Email Enquiry - DEFRA Consultation Doc

Initial Email Enquiry –

Please click the link below to access the latest release from DEFRA on PFOS. There is a link to the consultation document provided. Please use the link to access the document 'on line' and feedback to DEFRA your views (UK organisations only) on the proposals.

As JOIFF secretary I ask all members (Including none UK) to provide me with feedback on the consultation document so that a JOIFF consultative feedback stance is provided to DEFRA as views representative of our industry.

It is IMPORTANT that you take the time to complete this as the outcome of the consultation process may have direct implications to YOU and your organisation.

Click here to download the latest release from DEFRA on PFOS

End of email correspondence on Topic to date

Author’s identities are concealed for privacy and security reasons. Further information on the information contained in this topic can be directed to the JOIFF secretariat.

--

Initial Email Enquiry –

• On 16 May 2000 3M announced they would stop producing the fluorosurfactant Perfluorooctane Sulphonate (PFOS) due to concerns about potential damage caused to the environment.
• As a result of that announcement the EU instructed the UK government to undergo a PFOS Risk Reduction Strategy to limit any potential damage. Once the strategy had been ratified it would then become EU/UK law.
• A working group was set up under the auspice of Defra (The Department of Food and Rural Affairs) and using third party independent consultants (RPA & BRE) they set about researching the risk reduction options.
• At an early stage it was agreed by all that PFOS was a PBT (persistent, bio-accumulative and toxic) substance and therefore would have to be carefully but vigorously controlled.
• During the research however there was some doubt cast over the "safety" of the alternatives to current fluorosurfactants (PFOA, Telomer) manufactured using different methods to 3M.
• A period of 5 years has been given so that the impacts of the alternatives to PFOS can be proven. If it is proven that they are safe then only PFOS stock will need to be destroyed. However if it is proven to be as harmful then all foams containing fluorosurfactants (AFFF, FFFP, FP, AR, ATC) will be treated the same as PFOS.
• At this stage and for the next 5 years, the only restrictions on the use of all fire fighting foams (including PFOS) is managed via the requirements of The Ground Water Regs 1998.
• The Ground Water Regs 1998 states that the run off of all foams containing organohalogen compounds (that’s 95% of all types of foams) must be contained during use and disposed of in a manner agreed between the user and the local Environment Agency official. To date the most common agreed method is to pass the run off through filtration systems but as it is now known that this method will not remove PFOS or other organohalogens it is unlikely to be accepted in the future. The only recognised and agreed system for the disposal of fire water run off is high temperature incineration.
• Foam users should consider that it is cheaper to dispose of 1000 litres of 3% concentrate than have to dispose of 34,333 litres of fire water run off (1000 litre of concentrate and 33,333 litres of water)
• Foam users should also consider the financial impact of changing PFOS stock to any other types of foam concentrate until after the conclusion from the final research due to end in 5 years time.
• It is probable that the only accepted foam concentrate will be one that contains none of the substances listed in The Ground Water Regs 1998. The final report will be ratified in October and is expected tobecome EU/UK law in the near future.

Click here to view the minutes of UK CHEMICALS STAKEHOLDER FORUM sixteenth meeting on the 22nd June 2004. Where the MP Minister of State (Rural Affairs and Local Environmental Quality) made plain the Governments stance on PFOS for the future.

End of email correspondence on Topic to date

Author’s identities are concealed for privacy and security reasons. Further information on the information contained in this topic can be directed to the JOIFF secretariat.