Draft
Exploration of Management Options for
PFOS
Proposal submitted by Sweden
for
the fifth meeting of the LRTAP Task Force on Persistent Organic Pollutants,
Tallinn, 29 May-1 June 2006, revised 15 June 2006 and with an addendum resubmitted
for the 6th meeting of the LRTAP Task Force on Persistent Organic Pollutants, Vienna, 46 June 2007.
1
Exploration of Management Options for PFOS
Introduction
PFOS is an intentionally produced substance with no natural occurrence. It is a fully
fluorinated anion, which is commonly used as a salt or incorporated into larger polymers.
PFOS can be formed by degradation from a large group of related substances, referred to
as PFOS-related substances. PFOS and its related substances are defined as:
Perflourooctane sulfonates C8F17SO2X (X= OH, Metal, salt halide, amide, and other
derivates including polymers).
Due to its surface-active properties it has been used in a wide variety of applications e.g.
in textiles, and leather products; metal plating; food packaging; fire fighting foams; floor
polishes; denture cleansers; shampoos; coatings and coating additives; in the
photographic and photolithographic industry; and in hydraulic fluids in the aviation
industry.
Current Sources of Emission of PFOS
Estimated levels and trends of production and associated emissions in UNECE
The total production of PFOS has been significantly reduced from 2000 to 2005 due to a
voluntary phase out by industry. The total production volume today in the UNECE region
or globally is not known.
The use of PFOS in carpets, textiles, paper and packaging, coatings, cleaning products,
fire fighting foam and pesticides/insecticides is largely phased out in the UNECE region.
Current uses of PFOS are limited to applications where suitable alternatives have not tyet
been identified. The current demand (2004) in the European Union was estimated for the
ongoing industrial/professional usage of PFOS and PFOS-containing substances (Table
1) xi
Table 1: Estimated Current Demand for PFOS-Containing Substances in the Euoropean
Union
Industry Sector
Quantity (kg/year)
Photographic industry
1,000
Semiconductor industry
470
Hydraulic fluids
730
Metal plating
10,000
In January 2005, OECD published a report with results from a survey on the production
and use of PFOS and related substances in the OECD areai. The responses to the survey
were limited and only 10 OECD countries responded to the questionnaire. Eight of these
countries were signature to the LRTAP POPs protocol and one conclusion from the
survey is that PFOS is still manufactured by Germany (20 – 60 tonnes in 2003) and Italy
(< 22 tonnes in 2003).
2
Approximately 587 tonnes of perfluorinated alkyl compounds (PFA) were imported into
Canada during 1997-2000. Of this total approximately 318 tonnes were estimated to be
PFOS, its salts and its precursors. The manufacture and export of PFOS, its salts and its
precursors has been eliminated and it is only imported and used in one industrial sector,
according to a survey in 2005.
Use of PFOS in manufacturing process
Twenty enterprises, of which half are European, have been identified as producers of
PFOS related substances in the world during the past decade. It is possible that only half
of them are producing such chemicals today. PFAS production in year 2000 has been
estimated at 4 650 tonnes per year. The largest parts were used for surface treatment
(>2000 tonnes) and paper protection (1500 tonnes) while approximately 900 tonnes were
used in performance chemical applications (RPA 2004).
The total production has been significantly reduced from 2000 to 2005. 3M which
represented more than one quarter of the total production in 2000 had phased out PFOS
production by 2003.
Former and current processes that use PFOS and associated emissions
Due to the persistent nature of PFOS, there is need to take into account the total
accumulated production of PFOS since the beginning in the middle of the 1900 century
as well as the different uses in the past. It is not possible to make emission scenarios in
detail for all PFOS potential precursors since such information is not available, however,
since the precursors are degraded to PFOS, which is not further degraded in the
environment, they will all contribute to the environmental load for PFOS.
Releases of PFOS and its related substances are likely to occur during their whole life
cycle. They can be released at their production, at their assembly into a commercial
product, during the distribution and industrial or consumer use as well as from landfills
after the use of the productsii.
Emissions from manufacturing operations prior to the PFOS phase-out were primarily in
the form of process waste water discharge to industrial or municipal treatment facilities.
Paper recycling facilities may continue to be a source of PFOS emissions as there may
also be releases of PFOS during the recycling process. Over half of the PFOS use in
Canada was in the form of coating for packaging and paper.
The durability of the protective PFAS layer on carpets has been studied by 3M. It is
expected that 50% of the FC (fluorochemical) treatment will be removed over the nineyear life of the carpet due to walking and vacuuming, while an additional 45% of the FC
treatment will be removed in steam cleaning throughout the carpet lifeiii.
