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Don’t judge a book by its cover

PFAS

Not all PFAS is bad, argues Chris Hartfield

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Chris Hartfield of the NFU dissects the narrative around PFAS, responding to a FoodNavigator article on potential replacements for the chemical

PFAS chemicals are all tarred with the same brush – it takes the approach that all PFAS chemicals are the same in terms of negative properties and links to health issues. This is not the case.

It is understandable why some think this is the starting position, because this is the approach being taken in the EU, where you have a PFAS definition based on a certain chemical structure, then every chemical that includes that as part of its structure gets defined as a PFAS.

Also read → The article Hartfield is responding to

But this simplistic approach then captures a huge number of chemicals, which are very diverse in their properties, which should be assessed on the basis of actual risk of an effect – not on the basis of its chemical structure.

At the risk of overusing metaphors – using the chemical structure-based approach is like judging a book by its cover. The fact is that this approach captures PFAS chemicals that are useful and work well, and pose no risk – why would you replace such chemicals with alternatives?

Then when you look at the database at the centre of the article – I struggle to understand its usefulness. The approach it seems to take is to list PFAS, detail their functions and applications, then list alternatives that have similar functions/applications.

Maybe this has some use in other sectors – but for Plant Protection Products (PPPs), it has little if any use – because the categorisations, e.g. herbicide, insecticide, are way too broad. It implies you could replace any PFAS insecticide with a non-PFAS insecticide – that is not possible.

For something to be available as an alternative – it’s use would have to be specifically authorised against a pest on a specific crop – it is not a case of just swapping one for another as the article implies.

In fact, the caveats in the ‘read me’ section of the database that the article used make this clear – they basically say that there is no information on whether the ‘alternatives’ are actually technically feasible options.

Of greater concern, it says they cannot confirm ‘that the alternatives listed in the database are safer than PFAS’, which kind of makes it pointless. The good news here from a Plant Protection Products and GB point of view is that there issue of concern with PFAS – persistence, bioaccumulation and toxicity, are already accounted for in our pesticides regulation, which is among the strictest pesticide regulation in the world.

I’d also question the UK relevance of the database. I’ve not had time to go through line by line, but it includes PFAS PPPs that are already not authorised for use in GB – I suspect most of them aren’t. And there are also PPPs in the alternatives list that are not authorised for use in GB.

In summary, the PFAS issue is a really complex one, and that complexity doesn’t feature in the article. And in the context of PPPs, the database at the centre of the article doesn’t really offer anything useful in terms of saying whether alternatives are necessary or possible.

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