27 June 2019, The Member State Committee (MSC) unanimously agreed to identify 2,3,3,3-tetrafluoro-2-(heptafluoropropoxy)propionic acid, its salts and its acyl halides (covering any of their individual isomers and combinations thereof) (denoted as HFPO-DA) as substances of very high concern (SVHCs). ECHA will include the newly identified SVHCs in the Candidate List by mid-July 2019.
The substances are used as processing aids for producing fluoro-polymers with many applications, such as fluoropolymer resins, wire cables and coatings. They were proposed by the Netherlands due to their properties which cause probable serious effects to human health and the environment, giving rise to an equivalent level of concern to carcinogenic, mutagenic and reprotoxic (CMR), persistent, bioaccumulative and toxic (PBT) and very persistent and very bioaccumulative (vPvB) substances.
At its meeting early this week, the MSC acknowledged that HFPO-DA has a high potential to cause effects in wildlife and in humans through the environment due to its very high persistence, mobility in water, potential for long-range transport, accumulation in plants and observed effects on human health and the environment.
Furthermore, the committee noted the lack of known natural removal of HFPO-DA once released, leading to a continuous presence in water and resulting in the continuous bioavailability of these substances. It also noted the expected exposure through the food chain and drinking water, as well as difficulties to remediate polluted media and remove HFPO-DA from drinking water.
Together, these contribute to a high potential of these substances for continuous, increasing and widespread exposure which would be difficult to reverse. While in isolation none of these observations may be of equivalent level of concern, the MSC unanimously agreed that in combination they show that there is scientific evidence of probable serious effects to the environment and humans. The MSC also noted that co-exposure to other contaminants with similar effects may occur, which strengthens the concern for HFPO-DA.
C&K Testing reminds that companies may have legal obligations with respect to these substances once they are published in the updated Candidate List.