The Concept of Essential Use for Determining When Uses of PFAS can be Phased Out
Our peer-reviewed article establishes a framework for identifying when a use of chemical may be considered “non-essential” from a societal point of view. Our starting point is the definition of “essential use” as set forth under the Montreal Protocol on Substances that Deplete the Ozone Layer:
A controlled substance qualifies as essential only if:
It is necessary for the health, safety or is critical for the functioning of society (encompassing cultural and intellectual aspects), and
There are no available technically and economically feasible alternatives or substitutes that are acceptable from the standpoint of environment and health.
We propose three essentiality categories:
| Category | Definition | PFAS Examples |
|---|---|---|
| (1) Non-essential | Uses that are not essential for health and safety, and the functioning of society. | Most consumer textiles, cosmetics, ski waxes |
| (2) Substitutable | Uses regarded as essential because they perform important societal functions, but where alternatives have been developed so that those uses are no longer essential | Firefighting foams, floor coverings |
| (3) Essential* | Uses considered essential because they are necessary for health or safety or other highly important purposes and for which alternatives are not yet in place | Certain medical devices, occupational protective clothing |
*Essentiality should never be considered permanent; rather, a constant pressure is needed to search for alternatives and to move these uses into the substitutable category.
The ‘essential use’ concept has been taken up by the European Union as a guideline for addressing PFAS. Five European countries (the Netherlands, Germany, Sweden, Denmark, and Norway) have joined together to develop a proposal for a restriction under the REACH Regulation. The proposed restriction is expected to require a phase out of all non-essential uses of PFAS by 2030.
An overview of the uses of per- and polyfluoroalkyl substances (PFAS)
This research report fills a critical gap in information by providing a broad overview of how the thousands of PFAS inventoried so far are actually used –a compilation that so far has been missing. It documents the many use categories and the individual PFAS that have been employed, the functions of PFAS in those different applications, and the magnitude of the uses. It demonstrates that PFAS are used in almost all industry branches and many consumer products. In total, more than 200 use categories and subcategories are identified for more than 1400 individual PFAS. The identified use categories include such well-known categories as textile impregnation, fire-fighting foam, and electroplating, as well as many categories not previously described in the scientific literature.