The Open University              PFAS0091

Evidence submission from The Open University

Addressing the Risks from Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS)

Contributors

Dr. Olga Adrianova,1 Dr. James Bowen,2* Dr. James Bruce,3 Dr. Simon Collinson,3 Prof. Toni Gladding,2 Dr. Betül Khalil,4 Dr. Ilias Kounatidis,3 Dr. Kate Nixon,3 Dr. Daniel Payne,3 Dr. Tarek Rashwan,2 Dr. Catherine Rolph2  

1 The Open University Business School; 2 School of Engineering and Innovation; 3 School of Life, Health, and Chemical Sciences;   4 Faculty of Science, Technology, Engineering, and Mathematics;

Introduction

In preparing this submission, we considered whether the current efforts in the UK are sufficient to address the risks posed by perfluoroalkyl and polyfluoroalkyl substances (PFAS). The team of contributors offer an interdisciplinary perspective that spans environmental chemistry, materials science, microbiology, and waste and pollution management. Collectively, our research addresses PFAS challenges across the full lifecycle: detection; transport through soil, water, and air; environmental persistence; waste infrastructure; ecosystem remediation; and impact on human health.

Understanding the Threats and Benefits from Using Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS)  

Q1. What benefits do PFAS provide and how widely are they used?

1.1 PFAS offer benefits due to their unique properties, which include durability, water repellency, anti-grease properties, and non-stick qualities. These properties make them useful in applications ranging from everyday products to specialized industries. Common items which present or incorporate PFAS include cookware products, fabrics and textiles, food packaging, cosmetics, and cleaning products. Industrial application includes automotive manufacturing, electronics, and firefighting foam. Medical applications of PFAS include endoscopes, catheters, textiles, surgical instruments, pharmaceutical packaging, implantables, medical devices, and personal protective equipment.

Q2. To what extent are UK health and environmental regulators equipped to detect, monitor and understand the risks posed by PFAS?

2.1  PFAS are a wide ranging class of chemical with variable physical properties and as a result commercially available analytical techniques may not differentiate a mixed source of PFAS or detect all PFAS present. Current methods of PFAS detection based on Liquid Chromatography Mass Spectrometry (LCMS) are expensive, require specialist operators, and offer poor accessibility.

2.2  PFAS has been shown to be present across a broad range of environments, including air, soils, waste sites, and water sources, as well as being detected in food items and living organisms. [1,2] However, current analytical methods for detecting PFAS are unable to account for the complexity of the systems where PFAS could be present, which may result in under-reporting of PFAS levels from different sources. A standardised methodology for the detection and quantification of PFAS from these diverse sources would be highly beneficial.

2.3  The breadth of different types of PFAS and their persistence at ultralow concentrations may not be well understood by regulators. A study of perfluorooctane sulfonate (PFOS) concentrations between 2005 and 2023 in the groundwater of Yorkshire suggested a need for continued monitoring and the elucidation of pathways within the surface-groundwater interactions.[3] 

2.4  The need for a quick-and-easy means of detecting PFAS in the field is recognised. [4,5] Fluorescent sensors either derived from biosensors or synthetic origin are a feasible alternative as they are selective, and the fluorescence can be detected with minimal sample preparation compared to Liquid Chromatography methods. However, the limits of current detection may not cover the low end of the range for PFAS concentration in the environment.

Q3. How developed is the UK’s research base on the science of PFAS and the technology required to monitor their current and future impact?

3.1  Global publication trends indicate a sharp increase in PFAS-related research over the last decade (72 publications in 2014; 1592 publications in 2024). The UK’s research base on PFAS appears to be growing yet remains comparatively underpowered when compared to US or the EU, representing < 5% of all publications. Health Impact Assessments of PFAS have been performed but these tend to be from outside the UK. For example, the UK Food Standards Agency Committee on Toxicity reviewed health-based guidance values drawing extensively on findings from the US EPA, EFSA, and the Danish EPA. [6] The lack of UK-specific toxicological and epidemiological data could be constraining the ability of domestic agencies to define tailored risk thresholds or public health guidance.

Q4. How sophisticated is current knowledge of how and where PFAS enter the supply chain?

