In the wake of a Health and Safety Executive report recommending new restrictions on toxic  ‘forever chemicals’, an environmental charity has called for more monitoring and testing in Scotland.

Dr Clare Cavers, senior project manager at environmental charity Fidra, called on the Scottish Government, SEPA and Scottish Water to “increase monitoring in high-risk areas like sensitive environmental areas, or those military sites, airfields or industrial sites”.

The group of chemicals, known as per- and poly-fluoroalkyl substances (PFAS), are according to Dr Richard Daniels, director of HSE’s chemicals regulation division, a “global issue of concern”. But, across the UK we still test for relatively few of them, and a data gap exists between Scotland and England.

The HSE report even acknowledges that Scottish data was omitted “because the English monitoring data are more extensive and can be extrapolated as providing a relevant picture for the whole of the UK".

PFAS have been around since the 1950s, and have multiple uses, from non-stick pan coatings to textiles waterproofing and firefighting foam. 

Several PFAS have already been banned – the Stockholm Convention lists perfluorooctane sulfonate (PFOS), perfluorooctanoic acid (PFOA), and perfluorohexane sulfonate (PFHxS) as Persistent Organic Pollutants - but even these remain in the environment since they do not break down easily. Hence the name ‘forever chemicals'.

The concern is increasing as research has begun to find PFAS almost everywhere, from the foods we consume to human blood, from household dust to toilet paper, and even in the Arctic ice around Svalbard.

This rise in ubiquity has coincided with growth in the body of research showing links between exposure to some of the chemicals and low foetal weight, thyroid function problems, obesity, increased lipid levels and liver function and impaired vaccine response.

A recent US study of young children, teens and young adults, found all of them had a mixture of PFAS in their blood, and that this exposure “not only disrupted lipid and amino acid metabolism but also altered thyroid hormone function in the children”.

A review of research found the chemicals had been detected in every umbilical cord blood sample across 40 studies, which collectively included nearly 30,000 samples. 

“There has been,” said Clare Cavers, “a lack of urgency over these chemicals because they are not immediately toxic. But they are building up in our bodily systems. They are building up in the environment. They are building up in our food chains. They're called forever chemicals because they stick around. We’re heading towards a perfect storm if we don’t address it now.”

Compared to England, Scotland has done less monitoring. A recently published map of sites in Europe where PFAS had been identified at 10ng/l or over contained only four sites for Scotland, compared with a multitude of sites across England.

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Does this mean we are relatively PFAS-free? Perhaps, but without more widespread monitoring we cannot be sure.

“The lack of contamination sites,” said Cavers, “is likely to be down to a lack of monitoring. There has been a Chemicals Investigation Programme running in the UK, including in Scotland, but there is a difference in that the data in Scotland is not openly accessible, compared to the England data which is openly accessible.”

Forever chemicals don't just affect us - they also impact wildlife. A recent project carried out by the US Environmental Working Group mapped studies which have found the chemicals in wildlife.

Two of the three sites in which PFAS has been found in UK wildlife are in Scotland, where PFAS have been measured in gannets and shags. One of these, which tested gannet eggs on Ailsa Craig and the Bass Rock found that ten per cent of the eggs exceeded levels that might have an adverse effect.

The legislation around PFAS is complex, with some aspects (monitoring) devolved and others (chemical regulations) reserved. Key to averting this potential timebomb is a combination of approaches including monitoring and testing, restrictions on the use of these chemicals in industry and products and removal from the environment.

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Scotland is now in the third phase of its Chemical Investigations Project. In September 2021 it began sampling the final sludge product from two of Scottish Water’s sludge treatment centres. This follows on from the second phase, in which during 2018, SEPA monitored levels of 9 PFAs (including PFOS and PFOA) in 22 rivers across Scotland.

65% of the 550 data points, SEPA said, were below limits of detection, and in only three instances (two locations) were results >10ng/l reported.

During the same year, monitoring also included two estuary locations. In these  73% of the 55 data points reported were below the limits of detection, and no results under the guideline of 10ng/l were reported.

