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Regulating “forever chemicals”: social data are necessary for the successful implementation of the essential use concept
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This paper proposes a framework for regulating PFAS, also known as "forever chemicals," using the Essential Use Concept, which assumes a chemical should be phased out unless proven necessary and without alternatives. While focused on PFAS rather than microplastics, the regulatory approach is relevant because both are persistent synthetic pollutants that accumulate in the environment and human body. The authors argue that effective regulation requires input from affected communities, not just scientists.
Abstract Per- and polyfluoroalkyl substances (PFAS) are a large class of synthetic compounds, many of which are persistent, mobile and toxic (PMT). The sheer number of PFAS makes a substance-by-substance based approach to regulating this group unfeasible. Given the known risks of many PFAS, a precautionary approach (i.e., the Essential Use Concept; EUC) has been called for, whereby any substance is assumed to be harmful and should be phased out, unless it is shown that: (a) the use of this substance is necessary for health and safety, or is critical for the functioning of society and (b) there are no available technically and economically feasible alternatives. While experts, including chemists and toxicologists, are well-placed to assess the second criteria, determining what is necessary for the “functioning of society” requires a wider consideration of societal beliefs and preferences and greater involvement of various interested and affected parties, especially those whose voices are less heard but may be most vulnerable. The aim of the current paper is to provide a preliminary framework and research agenda outlining why and at what points in the essential use decision-making process broader societal perspectives are required, and how such ‘social data’ can be collected. The ultimate goal is to improve chemicals management by supporting citizens in becoming more informed and engaged participants in relevant debates and policies, including in how to operationalise the EUC.
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