The PFAS Conundrum-Of Logic, Science, Policy

The comprehensive ("universal") PFAS ban proposed by the EU raises questions of a scientific, philosophical, regulatory, and policy nature. This overview scrutinizes the proposal and finds it wanting in each of these respects. The grouping of all PFAS is based on a methodology that is only loosely science based. The scientific data on PFAS do not support the open-ended definition and the drastic restrictions that would be imposed by the proposal. To illustrate the weak scientific basis, we look more closely at the immunotoxicity claims as found in a few landmark epidemiological papers. We find these claims not well-founded and methodologically lacking. Also, we scrutinize a few animal studies and comment on their results. Detecting PFAS in multiple matrices is briefly looked at. The analytical context of detectability, quantifiability, measurement precision, and reproducibility of results of PFAS present in especially complex matrices (e.g., foods, soil, waxes, and fats) poses quite the challenge. Experimental uncertainties are reported to be extremely high. Disregarding the key distinctions between hazard and risk and between potential hazard and hazard, the proposal treats all PFASs, broadly defined, as presenting hazards based on an assumed common property: persistence. On this and other grounds, including the requirement of "unacceptable risk", the proposed ban fails to meet the requirements imposed by the REACH Regulation. From a public policy perspective, the costs of the proposal would appear to eclipse any advantages for human health and the environment. Thus, we conclude that the proposed PFAS ban is problematic from these key perspectives.