4.1  PFAS use can lead to direct run-off into the environment, e.g. from firefighting foams and cleaning products. There are also indirect routes, e.g. from PFAS in treated sewage sludge which may be added to agricultural land as a fertiliser. PFAS can also enter the environment in landfill leachate produced from contaminated waste disposed of in landfills, and the breakdown of littered food packaging. PFAS has also been identified in the air of waste management infrastructures, though the extent and impact is currently unclear. [7]

4.2  Public concern is evident, with a survey indicating that 90% of UK residents consider controlling PFAS levels in food, water, and the environment as "very important." [8] PFAS pollution has occurred in Jersey via runoff from firefighting foam. The resulting health implications are under investigation. [9] There are also growing concerns in Bentham (Yorkshire) over PFAS pollution from the local firefighting foam manufacturer Angus Fire, with residents now taking legal action. [10,11]

4.3 Current knowledge could be considered to be at an intermediate stage of maturity. There exists an understanding regarding the sources, accumulation, and detection of PFAS; high-risk product categories have been identified. Yet blind spots remain, especially unintended contamination, indirect sources, and complex global supply chains. Researchers and regulators have identified major pathways for PFAS entering the supply chain:

Intentional entry:

• Firefighting products: foam
• Industrial processing (metal plating, electronic manufacturing, textile finishing)
• Processing aids (plastic productions)
• Products packaging: food wrappers, pizza boxes, popcorn bags
• Raw materials: intentional additives in non-stick coatings (cookware)

Unintentional entry via water, air, and waste streams:

• Airborne dust and emission in facilities production
• Contaminated water used in manufacturing (textile or dyeing finishing)
• Recycled materials contaminated with legacy PFAs
• Waste management facilities, recycling and final disposal routes

Unintentional entry via logistics and packaging:

• Cross contamination has been recorded in shared warehouses or transport containers.
• PFAS treated materials as plastic wraps can transfer residues to goods

4.4  Challenging or unclear areas include undisclosed use, as some PFAS applications are proprietary, trade secrets, or not yet regulated. Many areas are not routinely screened. The complexity of supply chains with multi-tiered suppliers allows an indirect introduction of PFAS. Some brands lack full transparency of inputs especially in countries with less regulatory oversight. Global variability in terms of regulation also has a negative impact on the supply chain compliance and co-ordinated detection efforts.

Q5. What is the current understanding of how PFAS are made and then used in terms of product ranges, and geographical and socioeconomic distribution?

5.1  PFAS are synthetic compounds which contain carbon-fluorine bonds which make them highly resistant to degradation. PFAS range from well known ‘legacy’ compounds (e.g. perfluorooctane sulfate, PFOS; perfluorooctanoic acid, PFOA) to emerging and replacement compounds (e.g. PFBS; GenX). Manufacturing processes include electrochemical fluorination [12] and telomerization. [13] Intermediate steps during manufacture can produce precursors that then degrade into persistent PFAS.

5.2  Current understanding of how PFAS are made and used is increasingly comprehensive, with significant clarity relating to manufacture, product applications, geographic distribution, and socioeconomic disparities in both exposure and regulation. Major global PFAS manufacturers include 3M, Daikin, Chemours, Gujarat Fluorochemicals, and Dongyue. The Asia-Pacific region is increasingly dominant in PFAS manufacturing, although Japan and South Korea, while key users of PFAS for electronics and advanced materials, have tighter controls than other countries in the region. The USA and EU are phasing out legacy PFAS, but use newer variants extensively in high-tech applications.

5.3  Low-income countries often face higher PFAS exposure especially around industrial facilities, airports, military bases, landfills, and wastewater plants. The drinking water in marginalized communities and/or under-resourced areas is less likely to be tested or treated for PFAS. While high-income consumers often use more PFAS-containing products, the health burden falls mainly on communities near manufacturing or disposal sites. High-income countries are increasingly regulating PFAS, funding research, and informing the public of risks, whereas low- and middle-income countries may lack the infrastructure or/and regulation required to monitor contamination and restrict usage.

Q6. 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?

6.1  The UK does not appear to have standardised testing in place, for example via sampling and analysis at a range of regulated facilities. There is a large and growing research need. Since we are still at the point of finding out the scale of this issues relating to PFAS, it is unknown whether sufficient investment is being made into investigative, preventative, and remediation.

The Current Status of Measures to Address PFAS

Q7. What are the current technologies and solutions to treat PFAS pollution, how cost effective and efficient are they and do they create additional risks?

7.1  PFAS are highly recalcitrant compounds and resistant to many conventional pollution treatment technologies.  Thermal treatment methods are an important approach to destroy PFAS, because they can mineralise PFAS completely into hydrogen fluoride and carbon dioxide. However, PFAS may not break down fully across all thermal conditions, for example in systems with insufficient temperatures or residence times. Therefore, the fate of PFAS from thermal systems must be tracked to ensure that additional PFAS risks are not created by residual risks in the output emissions and ash.

