Facts about PFAS and SRF reporting

1. PFAS are considered ‘harmful’ by SRF

Per- and polyfluorinated alkyl substances (PFAS) are chemical substances that have become indispensable in a wide range of products due to their strength, durability, stability and resistance. These properties are crucial for the reliable and safe functioning of a wide range of products that are important for trade, industry and consumers:

• An integral part of modern life: PFAS are a diverse universe of chemicals that are essential to modern life. Countless everyday products are currently manufactured using PFAS – be they clothes, kitchen appliances or packaging.

• Use in trade and industry: PFAS are a component of many seals and are needed to manufacture computer chips or solar cells. However, commercial and industrial customers also benefit from the fact that production facilities can be used for longer.

• Healthcare and research: a large number of human and veterinary medicines contain PFAS as active ingredients. They are also practically indispensable in diagnostics and scientific research and development.
   
• Energy efficiency and renewables: PFAS seal building envelopes and are an integral component of photovoltaic systems, battery storage and water turbines, whose functionality could not otherwise be guaranteed. PFAS also enable heat transport in the living and working spaces of a large proportion of the heat pumps installed in Swiss residential buildings today.
   
• Reducing resources and waste: PFAS help to reduce resource consumption and the amount of waste generated. Thanks to their special properties, they extend the lifespan of products for end consumers. In their efforts to protect human health and the environment, manufacturers of PFAS chemicals have developed numerous practices and technologies that minimise environmental emissions.

Many PFAS are in fact difficult to break down due to their unique stability. Some PFAS are water-soluble and therefore mobile, some are toxic, which is why regulatory authorities worldwide are called upon to protect people and the environment. However, research by authorities such as the US Environmental Protection Agency (EPA) and the New York Department of Environmental Conservation has shown that PFAS chemicals can be broken down through proper waste management. This means that potential problems at the end of the life cycle can be effectively addressed.

Together with other industry and business associations, scienceindustries is committed to the safe handling of PFAS chemicals for humans and the environment and the proportionate setting of limit values. This involves weighing up the pros and cons of using specific chemicals. In addition, knowledge of the properties of the specific chemicals must be available, possible alternatives must be evaluated if necessary, and their use in industry, trade and by private consumers must be known. PFAS manufacturing companies want to be part of the solution, whether in terms of responsible production or the use of the chemical substances.

2. Regarding the OECD criteria and the classification of fluoropolymers as ‘polymers of low concern’

The SRF report criticises the fact that fluoropolymers have been classified as ‘of little concern’ even though the OECD is said not to have defined any such criteria. This is not the case:

• Historical classification of polymers: In the past, polymers were generally considered to be ‘polymers of low concern’ due to their low bioavailability and high stability. This is enshrined in both Swiss and EU chemicals legislation.
   
• OECD discussions: fluoropolymers have been discussed in OECD working groups. The distinction between ‘polymer of concern’ and ‘polymer of low concern’ is based on scientific criteria such as molecular weight and monomer units. These discussions are documented and have been correctly reproduced by scienceindustries.
   
• Low risk potential: We emphasise that the chemical and physical properties of fluoropolymers pose a low risk to humans and the environment. The claim that industry is relying on false OECD statements is therefore unfounded.

In the Swiss TV programme ‘Kassensturz’ on 14 January 2025, Prof. Martin Scheringer (ETH Zurich) confirmed that fluoropolymers per se have no negative impact on human health. The following should be noted in this regard:

• Substance properties versus life cycle: Of course, in addition to considering the properties of a chemical substance, its life cycle must also be considered, i.e. its production and, where applicable, recycling and disposal. Thanks to risk management measures, the risk of substances and manufacturing processes having a negative impact on people and the environment is constantly being reduced. Risk management is a permanent improvement process.

• Risk management measures are having an effect: Industry and the general public have been using safe fluoropolymers in almost all areas of life for decades. Thanks to risk management measures, similar substances, such as those produced 50 or more years ago, now have far fewer negative environmental effects, even though the quantities produced have multiplied. For example, newer production facilities are better sealed than older ones; improved processes and components, including fluoropolymers in some cases, further reduce the likelihood of accidents and thus the risk of releases.

