PAN Europe welcomes the opportunity to provide comments on the EFSA’s Draft statement on consumer health-based guidance values on trifluoroacetic acid.
Our organisation is closely following the developments related to TFA, as it is a common degradation product of 30 PFAS pesticide active substances approved and used in numerous pesticide products across Europe. The use of PFAS pesticides has increased over the past 10 years, as shown by rising residue levels in fruit and vegetables, as well as sales data where available. Most PFAS pesticides contain at least one -CF3 group and are a significant source of TFA contamination into the environment and water resources. Our preliminary work has shown that TFA is detected in water resources across all of Europe, including drinking water, both tap or mineral bottled water, as well as groundwater. It is also detected in plant-based products such as wine, bread and cereals.
Scientific evidence clearly indicates that this very persistent and very mobile metabolite has the potential to cause liver toxicity, impair foetal development and fertility. Because of its properties, scientist have warned that it must be considered a threat to our planetary boundaries. Given that human and environmental exposure to TFA is already widespread and rapidly increasing, it is of utmost importance to conduct an objective, independent, and thorough investigation of the toxicity of this common pesticide metabolite and to establish truly protective health-based guidance values. The contribution of multiple PFAS sources should also be considered, as they result in background levels significantly above zero.
As this issue concerns multiple PFAS substances, the assessment process must be safeguarded against industry attempts to downplay the toxicity of the substance.