7.2  The Drinking Water Inspectorate (DWI) have funded studies exploring methods for removing PFAS from water. [14] Most methods showed good removal at bench scale. Overall water quality influenced removal efficiency and results were inconsistent, suggesting further research is needed. The methods investigated included:

• A surface modified clay (SMC) adsorbent
• Advanced oxidation/reduction processes
• Coagulation
• Granular activated carbon adsorbent
• Ion exchange
• Nanofiltration and reverse osmosis membrane filtration

7.3  Activated carbon is an attractive method for PFAS removal from water, though limitations include inefficiency in removing short-chain PFAS species, poor selectivity over other organic compounds present, overall low adsorption performance, plus issues relating to economic sustainability. [15] It is also possible to remove PFAS via adsorption onto activated biochar, a material often derived from waste materials. [16,17]

7.4  Applied smouldering is a flameless form of combustion that has various environmentally beneficial applications, such as remediation of hydrocarbon-contaminated soil and sewage sludge treatment. [18] This technology takes advantage of the chemical energy stored within contaminants to drive self-sustaining treatment with minimal energy input. Smouldering treatment has recently been shown to drive complete PFAS remediation in challenging matrices, including sewage sludge [19], contaminated soil, and granular activated carbon [20], which is often used to treat PFAS-contaminated water.

7.5  The application of smouldering combustion for PFAS remediation is currently applied commercially and these systems routinely use small amounts of inexpensive calcium-based amendments to support the transformation of PFAS to calcium fluoride that can be safely removed after treatment. This strategy is a commercially viable way to reduce risks associated with gaseous emissions by limiting hydrogen fluoride production; and through promoting full PFAS removal from the resulting ash.

Q8. How well equipped is the UK’s research and development base to improve existing approaches to dealing with PFAS?

8.1  The UK has many academic research groups which are actively investigating new technologies for PFAS detection and the remediation of PFAS-contaminated soil and water.

Is the Current Regulatory Regime for PFAS Fit for Purpose?

Q9. 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?

9.1  A Regulatory Management Option Analysis (RMOA) performed by the UK Health and Safety Executive (HSE) concluded that only a few PFAS are currently regulated in the UK [21], mainly:

• PFOA, its salts, and related substances (based on EU REACH legacy regulations)
• Perfluorooctane sulfonic acid (PFOS) (restricted under the Stockholm Convention and retained UK law)
• Some perfluorinated silanes (in specific uses)

Many other PFAS substances, such as PFHxA, PFHxS, PFBS, GenX and others, remain unregulated.

9.2  The UK's regulatory framework for PFAS, primarily governed by UK REACH, is currently inadequate in several respects:

• UK REACH restricts only a few PFAS substances, notably PFOA and perfluorinated silane. Many other PFAS compounds remain unregulated, despite their persistence and potential health risks.
• The UK HSE's RMOA adopts a narrower definition of PFAS compared to the EU, potentially excluding thousands of substances from regulation.
• The UK's approach lacks a unified strategy, leading to inconsistencies in monitoring and enforcement across different regions and sectors.

9.3  The Royal Society of Chemistry have called for lower limits of PFAS in drinking water. [22] Current standards allow concentrations of each individual PFAS at up to ten times the level considered ‘low risk’, which is 10 ng/L (nanograms per litre). There are hundreds of different types of PFAS but there is currently no overarching limit on the total concentration when they are combined. Updated DWI guidance to water companies (March 2025) requires water companies in England and Wales to monitor for a wider range of PFAS and subsequently modify their risk assessments. This guidance adopts a tiered approach with a guideline value of 100 ng/L for the sum of 48 named PFAS, which is equivalent to 100 parts per million. [23]

9.4  Recommendations for improvement:

• Implement a comprehensive approach that regulates PFAS as a class, similar to proposals in the EU, to prevent the substitution of one harmful PFAS with another.
• Broaden the scope of UK REACH to include a wider array of PFAS compounds, ensuring more comprehensive protection.
• Invest in better detection methods and ensure consistent enforcement across all UK regions.

Q10. Is a precautionary approach to PFAS desirable or is an approach that uses regulation to assess their benefits and risks more appropriate?

