Environmental risks from alternative technologies

Jörg Feldmann highlights the need to address the unknown consequences of technological innovation on the environment and human health, particularly regarding Polyfluorinated Alkylated Substances (PFAS) and renewable energy technologies. While noting the benefits of innovation, he questions the adequacy of current assessment methods and urges greater use of the Precautionary Principle. Feldmann proposes a two-tier assessment system: a Safe and Sustainable by Design Panel for new technologies and an independent body to review long-term effects.

The term alternative technologies is already a statement which indicates that current technologies are harmful, not sustainable or too costly and new alternative technology is better and possibly better for the society and the environment. Have we considered all aspects when an alternative technology is introduced?

The production of GM crops has been discussed controversially. Without doubt GM crops would increase productivity and would result in the use of lower loadings of pesticides. A huge plus point for the environment. But single factor analysis may be misleading. How do we judge what impact of introducing GM crops into the Scottish environment has on the ecology? What are the long-term effects? Do they outweigh the plus points for the environment? A political judgement and not a judgement based on scientific data is often the case. Examples from the past, current and the future are described and a strategy set out on how all aspects of an alternative novel technology are assessed should be undertaken.

Misjudging non-toxic CFSs – can we learn from that?

In environmental chemistry, we are monitoring the health of an environment on a molecular level. We have seen in the past a lot of industrial processes and technologies which had advantages for modern life and also for the environment. Long-term effects are often not seen and are often not calculated in. Sometimes the effects are global and not restricted to a small country, such as Scotland. The use of benign chemicals which are inert and not toxic to humans were used for a long time in sprays and as coolants (CFCs). Only decades later we discovered that those chemicals have a devastating effect on stratospheric ozone levels. Science has provided some proofs, but it took a lot of time and endurance and the political will to get the chemicals banned. The Montreal Protocol in 1990, in which most CFCs were banned, was one of the fastest and most successful processes in the history of environmental protection, although some replacement products seem also not as harmless as thought.

The use of fossil fuels instead of wood during the period of industrialisation has propelled Europe and the West into the modern world. The effects of raised CO₂ emissions could only be seen centuries later. How can we prevent this type of consequence from happening in the future? What instruments do we have when new alternative technologies are introduced? From the government we have instruments such as the environmental impact assessments (EIS) which assess factors such as construction and its usage and the end-of-life aspects. But are long-term effects really being considered?

PFAS, the forever chemicals in the environment – can we phase them out?

In the past decades fluorinated organic compounds have revolutionized our life style significantly. These compounds can save money and resources and therefore be beneficial for the environment. No longer do we need a lot of detergents to clean our frying pans because Teflon, a fluoropolymer, prevents the burning of the food. No longer do we get wet but can work and can enjoy the great outdoors because our shoes and jackets became waterproof through applying fluoropolymers. Smaller loadings of pesticides are being used due to the introduction of fluorinated pesticides. Hence our waterways become less polluted with pesticides. But the quality (i.e., the potency of the chemicals) needs to be assessed as well. Often only after a long time does the degree of the problem become obvious. We discovered that our global environment is heavily polluted with these compounds since they are not readily degradable. The group of per- or poly-fluorinated alkylated substances (PFAS) were produced since the 1940s and brought into our daily life step by step. We do not want to have so much plastics which may have microplastics in our environment, hence we replaced plastic (e.g., PE, PET) in food and drink packaging by degradable paper cups, cartons and straws; and we felt good. These food contact materials however only function if they are coated and some of the coats are made with PFAS to make them water and oil-repellent. PFAS then are taken up by humans and enter the environment. PFAS were seen as non-toxic and durable due to the stable carbon-fluorine bond. However, it is exactly this durability that is the problem. These compounds cannot degrade in the environment fully to less harmful inorganic fluoride. Henceforth, the decades of using these compounds in consumer products and industrial applications has increased the PFAS concentrations in every sphere from groundwater, to rain, to pristine alpine meadows and to seawater. They are also taken up by plants, accumulate in animals and build up in humans and other species at top of food chains. For example, whales, stranding on Scottish coasts, are loaded with PFAS in their liver and also in their brains, in addition to a lot of other persistent organic pollutants (POPs). Orcas in Scotland might be infertile due to the build-up of POPs in those top predators, an effect often associated with PCB. But PFAS are also linked to infertility in mammals.

