Kortlægning af perfluorooktanylsulfonat og lignende forbindelser i forbrugerprodukter - fase 2

Summary and Conclusions

This project has enabled the Danish EPA to gain an overview over which types of products on the Danish market may contain perfluoroctanylsulfonates and related chemical substances (PFOS-compounds). These substances have been placed on the agenda during recent years because the substances or their degradation products are persistent in the environment and can bioaccumulate. The group of PFOS-compounds includes 175 substances all of which may potentially be degraded to perfluoroctanylsulfonates. Under normal circumstances perfluoroctanylsulfonates degrade very slowly and may bioaccumulate in animals and humans.

The study has been based on OECD's classification of PFOS-compounds into 22 categories. In all 75 CAS-numbers from 17 of these categories are registered in the Danish Products Data Register. Categories 1, 2 and 8 are represented by the largest number of CAS-numbers, 10, 10 and 12 respectively.

PFOS-compounds are used in a large number of products. The substances have been assessed based on a search in the Products Data Register and contact with the marketing players has been most widespread for the following types of products:
Impregnation agents for textiles, leather and paper
Wax and other polishes
Paint, varnish and reprographic agents
Cleaning products both general cleaning products and products used to clean metal surfaces or carpets

Of products with a lesser consumption may be mentioned flame-retardants and mould release agents.

The largest groups of products to be found in the Products Data Register are the categories "wax and other floor polishes", "paint and varnish" and "reprographic agents". Many products containing PFOS-compounds would not however be notified and are therefore not represented in the Products Data Register. Most of the PFOS-compounds are not present on Annex I, "The List of dangerous substances" and therefore do not contribute to the classification of the products they are contained in, but the substances will often be registered if the products contain other substances which are subject to notification.

The total registered sale in Denmark of PFOS-compounds contained in products is in the order of 8-16 tons per annum. Products for impregnating leather and paper as well as paints/varnishes and reprographic agents are represented by the largest amount in the Products Data Register.

However, as many products/materials - for example many textiles, wax and polish products - are not subject to notification the registered amounts do not give an adequate picture of the total sales in Denmark. Thus there are indications that the import for use in production of materials is larger than the registered amount. In addition many products, such as textiles, leather and paper goods impregnated with PFOS-compounds, are imported without being registered in the Products Data Register. However, it cannot be ruled out that Notifiers when notifying products, which are subject to notification also, chose to register non-notifiable products. If one considers the amounts registered in the Products Data Register (8-16 tons per annum) and the marketing players information about non-registered amounts, it is estimated that the total Danish consumption (registered and non-registered) is in the order of 5-50 tons per annum.

The study has attempted to verify and supplement data from the Products Data Register with information from the relevant industry. All the most important application fields have been verified, with the exception of paints/varnishes.

The paint/varnish trade has stated that by and large PFOS-compounds are not used any more, but it cannot be denied that the compounds could occur in certain imported products. It is estimated that the consumption of PFOS-compounds by firms represented by the industry’s trade association hardly amounts to more than a few kilos. To this must be added the consumption by firms who are not members of the industry’s trade association. As members of the trade association accounts for the largest part of the total sales of paint/varnish products, this consumption is not estimated to be very extensive.

In certain cleaning products and polishes produced in Denmark PFOS-compounds are used more deliberately.

It has generally been difficult to obtain more precise non-confidential information of quantities of PFOS-compounds, partly because many Danish consumers of raw materials and importers of finished goods do not know whether the products contain PFOS-compounds, and partly because the information must be treated as confidential. Danish producers advise that they often do not know whether their products might contain PFOS-compounds but cannot rule out that PFOS-compounds are actually contained in the raw materials used. As PFOS-compounds are not classified as to toxicity and ecotoxicitity, they are often not mentioned in safety data sheets.

In the Products Data Register the function of substances is primarily registered as being the main ingredient and/or having surface activity properties. According to market players the dominant function in most products is that the use of PFOS-compounds results in the product attaining a high degree of dispersal - that is to say the product disperses easily over the desired area and smooths out irregularities. This function is used particularly in floor polish, paint, varnish, reprographic agents etc.

Apart from the intended use of PFOS-compounds the substances may also appear as impurities in products which contain polymers of fluor carbons. This is particularly the case with impregnation products where PFOS-compounds may appear as impurities on the level of parts per million (ppm).

The largest international producer 3M has phased out the major part of its production with the exception of PFOS-compounds used for example for flame retardant purposes in airplanes. On the European market, however, this has meant that many consumers have switched to other suppliers who base their deliveries on producers who have continued their production of PFOS-compounds/perfluor-compounds.

According to the industry, PFOS-compounds are used only in very modest amounts in the production of paint/varnish and reprographic agents in Denmark. In cleaning products for industrial use a substantial amount of substitution has taken place but for other product groups there does not appear to have been a marked shift away from the use of PFOS-compounds.

To summarise, the conclusion must therefore be, that:
PFOS-compounds are used in Denmark
That there is no conformity between the information which may be extracted from the Products Data Register and that which is notified by the industry, which is why the extent of consumption can only be stated with a degree of uncertainty. An uncertainty which may be due either to the importer being unaware of the precise composition of the chemical raw materials and finished goods they import or that the enterprises, who are responsible for the notification of data, have failed to discharge their duty to inform the Products Data Register of changes in composition, amounts and the turnover of the products.

Based on the results of this project the Danish EPA have decided to carry on the work of studying the content of some PFOS-compounds in wax/floor polishes and in impregnating agents which may be purchased from retail outlets.