10.1  A precautionary approach is more appropriate for PFAS regulation due to the following reasons:

• PFAS are known as ‘forever chemicals’ because they do not break down in the environment and can accumulate in living organisms, leading to long-term exposure risks.
• Given the vast number of PFAS compounds and the limited understanding of their individual and combined effects, waiting for conclusive risk assessments could result in prolonged exposure to harmful substances.
• The EU is moving towards a precautionary, group-based ban on PFAS, recognising the limitations of assessing each compound individually. [24]

Q11. Is there any regulatory divergence across the UK in terms of PFAS? If so, what are the implications, and is there a need for a more joined-up approach?

11.1 Post-Brexit arrangements mean that Northern Ireland continues to follow EU REACH regulations, while Great Britain operates under UK REACH. Establishing a unified regulatory framework across all UK regions would support consistent protection and simplify compliance for businesses.

Q12. 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?

12.1  The UK's current regulatory regime for PFAS appears insufficient to address the widespread and persistent nature of these chemicals. Adopting a precautionary, group-based approach, harmonising regulations across all UK regions, and learning from international best practices are essential steps toward more effective PFAS management.

12.2  Usage and Regulation Landscape:

What Lessons Can the UK Learn From Other Countries on How They Monitor and Treat PFAS? 

Q13. What lessons can the UK learn from other countries in terms of resourcing and supporting the detection, monitoring and treatment of PFAS pollution?

13.1  The UK could draw upon wider expertise in environmental and/or public health law to help frame responses to questions about the fitness of UK REACH and other relevant legal frameworks. General insights on institutional coordination, legal mandates, and enforcement processes could also be beneficial. This could yield transferable knowledge from comparative law or international policy work that could help contextualise regulatory approaches, which could extend to the structuring and resourcing required to address the complex environmental risks presented by PFAS.

Q14. How does the UK compare to other countries in terms of funding research and new technologies to improve outcomes?

No comment

May 2025

References

[1] Dimitrakopoulou, M.E.; Karvounis, M.; Marinos, G. et al. (2024) Comprehensive analysis of PFAS presence from environment to plate. npj Sci Food 8, 80. https://doi.org/10.1038/s41538-024-00319-1

[2] United States Environmental Protection Agency (2024) Our Current Understanding of the Human Health and Environmental Risks of PFAS. Available at https://www.epa.gov/pfas/our-current-understanding-human-health-and-environmental-risks-pfas (25/05/2025).

[3] Agarwal, V.; Kumar, M.; Dogra, K.; Mejia-Avendaño, S. (2025) Isomers of perfluorooctanesulfonate exhibit preferential infiltration and contrasting ionic associations between surface water and groundwater. J. Hazardous Mater. 494, 138445. https://doi.org/10.1016/j.jhazmat.2025.138445

[4] Charbonnet, J.A.; Rodowa, A.E.; Joseph, N.T.; Guelfo, J.L.; Field, J.A.; Jones, G.D.; Higgins, C.P.; Helbling, D.E.; Houtz, E.F. (2021) Environmental source tracking of per- and polyfluoroalkyl substances within a forensic context: current and future techniques. Environ. Sci. Technol. 55, 7237-7245. https://doi.org/10.1021/acs.est.0c08506

[5] Nahar, K.; Zulkarnain, N.A.; Niven, R.K. (2023) A review of analytical methods and technologies for monitoring per- and polyfluoroalkyl substances (PFAS) in water. Water 15, 3577. https://doi.org/10.3390/w15203577

[6] Food Standards Agency Committee on Toxicity (2024) PFAS Working Group. Available at https://cot.food.gov.uk/PFAS (25/05/2025).

[7] Lin, H.; Lao, J-Y.; Wang, Q.; Ruan, Y.; He, Y.; Lee, P.K.H.; Leung, K.M.Y.; Lam, P.K.S. (2022) Per- and polyfluoroalkyl substances in the atmosphere of waste management infrastructures: uncovering secondary fluorotelomer alcohols, particle size distribution, and human inhalation exposure. Environ. Int. 167, 107434. https://doi.org/10.1016/j.envint.2022.107434

[8] Royal Society of Chemistry (2025) First-ever survey of UK public attitudes to PFAS ‘forever chemicals’. Available at https://www.rsc.org/news-events/articles/2025/01-january/first-ever-survey-of-uk-public-attitudes-to-pfas-forever-chemicals (25/05/2025).

