Inconsistencies in the EU regulatory risk assessment of PFAS call for readjustment.

Recognition of per- and polyfluoroalkyl substances (PFAS) as widespread environmental pollutants and a consequent risk to human health, has recently made the European Union (EU) adopt several regulatory measures for their management. The coherence of these measures is challenged by the diversity and the ubiquitous occurrence of PFAS, which also complicates the EU's endeavor to advance justified, harmonized, and transparent approaches in the regulatory assessment of chemical risks. Our study critically reviews the European approach for the risk assessment of PFAS, by applying a comparative analysis of the current and pending regulatory thresholds issued for these chemicals in water bodies, drinking water, and certain foodstuffs. Our study shows that the level of health protection embedded in the studied thresholds may differ by three orders of magnitude, even in similar exposure settings. This is likely to confuse the common understanding of the toxicity and health risks of PFAS and undermine reasonable decision-making and the equal treatment of different stakeholders. We also indicate that currently, no consensus exists on the appropriate level of required health protection regarding PFAS and that the recently adopted tolerable intake value in the EU is too cautious. Based on our analysis, we propose some simple solutions on how the studied regulations and their implicit PFAS thresholds or their application could be improved. We further conclude that instead of setting EU-wide PFAS thresholds for all the environmental compartments, providing the member states with the flexibility to consider case-specific factors, such as regional background concentrations or food consumption rates, in their national regulatory procedures would likely result in more sustainable management of environmental PFAS without compromising the scientific foundation of risk assessment, the legitimacy of the EU policy framework and public health.

The occurrence, distribution, and risks of PFAS at AFFF-impacted sites in Finland.

Per- and polyfluoroalkyl substances (PFAS) comprise a wide group of persistent chemicals, whose ubiquitous occurrence in the environment, particularly due to their extensive use for fire suppression in aqueous film forming foams (AFFFs), has raised global attention. We evaluated the impacts of PFAS at three firefighting training sites and one industrial site in Finland, to highlight key elements to be considered in the retrospective risk assessment of these chemicals. The site assessments covered the occurrence and distribution of 23 PFAS in multiple environmental matrices, i.e., soil, sediment, surface water, groundwater, and biota, and the subsequent risks to human health and the environment owing to the migration of and exposure to the selected compounds. Our study showed that the extensive use of nowadays restricted or substituted PFAS, particularly PFOS, are still often the predominant compounds detected at AFFF-impacted sites and will continue to cause long-term risks to the environment. The most significant environmental or health risks at these sites are likely to concern aquatic ecosystems, fish consumption or groundwater usage due to the off-site migration of PFAS. Here, even a single fire extinguishing event can be a considerable contributor. We also illustrate that conventional procedures based on simple mass-balance, and exposure models, with a focus on PFOS and other site-specifically relevant PFAS may provide sufficient means to assess the risks. Moreover, we address that despite the exceedance of the very stringent regulatory threshold values issued recently for PFAS, the actual site-specific risks to human health and the environment may remain reasonably low.

Finnish policy approach and measures for the promotion of sustainability in contaminated land management.

The importance of sustainability considerations in contaminated land management (CLM) is highlighted in policy frameworks all around the world. It means that while the reduction of risks to human health and the environment remains the main goal of CLM, a variety of other environmental factors as well as economic and social aspects have an increasing role in decision making. The success of finding the right balance between these considerations and incorporating them in the risk management approach defines the overall sustainability of the outcome. Although the concept and principles of sustainable CLM are already widely accepted, they have not been fully realized in national procedures. According to several studies this often results from the lack of explicit policy measures. A sound policy framework in conjunction with functional policy instruments is therefore a prerequisite for the attainment of sustainable practices. In Finland, the environmental administration along with other key stakeholder groups, including regional authorities, landowners, consultants, industries, research institutes and academia, has developed a national strategy and associated policy measures in order to promote sustainable CLM.

Promoting justified risk-based decisions in contaminated land management.

Decision making and regulatory policies on contaminated land management (CLM) are commonly governed by risk assessment. Risk assessment, thus, has to comply with legislation, but also provide valid information in terms of actual risks to correctly focus the potentially required measures and allocate the available resources. Hence, reliable risk assessment is a prerequisite for justified and sustainable risk management. This paper gives an introduction to the Finnish risk-based regulatory framework, outlines the challenges within the policies and the practice and provides an overview of the new guidance document to promote risk-based and sustainable CLM. We argue that the current risk assessment approaches in the policy frameworks are not necessarily efficient enough in supporting justified risk-based decisions. One of the main reasons for this is the excessive emphasis put on conservative risk assessments and on generic guideline values without contributing to their appropriate application. This paper presents how some of the challenges in risk-based decision making have been tackled in the Finnish regulatory framework on contaminated land. We believe that our study will also stimulate interest with regard to policy frameworks in other countries.

TAPIR--Finnish national geochemical baseline database.

In Finland, a Government Decree on the Assessment of Soil Contamination and Remediation Needs has generated a need for reliable and readily accessible data on geochemical baseline concentrations in Finnish soils. According to the Decree, baseline concentrations, referring both to the natural geological background concentrations and the diffuse anthropogenic input of substances, shall be taken into account in the soil contamination assessment process. This baseline information is provided in a national geochemical baseline database, TAPIR, that is publicly available via the Internet. Geochemical provinces with elevated baseline concentrations were delineated to provide regional geochemical baseline values. The nationwide geochemical datasets were used to divide Finland into geochemical provinces. Several metals (Co, Cr, Cu, Ni, V, and Zn) showed anomalous concentrations in seven regions that were defined as metal provinces. Arsenic did not follow a similar distribution to any other elements, and four arsenic provinces were separately determined. Nationwide geochemical datasets were not available for some other important elements such as Cd and Pb. Although these elements are included in the TAPIR system, their distribution does not necessarily follow the ones pre-defined for metal and arsenic provinces. Regional geochemical baseline values, presented as upper limit of geochemical variation within the region, can be used as trigger values to assess potential soil contamination. Baseline values have also been used to determine upper and lower guideline values that must be taken into account as a tool in basic risk assessment. If regional geochemical baseline values are available, the national guideline values prescribed in the Decree based on ecological risks can be modified accordingly. The national geochemical baseline database provides scientifically sound, easily accessible and generally accepted information on the baseline values, and it can be used in various environmental applications.

Application of arsenic baselines in the assessment of soil contamination in Finland.

In Finland, a new Government Decree on the Assessment of Soil Contamination and Remediation Needs (214/2007) came into force on 1 June 2007. According to the Decree, natural baseline concentration levels should be taken into account when assessing potential soil contamination and the need for remediation. This applies particularly in the case of toxic metallic elements, since baseline concentrations may naturally be rather high. The new decree prescribes soil screening values for 52 substances or groups of substances. The natural baseline concentrations have been taken into account in the definition of the screening values for inorganic pollutants. The Geological Survey of Finland (GTK) carried out a nation-wide geochemical mapping of till on a reconnaissance scale in 1983 and on a regional scale during 1984-1992. These surveys have provided information on natural elemental distribution in subsoils of the glacial till. However, some important trace elements in regional mapping such as arsenic are missing from the analysis, and subsoil samples do not reflect the diffuse anthropogenic input. Thus, GTK has continued the survey work by determining geochemical baselines around suburban areas. Samples have been taken from humus, topsoil and subsoil layers, and the soil parent material has covered sandy soils, glacial tills and fine-grained sediments. According to the studies, a regional difference in the levels of arsenic and some other trace elements can be clearly seen, especially in minerogenic soils. The results illustrate the importance of information on regional baseline concentrations while assessing potential soil contamination.