industrial chemicals had to undergo trials or studies in the way that pharmaceuticals do, sure there probably would be fewer new things. OTOH if there had to be even the most-rudimentary plan for the lifecycle of a product up front, maybe we wouldn't have millions of tons of discarded plastics or forever chemicals in the environment that everyone knows there's no money to clean up (because our system protects those that profit by externalizing costs).
Great post, but just throwing this out there. Teflon was invented in 1938 and brought to the commercial market in 1948. PFOA is one of the top 2 legacy PFAS chemicals under scrutiny and is a chief ingredient in the manufacture of PTFE (Teflon). PFOA wasn't noticed at all until 1968 and links to health impacts weren't noticed until 1999.
This specific chemical existed before many of the consumer protection laws we have today, but even if those laws had been in place it would have likely been decades before we had made the connection. 20 - 60 years to test a new chemical is a long long time.