It is unlikely that PFOS is transported to remote regions in the vapour phase due to its
low vapour pressure. It has been suggested that the presence of PFOS in Arctic wildlife
may be due to long-range transport of volatile precursor compounds that degrade to give
3
PFOSiv One of the most likely precursors of PFOS are the electrochemically produced
perfluorinated sulphonamidoethanols used to incorporate PFOS into polymeric materialsv
and perfluorinated sulphonamides, which has been used in a variety of consumer
products and industrial materialsvi
A recent study on rainbow trout (Onchorhynchus mykiss) liver microsomes has
demonstrated that N-ethyl perfluorooctanesulphonamide (N-EtPFOSA) is a precursor of
PFOS in fishvii. These findings combined with the recent measurements of high
concentrations of N-EtPFOSA in aquatic organisms from Arctic regionsviii strengthen the
hypothesis that perfluorinated sulphonamides are one of the volatile precursors of PFOS
transported over long distances to the Arctic.
However, the hypothesis that these volatile precursors reach the Arctic latitudes by
atmospheric transport has not yet been confirmed by atmospheric measurementsix.
Use of products containing PFOS
The category of uses where there is no current use or where use is in the process of being
phased out consists of carpets, leather, textiles, paper and packaging, coatings, cleaning
products, fire fighting foam and pesticides/insecticides.
As an example, the majority of PFOS imported into Canada was used in applications
involving packaging (56%), rugs and carpets (20%), fire fighting foams (10%), paint and
coating additives (8%), chemical formulation, (3%) and water, oil, soil and grease
repellents for fabrics (1%). Small quantities of PFOS were also used in the
photographic/photofinishing and semiconductor sector.
The current use of PFOS is generally limited to those areas where suitable alternatives
have not yet been identified. These include the photographic, photolithography and
semiconductor applications and chemical formulation, surfactant use in metallic
electroplating and hydraulic fluids used in aviation.
Emissions during product life cycles
Releases of PFOS and its related substances are likely to occur during all stages of their
life-cycle e.g. production, product application, distribution, industrial and/or consumer
use and disposal. No comprehensive data on present emissions in the UNECE area are
available.
In a recently published report from Norwayx an inventory was made for the remaining
quantities and historic emissions of fire fighting foams containing PFOS in Norway. The
quantities of PFOS in the remaining foam were estimated to approximately 22 tons and
the dominating uses were in offshore installations.
The estimated quantity for fire fighting foams, held in current stock for the European
Union, was 122 tonnes in 2004 xi.
4
Average emission/use rates for aqueous film fire fighting foams in Canada are estimated
to be in the order of 10-12% per year.
Potential emissions to wastewater effluent have been identified from the washing of
fabrics and to air from the vacuuming of rugs and carpets. A study shows that 50% of the
fluorochemical treatment will be removed over the nine-year life cycle of the carpet due
to walking and vacuuming, while an additional 45% of the fluorochemical treatment will
be removed in steam cleaning throughout the carpet life.
Emissions to air from the use of after market applications for oil, soil and grease
repellents for apparel, upholstery and carpets are estimated to be minimal but will
contribute in the form of material disposal. For the semiconductor industry emissions
from critical uses were 54 kg in Europe which is approximately 10% of its use.
Waste containing PFOS
Recent studies confirm that WWTPs are significant sources for introduction of
perfluoroalkyl substances (including PFOS) to natural waters. Six WWTPs was analysed
in a study in New York State and PFOS was found to be ubiquitous in the effluents of
these WWTPsxii
There are no data to reflect the potential Canadian releases from the use and final
disposal of imported finished products that may contain PFOS as part of the fabric
finishes or coatings. Environmental releases from these surface treatments are expected
during use and may involve discharges to process wastewater and air during initial
applications.
Additional wastes occur from cutting, shearing or packaging operations and are generally
landfilled or recycled. End use of consumer articles will create additional losses.
Vacuuming and cleaning of carpets creates releases and final disposal of the treated
carpets is generally to the landfill. The use of after market applications for apparel,
upholstery and carpet will also result in additional landfill material.
A study of the possible releases from landfills and biosolid application fields has been
commissioned by Environment Canada. The final results of this study will be available in
June 2006. In the case of fire fighting foams, final disposal would be to waste treatment
facilities as well as uncontrolled releases to the terrestrial or aquatic environment
depending on the nature and location of the fire and the type (fixed versus portable) of
equipment used to contain it.
