Call for Evidence: UK Authorities Seek Information on PFAS in Firefighting Foams

On 4 April 2024, the UK Health and Safety Executive (HSE) announced its initiative to seek information and evidence on firefighting foams containing per- and polyfluoroalkyl substances (PFAS). This initiative aims to gather information to prepare an Annex 15 restriction dossier in collaboration with the Environment Agency to assess the risk to the environment and human health from PFAS in firefighting foams. This Annex 15 dossier will assess whether a restriction on the use of PFAS in firefighting foams should be introduced in Great Britain (GB; England, Scotland and Wales).

Stakeholder Engagement Key to UK PFAS Restriction Process

In an effort to address the significant environmental emissions from PFAS in firefighting foams, the UK government has initiated steps towards restriction. Stakeholders including manufacturers, importers, distributors, and environmental organisations are invited to come forward for further dialogue with the Agency. The call for evidence, which is part of the UK's REACH regulation, aims to inform the development of a restriction report and will require comprehensive data and evidence from respondents.

The HSE is interested in relevant information on all aspects of firefighting foams, particularly those containing PFAS, including the following:

• Manufacture of firefighting foams: substances used, processes, quantities.

• Import of firefighting foams of all types: quantities, suppliers.

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

• Alternatives to PFAS in firefighting foams: availability, cost, performance compared 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 use, where does it go?

• Waste: disposal requirements, recycling options, remediation.

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

Background: UK Authorities Act after Identifying Risks

Following the identification the adverse environmental and human health properties of PFAS, the UK Environment Agency published a Risk Management Options Analysis (RMOA) in April 2023.

This analysis concluded that PFAS have a number of properties which, taken together are of concern to the environment and human health, in particular:

• Persistence of these substances or their breakdown products in the environment.

• The potential for high mobility leading to widespread distribution and the risk of contamination including of the aquatic environment.

• Uncertainties about long-term adverse effects on the environment and human health

As a result, one of the RMOA’s key recommendations was to initiate a restriction proposal to address the significant emissions from the use of PFAS in firefighting foams.

With the Health and Safety Executive (HSE) leading the preparation of the Annex 15 restriction dossier, the UK is seeking to mitigate the risks posed by PFAS in firefighting foams, emphasising transparency and stakeholder engagement throughout the process.

Submitting Comments: How to Respond to the PFAS Consultation

To submit comments, respondents can provide basic information in the survey, which can be found here and attach detailed documents at the end. Respondents are encouraged to provide as much evidence as possible. By submitting information, participants agree that data (excluding personal data) may be shared with relevant authorities for the development of the Annex 15 restriction dossier. The consultation closes on 3 June 2024 at 23:59 London time (BST).