3. PFAS and their alternatives

The SRF investigation criticises the fact that scienceindustries and other stakeholders claim that there is no alternative to PFAS in many areas, without providing sufficient evidence to support this. The group of substances that fall under the PFAS definition includes thousands of compounds from different substance classes, with very different properties and areas of application, which cannot be assessed in a blanket way.

• Example: medical technology: fluoropolymers, i.e. solids, are used in minimally invasive surgical instruments because they combine properties such as biocompatibility, low friction, high electrical insulation capacity and high chemical and thermal stability. Individual alternatives are known, but mainly for applications that require only a few of the many special properties of fluoropolymers. In areas of application such as medical technology, which require a whole range of these properties at the same time, intensive research into alternatives has so far been unsuccessful. This makes fluoropolymers irreplaceable for such applications for the foreseeable future, according to current knowledge.
   
• Example: Heat pumps: Many heat pumps installed in Switzerland use PFAS-based heat transfer fluids – these are gases. A transition to alternative media requires long-term planning, since existing systems cannot simply be operated with a different gas that has different properties, but would have to be completely replaced. This would result in high costs for consumers and would entail conflicting sustainability goals. Furthermore, alternative systems that use ammonia or propane/butane mixtures pose alternative risks (ammonia is acutely toxic, propane/butane mixtures are extremely flammable). In addition, the limited availability of alternative systems and the specialist personnel required to install them is slowing down the timely replacement of existing PFAS-based systems. In Switzerland alone, tens of thousands of such systems have been installed in the last 10 to 20 years, subsidised by the federal government's buildings programme, to replace oil and gas heating systems.
   
• Other applications: PFAS will remain essential for the foreseeable future in electronics, for example in semiconductors or lithium-ion batteries, due to their stability and performance. They are also used in the textile industry, where water-repellent properties are required.

Although alternatives do exist in some areas, they are often not yet available on an industrial scale or are less efficient or have other undesirable effects. Research and development is focusing on creating more sustainable alternatives that offer the same properties.

4. Costs of PFAS remediation

The remediation costs cited by SRF are based on hypothetical scenarios. The Swiss Federal Audit Office (SFAO) recommends examining how the polluter pays principle can be designed in the future so that manufacturers and importers have to contribute financially to the remediation of damage.

• More knowledge needed: scienceindustries is somewhat critical of this recommendation as long as there is no better understanding of the actual causes and emission pathways.
   
• The polluter pays principle works: in the view of the industry, the existing approach of holding the polluter responsible works well enough and already requires the polluters of environmental contaminants, whether companies or private individuals, to provide material remediation and financial compensation for the damage they have caused.
   
• Bureaucracy and control: There are also doubts as to how a change to the previously well-functioning process should be implemented in practice without an escalating bureaucracy and control system significantly increasing prices for consumer products as well as for products used commercially and industrially, and making Switzerland, which is already an island of high prices, even more expensive.

The industry is working hard to minimise unintentional emissions and to remediate existing contamination. This includes efforts to learn more about the actual sources and emission pathways, to actively participate in the remediation of environmental contamination through research and development, and to support the authorities with expertise wherever possible.

5. Regulatory approach: differentiation instead of blanket bans

A comprehensive PFAS ban does not do justice to the diversity of the substance group and its applications:

• Targeted regulation: Switzerland has already introduced strict rules for PFAS in areas such as fire extinguishing foams and heat transfer media. Only recently, the federal government has put forward further restrictions for certain areas of application for consultation – scienceindustries will comment on these in due course. Blanket bans could hinder innovative developments and introduce alternative substances without comprehensive environmental assessment.
   
• Sustainable development: Science-based regulation that balances risk and benefit is crucial to ensure sustainable development.

Conclusion

scienceindustries is committed to a fact-based, nuanced discussion. We demand that reporting remains objective and takes into account the complexity of the issues. Scientific findings and the industry's perspective should be given equal weight in political decision-making to ensure a sustainable and innovation-friendly future. Our detailed answers to the SRF questions, which are partly based on false facts and unfounded accusations, can be found here: scienceindustries - Questions & Answers Kassensturz on PFAS