Agricultural Industries Confederation (AIC)                            PFAS0085

AIC’s response to the Environmental Audit Committee’s Call for Evidence: Addressing the risks from Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS)

Summary

  • Regulatory Gaps in Biosolids Management: The current UK regulatory framework (including UK REACH) is inadequate for managing PFAS in biosolids. There is a loophole allowing sewage sludge containing PFAS to be applied to agricultural land without sufficient testing.
  • Environmental Risks from PFAS and Microplastics: Biosolids are a significant pathway for PFAS and microplastics to enter agricultural soils, posing risks through leaching into groundwater and uptake by crops. Microplastics can also act as carriers for PFAS and other toxic substances.
  • Potential for PFAS Removal: Technologies like high-temperature pyrolysis (e.g., at 700°C) can effectively destroy PFAS in biosolids, reducing levels by up to 97–100%, offering a viable treatment option.
  • Challenges in Monitoring and Regulation: PFAS are widespread due to diverse uses (e.g., firefighting foams, consumer products), making it difficult to trace sources. Current UK monitoring and regulatory resources may be insufficient to fully address the threat.
  • International Comparisons and Lessons: The EU is pursuing a comprehensive ban on PFAS, and the UK could learn from their approach, especially in terms of monitoring, resourcing, and identifying cost-effective alternatives when phasing out PFAS.

 

About the AIC

The Agricultural Industries Confederation (AIC) is the agri-supply industry’s leading trade association with over 230 Members in the agri-supply trade and represents £8 billion turnover at farmgate. AIC represents several sectors within the agri-supply industry including: Animal Feed; Crop Protection and Agronomy; Fertilisers; Combinable Crops; Seed.

The AIC response to PFAS considers PFAS in biosolids applied to land and PFAS in some plant protection products.

Biosolids: is the current regulatory regime for PFAS fit for purpose

AIC would like to focus on this section of the Call for Evidence and in particular the sub question:

Is the current regulatory regime for the use and disposal of PFAS, including UK registration, evaluation, authorisation and restriction of chemicals (UK Reach), adequate? If not, how can it be improved?

Land application of biosolids is a major pathway for PFAS to enter agricultural soils. These substances can leach into groundwater or be taken up by crops. Biosolids in the UK contain microplastics that accumulate during wastewater treatment. These microplastics can act as vectors both for PFAS chemicals and  toxic substances, compounding environmental risks.

 

The current regulatory regime for the processing and subsequent use of PFAS is not adequate. There is currently a regulatory gap that allows the application of sewage sludge that contains PFAS onto agricultural land. This should be addressed through the development of suitable regulations that bans this practice unless appropriate testing has been carried out to prove there are no PFAS present.

 

It is possible to remove PFAS from sewage sludge through high-temperature pyrolysis and other thermal treatments can effectively destroy PFAS in biosolids. Studies show that pyrolysis at 700°C can reduce PFAS levels by up to 97–100%[1].

 

[1]: https://www.mdpi.com/2073-4441/12/12/3590

 

Plant protection products

  1. What benefits do PFAS provide and how widely are they used?
    PFAS are present in a small number of plant protection products which are used by farmers and growers to control weeds, pests and diseases.
    PPPs are regulated in GB by the adopted Regulation for placing plant protection products on the Market (1107/2009). Annex II sets out procedures and non-approval criteria for active substances in PPPs, including (paragraphs 3.7.2.1 – 3.7.2.3) persistence, bioaccumulation and toxicity. PPPs cannot be approved for use if they meet any of the criteria.
    Without access to PPPs containing PFAS the choice of products would be reduced to growers. This is likely to increase the development of resistance to the remaining products within weeds, pests and disease and add to production costs for growers.

 

4. How sophisticated is current knowledge of how and where PFAS enter the supply chain? 
PFAS are ubiquitous in the environment due to their many and varied uses including firefighting foams, makeup, coatings on food containers, water proofing products and non-stick coatings in cookware.

Due to the various sources and many PFAS used it is likely to be very difficult to correlate use to detections in the environment.
 

6. To what extent are the Environment Agency, and other relevant UK bodies and research institutions, resourced to understand the current threat posed by PFAS and to monitor their impact going forward? 
HSE published an Analysis of the most appropriate regulatory management options for per- and polyfluoroalkyl substances (PFAS) in 2023.

The RMOA offered recommendations to manage the risk posed by PFAS to human health and the environment, including the restriction on PFAS in firefighting foams (FFFs).
The key applications that have been identified as major primary sources of PFAS into the environment are industrial processes, fire-fighting applications and consumer products (page 150). PFAS in PPPs were not identified as requiring action within the RMOA.

 

The current status of measures to address PFAS 

Is the current regulatory regime for PFAS fit for purpose?

10. Is a precautionary approach to PFAS desirable or is an approach that uses regulation to assess their benefits and risks more appropriate?
PFAS are a very broad group of chemicals with very different physical, chemical and biological properties, different exposures, and different risks.
To assess the risk to the environment the focus should be behaviour of individual PFAS in the environment, not necessarily their chemical structure.

 

12. How do other jurisdictions around the world, including the EU and US, regulate PFAS use and disposal, and what lessons, if any, can the UK learn? 

Experts from competent authorities in Germany, Denmark, Norway, Sweden and Holland submitted a ‘restriction dossier’ to ECHA aiming for blanket ban on all (circa 10,000) PFAS chemicals. Work is ongoing to manage PFAS in the EU.

 

What lessons can the UK learn from other countries on how they monitor and treat PFAS?  

13. What lessons can the UK learn from other countries in terms of resourcing and supporting the detection, monitoring and treatment of PFAS pollution?

The management of PFAS is complex due to the many sources. Where there is a proposal to withdraw PFAS cost effective alternative solutions must be found.

 

Ends

 

 

May 2025

 

 

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