[9] PFAS Scientific Advisory Panel (2025) Draft Third Report of the Independent PFAS Scientific Advisory Panel for Jersey: Testing, Biomonitoring and Management of PFAS in the Human Body. Available at https://www.gov.je/SiteCollectionDocuments/Health%20and%20wellbeing/Draft%20Third%20Report%20of%20the%20Independent%20PFAS%20Scientific%20Advisory%20Panel%20for%20Jersey.pdf

(25/05/2025).

[10] Ends Report (2024) God’s Own Dark Waters? Available at https://www.endsreport.com/article/1873849/gods-own-dark-waters-exposing-yorkshire-town-became-pfas-polluted-place-uk-regulator-let-happen (25/05/2025).

[11] BBC News (2024) Town brings legal case over 'forever chemicals'. Available at https://www.bbc.co.uk/news/articles/cz0m2nn2p2zo (25/05/2025).

[12] Li, B.; Xu, M.; Feng, P.; Xu, S. (2024) Electrochemical construction of C−F bonds: recent advances and future perspectives. EurJOC 27, e202400605. https://doi.org/10.1002/ejoc.202400605

[13] Sun, J.; Lorpaiboon, W.; Fox, N.; Jones, A.; Ho, J.; Manefield, M.J.; Kumar, N.; O'Carroll, D.; Lee, M. (2025) Characterization of PFOA isomers from PFAS precursors and their reductive defluorination. Water Res. 268 B, 122717. https://doi.org/10.1016/j.watres.2024.122717

[14] Drinking Water Inspectorate (2025) Bench-Scale Water Treatment Efficacy Study of PFAS Removal. Available at https://www.dwi.gov.uk/research/completed-research/analysis/bench-scale-water-treatment-efficacy-study-of-pfas-removal (25/05/2025).

[15] Mian, M.M.; Zhu, J.; Jiang, X.; Deng, S. (2025) Recent advances in activated carbon driven PFAS removal: structure-adsorption relationship and new adsorption mechanisms. Front. Environ. Sci. Eng. 19, 78. https://doi.org/10.1007/s11783-025-1998-3

[16] Steigerwald, J.M.; Ray, J.R. (2021) Adsorption behavior of perfluorooctanesulfonate (PFOS) onto activated spent coffee grounds biochar in synthetic wastewater effluent. J. Hazardous Mater. Lett. 2, 100025. https://doi.org/10.1016/j.hazl.2021.100025

[17] Liang, D.; Li, C.; Chen, H.; et al. (2024) A critical review of biochar for the remediation of PFAS-contaminated soil and water. Sci. Total Environ. 951, 174962. https://doi.org/10.1016/j.scitotenv.2024.174962

[18] Torero, J.L.; Gerhard, J.I.; Martins, M.F.; Zanoni, M.A.B.; Rashwan, T.L.; Brown, J.K. (2020) Processes defining smouldering combustion: Integrated review and synthesis. Prog. Energy Combustion Sci. 81, 100869. https://doi.org/10.1016/j.pecs.2020.100869

[19] Fournie, T.; Rashwan, T.L.; Switzer, C.; Gerhard, J.I. (2023) Smouldering to treat PFAS in sewage sludge. Waste Man. 164, 219-227. https://doi.org/10.1016/j.wasman.2023.04.008

[20] Duchesne A.L.; Brown, J.K.; Patch, D.J.; Major, D.; Weber, K.P.; Gerhard, J.I. (2020) Remediation of PFAS-contaminated soil and granular activated carbon by smoldering combustion. Environ. Sci. Technol. 54, 12631–12640. https://doi.org/10.1021/acs.est.0c03058

[21] Health and Safety Executive (2023) PFAS Regulatory Management Option Analysis (RMOA). Available at https://www.hse.gov.uk/reach/rmoa.htm (25/05/2025).

[22] Royal Society of Chemistry (2025) Cleaning Up UK Drinking Water. Available at https://www.rsc.org/policy-evidence-campaigns/environmental-sustainability/sustainability-reports-surveys-and-campaigns/cleaning-up-uk-drinking-water (25/05/2025).

[23] Drinking Water Inspectorate (2025) PFAS and Forever Chemicals. Available at https://www.dwi.gov.uk/pfas-and-forever-chemicals (25/05/2025).

[24] European Chemicals Agency (2023) Annex XV Restriction Report: Per- and polyfluoroalkyl substances (PFASs). Available at https://echa.europa.eu/documents/10162/1c480180-ece9-1bdd-1eb8-0f3f8e7c0c49 (25/05/2025).

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