Possible alternatives for existing uses
The possible alternatives identified for the photographic industry are: digital techniques,
telomer-based products, C3 and C4 perfluorinated compounds, hydrocarbon surfactants
and silicone products.
According to the European Semiconductor Industry Association, while new techniques
are being developed where PFOS-related substances are not being used, there are no
5
alternatives available that would allow for comprehensive substitution of PFOS in critical
applications.
For hydraulic oils a change in the formulation of the oil seems to be the only alternative
solution. This will, however, demand a comprehensive testing together with an approval
from the airplane manufacturers, as safety standards within this industry are very high.
For decorative chromium plating an alternative process already exists. In this process
chromium(III) is used and no PFOS-chemicals are necessary. For hard plating, however,
the process with chromium(III) does not function as well. Instead larger closed tanks, or
increased ventilation combined with extraction of chromium(VI), are suggested as
alternative solutions for the applications where a use of chromium(III) is not possible yet.
In both cases exposure to chromium(VI), a known human carcinogen, will decrease,
which is an added benefit of the alternatives.
Possible management actions
For the surface protecting uses of PFOS e.g. in of carpets, leather, textiles, paper and
packaging, coatings, cleaning products and for pesticides/insecticides substitution has
largely occurred and there are alternatives which are judged to be less environmentally
damaging. Further investigation of some of the alternatives with respect to their costs and
environmental and health effects is needed.
For photography the potential alternatives identified are: digital techniques, telomerebased products, C3 and C4 perfluorinated compounds, hydrocarbon surfactants and
silicone products. The reduction by 83% in the EU photographic industry since 2000 has
been estimated to cost € 20-40 M per year. Further reductions will cost more per unit
since the uses that are easy to substitute have been eliminated first and the remaingn are
most likely more difficult to substitute.
For photolithography in the semiconductor industry some uses are presently vital. Once
substitutes are identified, the bulk of the costs are likely to be related to the change in
technology, i.e. investment costs, rather than running the new process. New techniques
are being developed for semiconductors where PFOS-relarted substances are not being
used, but there are no alternatives available at present that would allow for
comprehensive substitution of PFOS usies in critical applications.
The global semiconductor industry has recently announced a commitment to curtail
PFOS use and its intention to work to identify substitutes in critical applications. The
industry has committed to end non-critical uses in the UNECE region by May 2007.
Management options should consider time frames for the availability of substitutes.
For metal plating, alternative processes already exist for decorative chromium plating. In
this process chromium(III) is used and no PFOS-chemicals are necessary. For hard
plating the process with chromium(III) process does not function as well. Larger closed
tanks, or increased ventilation combined with extraction of chromium(VI) are suggested
as alternative solutions for the applications where a use of chromium(III) is not yet
6
possible. In both cases exposure to chromium(VI), a known human carcinogen, will
decrease, which is an added benefit of the alternatives. The financial gain of not using
PFOS may vary among enterprises according to their size and could be as large as the
cost of a new system.
For hydraulic fluids a change in the formulation of the oil seems to be the only alternative
solution. This will, however, demand a comprehensive testing together with an approval
from the airplane manufacturers, as safety standards within this industry are very high. At
present there is point uncertainty about alternative technologies/substances.
For waste containing PFOS consideration should be given to setting up a collection
programme for fire fighting foams and hydraulic fluids used in aviation. In the EU
hydraulic fluids used in aviation are managed as hazardous waste.
Cost implications
The cost of eliminating the surface protecting uses of PFOS is very low since industry
has largely substituted such use already (EU COM 2005). There are alternatives which
are judged to be less environmentally damaging.
For the other uses, photographic industry, photolithography and semiconductors, metal
plating and hydraulic fluids there is a need for special conditions. It would be difficult to
eliminate these uses at short notice.
Photography
The reduction by 83 % in the EU photographic industry has been estimated to cost € 2040 M/year during a few years (RPA 2004). Further reductions will cost more per unit
since the uses that are easy to substitute have been eliminated first and the remaining are
most likely more difficult (costly) to substitute.
Semiconductors
The total turnover of the semiconductor industry is € 213 billion and employs about half
a million people. More than 60 % of employment is in the USA and EU (SIA 2006).
Semiconductors constitute an important part of our modern society and they are used in
very many products. This does not automatically imply that PFOS, which is used in the
process, has such high value. Many functions can be materialized with alternative
substances. The main reason for using PFOS is high quality demands, i.e. precision in the
production process in order to guarantee good function.
