Ireland's State of the Environment Report 2024

388 Chapter 14: Environment, Health and Wellbeing The issue of PFAS is also one of national concern, with PFAS detected in the Irish environment, including in surface waters, groundwaters, transitional and coastal water bodies, sediments and certain biota. The EPA report Water Quality in Ireland 2016–2021 indicated that 2.7% of surface waters failed to achieve good chemical status due to the presence of PFOS (EPA, 2022), a PFAS that has been restricted under the Stockholm Convention since 2009/2010. The EPA-funded FUEL project investigated the risks posed by PFAS in Irish landfills and highlighted a potential risk of PFAS contamination of groundwater sources from unlined or partially lined landfills, as well as waste water treatment facilities receiving landfill leachate (Harrad et al ., 2020a). Environmental monitoring performed at a number of sites at risk of PFAS contamination because of their close proximity to firefighting training facilities, large scale storage facilities and waste water treatment facilities, particularly those receiving landfill leachate, found elevated levels of PFAS in many instances (EPA, 2021a). A national human biomonitoring study examined the Irish population’s exposure to PFAS through non- dietary sources, which was found to fall below the EFSA’s tolerable weekly intake (Harrad et al ., 2020b). Concentrations of PFAS found in Irish breastmilk did not indicate a health concern for nursing infants based on EFSA breastfeeding exposure scenarios. However, pharmacokinetic modelling of the level of adult exposure to PFAS that would result in the levels observed in breastmilk suggests that overall exposure of some individuals may approach or exceed EFSA’s tolerable weekly intake, pointing to the need for an assessment of dietary exposure to PFAS in Ireland. This study highlights the power of human biomonitoring studies as valuable surveillance tools that can provide useful baseline data around population exposure to PFAS. Regular re-assessment should be performed nationally to facilitate ongoing monitoring and evaluation of the impact of measures taken to reduce human exposure to PFAS and other such chemicals. Many European countries have well-established human biomonitoring programmes in place as a tool for chemical risk assessment. While some human biomonitoring work has been undertaken in Ireland, consideration should be given to establishing a more formalised ongoing monitoring programme. An EPA-funded research project is currently conducting a feasibility study to determine the prospect of having an ongoing national human biomonitoring programme in Ireland. 13 The REACH Regulation ((EC) No. 1907/2006) is comprehensive legislation that aims to improve the protection of human health and the environment from the risks that can be posed by chemicals, while also enhancing the competitiveness of the EU chemicals industry. It also promotes alternative methods for the hazard assessment of substances to reduce the number of tests on animals. REACH has a very wide scope, as it applies to all chemical substances that are manufactured, imported, placed on the market or used within the EU, either on their own, in mixtures or in articles with intended release. Under the Chemicals Acts 2008 and 2010, the Health and Safety Authority is the lead competent and enforcement authority for REACH in Ireland. While action is being taken at both EU and global levels to combat the harmful effects of PFAS, given the nature of the issue, progress is slow. The EU Chemicals Strategy for Sustainability (CSS) aims to phase out PFASs, allowing use only when they are essential for society. In 2024 the European Commission published guiding criteria and principles for the essential use concept in EU legislation dealing with chemicals to facilitate decision-making and increase regulatory efficiency to achieve the phasing out of harmful substances in non-essential uses (EC, 2024). While there are currently three groups of PFAS restricted under the Stockholm Convention, under the REACH Regulation 13 there are two proposed broad restrictions on the use of PFAS that point to a new way of tackling groups of chemicals rather than one at a time, that is, a generic risk assessment. The first proposal would see the use of PFAS in firefighting foams, the use of which has been a major source of pollution, particularly water contamination, prohibited completely. The other, more universal, proposed restriction on PFAS would strictly limit their use to applications where it is essential to society and where no alternative safer chemicals are available to fulfil the specific role. The European Chemicals Agency (ECHA) received 5600 comments from over 4400 organisations on the PFAS restriction proposal consultation in 2023. ECHA scientific committees will evaluate the proposed restrictions, along with comments from the consultation, throughout 2024. A key task across Europe at present is to replace stockpiles of PFOA used in firefighting foams with safer alternatives and ensure that existing stockpiles of PFOA foams are managed in an environmentally sound manner. The EPA holds a register related to stockpiles of PFOA, a PFAS that was banned under the Stockholm Convention in 2019 but remains in a phase-out period (until July 2025) for certain uses. Those with stocks of PFOA must notify the EPA and provide details on the nature/use and storage conditions and confirmation of correct disposal. To date a total of approximately 498,000 kg of PFOA firefighting foam has been notified to the EPA via the online PFOA stockpile reporting system. Approximately 30% of this is reported as being still in use per the specific exemption. The remainder is reported as being in storage on site/awaiting disposal or as having been disposed of already. The EPA is working on checking and verification of this stockpile register. As part of this work, the EPA encourages various organisations and networks (e.g. industry trade associations, fire industry associations, local authority representatives) to raise awareness of the obligations and deadlines concerning stocks of PFOA.