Between 2009 and 2016 SEPA carried out surveys of fifteen PFAs at 24 groundwater locations. 95% of the 2123 data points from 24 locations were below the limit of detection, with 2% of results less than 10ng/l.

Compare this with a 2021 report, which said that the Environment Agency had sampled, since 2016, 470 freshwater sites and 55 estuarine coastal locations in England for PFOS and PFOA as part of their routine surveillance monitoring programme. They also sampled groundwater at 322 sited and conducted additional surface water sampling across fresh, estuarine and coastal water sites.  

A spokesperson for SEPA  said: “Chemicals play an intrinsic part in modern living and SEPA, as Scotland’s environmental watchdog, has been working for some time to assess and reduce their environmental impacts. 

“We’ve proactively undertaken monitoring programmes for several different per- and poly-fluoroalkyl substances (PFAS). Scientific understanding of the sources, environmental concentrations, and risks of PFAS in the environment is continuing to develop, and SEPA continues to review our evidence-gathering approach, working with partners. This includes plans to develop our capability to monitor for a larger range of PFAS at a wider range of monitoring locations. We are also considering how best to make our data more readily available.    

The chief sources of possible exposure to PFAS are drinking water, airborne inhalation and ingestion of contaminated food. The Public Water Supplies (Scotland) Regulations 2014 was amended in 2022 and now includes a standard of 0.1 ug/l for the sum of 20 named PFAS.

A Scottish Water spokesperson said: “Scottish Water takes its responsibility to provide excellent quality drinking water to its customers extremely seriously. The drinking water we provide in Scotland adheres to some of the most stringent standards in the world, as set out and regulated by Drinking Water Quality Regulator for Scotland.

“We monitor water sources and review the summary of test results and risk assessments on an ongoing basis. If the risk assessment shows there are reasonable grounds to believe that there may be PFAS in the raw water supply, Scottish Water carries out sampling by regulation 10 of the Public Water Supplies (Scotland) Regulations 2014.”

Based on its current risk assessment and sampling programme, Scottish Water has seven sites that it monitors monthly; 17 sites it monitors four times per year; and 8 sites it test two times per year.

The spokesperson said: “We currently provide drinking water via 225 water treatment works across Scotland and, during 2023, we plan to sample each of these works at least once for the sum of PFAS compounds.”

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“It is important to note that we have relatively low levels of these chemicals in Scotland as the country is not densely populated and we do not have a lot of heavy industry.”

Dr Cavers would like to see more extensive testing in Scotland, particularly monitoring away from sewage works. She said: “Wastewater treatment is just a starting point. We have not been looking at industrial areas and ex-industrial areas which are probably where we’re going to find high concentrations”

“Military and industrial sites," she said, "are areas that should be pin-pointed ”

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Another area of concern in terms of contamination is sewage sludge, the product of wastewater treatment works that currently gets spread in many of our fields.

“Sewage sludge,” said Cavers, “is likely to have a high concentration of PFAS because you’ve removed it from the water, which is great, but you’ve then put it into the sewage sludge which is then going on the farmland, which is then going into our crops.”

The HSE Regulatory Management Option Analysis (RMOA) report has recommended limiting the use of PFAS-containing foams used by firefighters to put out fires, as well as the use of PFAS in textiles, furniture, and cleaning products.

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In response to these recommendations, Dr Cavers said: “We welcome the grouping approach that has been taken in the RMOA, but do feel the scope is too narrow and will not adequately address the wide range of sources of PFAS into our environment. While we appreciate this is a first step, there needs to be a broader phase-out of PFAS and a movement towards a PFAS-free economy. By not addressing all PFAS sources there is a risk that harmful impacts on our wildlife, and human health, may continue. We would like to see a tougher approach to phase out more PFAS in alignment with those proposed in the recent EU restriction proposal.”

Among Fidra’s specific concerns was the recommendation on food packaging. “We are disappointed that it is not included, but that instead it ‘may be considered’. There is a clear precedent already set by Denmark, which has banned PFAS in food packaging, and several of the US states.”