7th July 2020
Ms Nicola Powell
Director
PFAS Taskforce and Minamata Convention
Department of Agriculture, Water and the Environment
GPO Box 858
Canberra City ACT 2601, Australia
email: PFASTaskforce@environment.gov.au
Dear Ms Powell,
Subject: PFAS Taskforce Consultation Response to Questions
Thank you for the opportunity for the Royal Australian Chemical Institute to participate in the Australian Government consultation on the National PFAS Position Statement (the Position Statement).
Who is the Royal Australian Chemical Institute?
The Royal Australian Chemical Institute (RACI) is a professional membership organisation for professional chemists and chemical sciences across Australia. It acts both as the qualifying body in Australia for professional chemists, and as a learned society promoting the science and practice of chemistry. The RACI has approximately 4000 members who work as scientist, educators, laboratory technicians, researchers, health and safety profession across education (secondary and tertiary); research, government and industry.
The RACI represents and caters for the professional needs of the full range of chemists and those with an interest in chemistry, providing targeted activities and services in the following areas:
- Analytical & Environmental
- Carbon
- Chemical Education
- Electrochemistry
- Health, Safety & Environment
- Industrial Chemistry
- Inorganic Chemistry
- Material Chemistry
- Medicinal Chemistry/Chemical Biology
- Organic Chemistry
- Physical Chemistry
- Polymer Chemistry
- Radiochemistry
Response to the consultation document questions.
The following three questions were put to the membership and I have attached the responses as Appendix 1.
Additional Concerns
Members also voiced a number of concerns as outlined below:
1. Definition
The definition being put forward in the National PFAS Position Statement as being either long chain and short chain PFAS appear to be an abbreviated form of what has been defined based on the OECD Guidelines and the Stockholm Conventions i.e.
- Long-chain PFAS: Perfluorosulfonates with six or more carbons, perfluorocarboxylic acids with seven or more carbons, and their precursors
- Short-chain PFAS: Perfluorosulfonates with less than six carbons, perfluorocarboxylic acids with six or less carbons, and their precursors.
However, the problem with these broad definitions is that these definitions can also captures non-bio persistent compounds (containing Fluorine) which are often found in pharmaceutical preparations including anaesthetics and other significant medications. Thus, while the intention to reduce/eliminate bio-persistent forms of PFAS is commended, by extending the definition of PFAS beyond this category, is not necessary, and would have significant ramifications with in the pharmaceutical and other related industries.
2. Importation of PFAS into Australia
Members also identified that Australia does not currently manufacture PFAS, but imports PFAS. This has raised the questions, of the importance of scrutiny by the Office of Chemical Safety through the Australian Industrial Chemicals Introduction Scheme (AICIS) of imported chemicals, and the reliance and acceptance of overseas risk assessments and other data in their determinations.
3. Focus on Firefighting Foams rather than other sources of PFAS.
Members are also concerned that there has been a targeting of specific products containing PFAS i.e. firefighting foams. However, the membership has identified other every day products which seem to escaped the eyes of the regulators including (but not limited to) the following items which potentially end up in landfill.
- O-rings and seals (e.g. Viton) which contain per-fluorinated elastomers. These could degrade to generate PFAS materials. These are used across industry - vehicles, medical equipment, aerospace etc.
- Per fluorinated membranes and critical component in advanced membrane fuel cells for the use and production of hydrogen and in the chlor-alkali industries.
- Per-fluorinated lubricants for advanced operation of high specification engines and turbines.
- Per fluorinated coatings to minimize friction (wind turbine blades), water resistance (electronic components), and to ensure cleanliness and ease of sterilization in hospitals and the like.
- Plastic like – rain coats
- Liquid repelling material Raincoat
- Paper Wrist Bands
- Coatings on paper plates.
Many of these products are imported from overseas, with a large percentage coming from China, India and other Asian countries, without regulation.
While the RACI supports the move to reduce the use of PFAS in Australia, it is important that ensure that any regulations and management approaches are based on those compounds which an bio-persistent and not target non-bio-persistent forms.
For any questions in relation to this response please contact myself on +61 (03) 9328 2808 or roger.stapleford@raci.org.au
Yours sincerely
Roger Stapleford
Chief Executive Officer
Royal Australian Chemical Institute
View Appendix 1 in Full Document