For some uses this is vital and a total elimination without time derogations would be very
costly. The choice between applying PFOS or an alternative substance is a function of
several factors, of which one is the cost of PFOS. The main impediments that the industry
faces today are however related to the need for substitutes that will provide a comparable
level of performance to PFOS in advanced photolithographic applications where accuracy
7
is essential. The bulk of the costs are therefore likely to be related to the change in
technology, i.e. investment costs, rather than running the new processes.
Emissions from semiconductor industry may be less than half a percent of total PFOSemissions (SIA 2006. The statement can not be confirmed since data on all uses and
emissions are not available.). This proportion is increasing as PFOS use is reduced in
other sectors. The environmental and health risks of accepting this production is very
small compared to impacts of other uses.
Metal plating
The cost of improved ventilation with extraction, which is the recommended substitute
for PFOS based mist suppressants, has been calculated to be € 3400 per year in each
production unit where the investment period is 15 years (RPA 2004). Assuming a few
hundred units in the EU the total cost would be one or two million euros. PFOS will not
be needed if improved ventilation is used. The economic gain of not having to use PFOS
may be as large as the cost of the new system. The net cost is, thus, rather low but may
vary among enterprises. Air pollution control is relatively more costly to change for small
production units than for large.
The possibility to substitute chromium(VI) for other metal plating is mainly motivated by
the carcinogenic risks involved. If such substitution is successful, PFOS would not be
needed in the metal plating industry. This should be seen as a positive side effect rather
than a cost for reducing the use of PFOS.
Hydraulic oils
There are no economic calculations available.
Fire fighting foam and cost-effectiveness
Fire fighting foams are expected to have the longest in use lifespan since its use is based
on fire incidents and many organizations have already eliminated the use of fire fighting
foams for training exercises. An acceleration of the fire fighting foam use to achieve a
more rapid phase-out is unlikely to be pursued. No significant management costs are
anticipated with this turnover of existing PFOS based stock. It is cost-effective to destroy
the stocks when comparing with emission reduction options from other uses.
Costs of destruction of foam are about € 1000/tonne and new foam € 5000/tonne (the cost
of early renewal is much lower), while the cost of reducing the use of PFOS for
photolithography and semiconductors is € 2 M/tonne or more (Swedish estimates and
RPA 2004). The risks are also greater since the foam is spread directly into the
environment when used. The stock in the EU is 122 tonnes which shows that a significant
effect can be achieved. Even if only a fraction of the stock would be used it is costeffective to destroy the stock when comparing with the other options.
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Costs for consumers
Except where there are no substitutes, price increases for consumers are generally
expected to be very low since the alternatives are not very costly and the PFOS part is
small in most final products. The possible threat to the interests of consumers comes from
a loss of function that may be the result of elimination of uses where there are no
available alternatives. The costs could become very large, in particular for
semiconductors and hydraulic oils in aviation, in case of a total elimination without time
derogations.
Costs for state budgets
The costs for governments may depend on the action taken. There may be costs
associated with mandated control measures, e.g. in metal plating, photographic industry
and airplane maintenance. There may also be costs associated with monitoring and
controlling consumer products containing PFOS, especially imported products.
If taxes/charges are used at the national level to speed up the phase out process,
governments would receive revenue that could compensate for the control costs.
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Addendum
Additional information received in March 2007, collected
through questionnaires and not evaluated in the above report.
In response to a questionnaire developed by the Netherlands to assist the Task Force in
the evaluation of management options for the substances under consideration, responses
for PFOS were obtained from the following Parties to the Protocol (P), non-Parties (nonP) and observers (Obs):
Belgium (P)
Canada (P)
Cyprus (P)
France (P)
Germany (P)
Ireland (non-P)
Netherlands (P)
Switzerland (P)
United Kingdom (P)
United States (non-P)
Semiconductor industry (Obs)
Several questionnaires referred to information that had already been included in the
report to the 5th meeting of the Task Force in June 2006. The additional information is
summarized below. All figures are expressed as PFOS.
National and regional control actions taken
Canada has proposed regulation to prohibit the production and use of PFOS and its salts
and substances that contain on of the following groups C8F17SO2, C8F17SO3 or
C8F17SO2N (Canada Gazette, vol. 140, No 50, December 16, 2006).
The European Union has by adopting Directive 2006/122/EC of the European Parliament
and of the Council of 12 December 2006 amended for the 30th time Council Directive
76/769/EEC on the approximation of the laws, regulations and administrative provisions
of the Member States relating to restrictions on the marketing and use of certain
dangerous substances and preparations (perfluorooctane sulfonates).
