A number of scientists known as the Global PFAS Science Panel argue for listing persistence as a stand-alone hazard class in the CLP Regulation. They raised the argument in their comments on the schedule that the EU published at the end of March for a planned revision of the CLP Regulation.
The very fact that a chemical is not degradable is enough to classify it as hazardous, say the authors in their statement. They see the worst environmental damage being done by highly persistent chemicals like polychlorinated biphenyls (PCBs), chlorofluorocarbons (CFCs), and per- and polyfluoroalkyl substances (PFAS). They add that the use of such chemicals is inconsistent with the EU Chemicals Strategy for Sustainability.
The authors refer to the regulations in California as a model that implements this approach to persistence to protect human beings and the environment.
However, the EU plans to combine the criterion of persistence (P) with others, such as bioaccumulation (B), mobility (M), and toxicity (T), thus creating the following new hazard classes:
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