The United States Environmental Protection Agency (US EPA) has adopted federal
Significant New Use Rules (SNURs) for 88 PFOS substances which apply to new
manufacture and new uses of these substances(40CFR 721.9852). A proposed SNUR for
183 additional perfluoroalkyl sulfonate substances was posted in April 2006 for public
consultations, and the publication of the final SNUR is expected in 2007.
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Total use
Switzerland gives several estimates for the current use of PFOS ranging from 230 kg/yr
to 5 tons/yr. The United States estimates total use to be less than 7.98 tons/yr (2006).
Semi-conductors
Ireland reports import and use of 10 kg during 2006. The semi-conductor industry reports
a non-critical use in the EU of 347 kg/yr for 2004. Figures are also given for countries
outside the UNECE region (Japan).
Emissions in the EU are estimated at 54 kg/yr to water (2004) for critical uses and 298
kg/yr for non-critical uses (2004).
Metal plating
Canada reports an estimated 3 metric tons used for metal plating in 2004. For the same
year and purpose they report an import of 3 tons from the United States.
France reports 200 kg used for metal plating during 2006.
Fire fighting foams
Canada reports use of 300 kg during 2004.
Stockpiles and waste
Canada reports an estimated 3 tons of PFOS in stockpiles of fire fighting foams, of whihc
10% is estimated to be expended each year.
Switzerland reports an estmate fo the flow of PFOS from use to waste ranging from 5 to
17 tons/yr before 3M production ceased in 2001.
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i
Results Of Survey On Production And Use Of PFOS, PFAS and PFOA, Related Substances And
Products/Mixtures Containing These Substances, OECD, ENV/JM/MONO 2005, 1
ii
Sulphonated Perfluorochemicals in the Environment: Sources, Dispersion, Fate and Effects (AR2260545). 3M Company, St Paul, MN. 2000
Sulphonated perfluorochemicals: U.S. release estimation – 1997. Part 1: Life-cycle waste stream
estimates, Final report, 3M, Battelle Memorial Institute, Columbus, Ohio, United States of America, 2000
iii
iv
Martin, J.W.; Muir, D. C. G.; Moody, C. A..; Ellis, D.A..; Kwan, W. C.; Solomon, K. R.; Mabury, S. A.
Collection of airborne fluorinated organics and analysis by gas chromatography/chemical ionization mass
spectrometry. Anal. Chem. 2002, 74, 584-590.
v
Kissa, E. Fluorinated Surfactants and repellents, 2nd ed.; Marcel Dekker: New York, 2001.
vi
U.S. Environmental Protection Agency. Perfluorooctane sulphonates; proposed significant new use role.
Fed Regist. 2000, 65, 62319-62333
vii
Tomy, G. T.; Tittlemier, S. A.; Palace, V. P.; Budakowski, W. R.; Braekevelt, E.; Brinkworth, L.;
Friesen, K. Biotransformation of N-ethyl perfluorooctanesulphonamide by rainbow trout (Onchorhynchus
mykiss) liver microsomes. Environ. Sci. Technol. 2004, 38, 758-762
viii
Tomy, G.T.; Budakowski, W.; Halldorson, T.; Helm, P.A.; SternG. A.; Freisen, K.; Pepper, K.;
Tittlemier, S. A.; Fisk, A. T. Fluorinated organic compounds in an eastern Arctic marine food web.
Environ.Sci Technol. 2004, 38, 6475-6481
ix
Bossi, R.; Riget, F. F.; Dietz, R. Temporal and spatial trends of perfluorinated compounds in ringed seal
(Phoca hispida) from Greenland. Environ. Sci. Technol. 2005, 39, 7416-7422
x
Kartlegging av PFOS I brannskum, SFT report, TA-2139/2005, ISBN 82-7655-275-7, (Summary
available in English), http://www.sft.no/publikasjoner/kjemikalier/2139/ta2139.pdf
xi
Risk & Policy Analysts Limited (RPA) in association with BRE Environment, Perfluorooctane
Sulphonate – Risk reduction strategy and analysis of advantages and drawbacks, Final Report prepared for
Department for
Environment, Food and Rural Affairs and the Environment Agency for England and Wales, 2004.
xii
Sinclair, E.; Kannan, K. Mass Loading and Fate of Perfluoroalkyl Surfactants in Wastewater Treatment
Plants, Environ. Sci. Technol., 40 (5), 1408 -1414, 2006
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