Due to the use of PFAS in day-to-day life, consumers pollute our groundwater and drinking water with PFAS. Our sewage treatment plants are unable to remove PFAS from the water, even when they work according to governmental standards. Some of the notorious bioaccumulative PFAS were consequently banned from usage by the Stockholm Convention (e.g., in 2009 (PFOS) and 2019 (PFOA)). What did the industry do? They did not exclude PFAS, but instead of using these banned so-called C8 PFAS, they used PFAS with other chain lengths, such as C6 or C9 to produce PFAS polymers. These PFAS compounds, also not biodegradable, were also not acceptable for sustainable new technologies. Then the industry produced other PFAS so-called replacement PFAS which can degrade fast by introducing easy to break bonds in the middle of the carbon chain (a carbon oxygen bond is not as strong as a carbon carbon bond). Products like ADONA or GenX were generated. Not only those compounds seemed to accumulate in the environment, but also their breakdown products (also PFAS but with shorter C-chain length) were found in the environment. This is also not acceptable as sustainable new technology.

PFAS is a group of more than 12,000 human made compounds. All these compounds are considered to be associated with long lasting diseases in humans. They interfere in neurotransmitters and act as hormones. They are associated with producing cancer cells, thyroid dysfunction, infertility etc. How our wildlife copes is unclear.

The EU proposed a ban on ALL PFAS in 2023 – a challenging and ambitious ban, in response to the industry avoiding single groups of PFAS but using other PFAS instead. First discussions on the ban highlights that some PFAS are well studied, and those compounds should be avoided (per and polyfluorinated carboxylic acids and sulfonic acids). On the other hand, fluoropolymers (e.g., PTFE, PFA) are considered as inert and should not been tackled in the first phase. We do not know anything about those polymers in the environment due to the lack of analytical methodologies, but it is well established that their production generates non-polymeric PFAS. There is a hope that the EU authorities will also consider these compounds. Again, the long-term effects are not seen at the moment. But it is clear that those compounds are not easily degraded and will last for decades or centuries in our environment. It is unclear at the moment whether the UK Government will align with the ambitious plan of the EU to ban of all PFAS. The current UK position is that they will restrict only a few hundreds of the most studied PFAS. It is unclear if these are also the most potent ones or the ones which can easily be replaced. The UK’s PFAS Regulatory Management Option Analysis have a position paper which clearly states that they would not consider fluoropolymers due to lack of scientific data. Hence the Precautionary Principle is not applied. The Precautionary Principle guides decision-makers when facing potential environmental or human health risks, especially when scientific evidence is lacking or uncertain and the consequences are significant. It helps policymakers address risks that cannot be fully quantified in advance.

This ban can be seen as an innovation to push for alternative products, at least for the products with a short life time, such as food packaging. But we should be aware that possible alternative products could introduce other problems. For example, materials suggested to replace PFAS made from seaweed have been proposed for drinking straws. Seaweed may contain a lot of compounds which may be harmful for us and the environment, such as inorganic arsenic, a class I carcinogen. A full Environmental Impact Assessment of alternative technologies, which includes long-term effects on the environment, is needed and weighted accordingly.

Staying with PFAS, most newly introduced pesticides are classed as PFAS since they have a fluorinated carbon (as -CF₃). These pesticides are effective in smaller concentrations because they are taken up by the target organism efficiently, but when degraded they will produce in the environment one of the smallest PFAS and very mobile trifluoroacetic acid (TFA). It is expected that TFA will be listed as harmful and toxic by the European Chemicals Agency (ECHA) in 2025. Currently fluorinated pesticides containing no –CF₃ group but a -CF₂H group are not classified as PFAS, and pesticides producers will see a loophole in the proposed legislation. But are the degradation products less harmful and less persistent? If we ban all fluorinated products, we have less efficient pesticides, which would result in higher loadings of non-fluorinated pesticides in the field. Innovation should provide products which are more effective and produce less harmful degradation products. Hence, before the introduction of alternative pesticides stringent and detailed toxicological and environmental assessments are needed for all degradation products.

Other potent chemicals, such as pharmaceuticals in the sewage system could be destroyed by a new fourth cleaning step in sewage treatment plants so that they do not reach our rivers and drinking water reservoirs. Ozone with subsequent filtering on active charcoal is often discussed and already tested for pharmaceuticals. However, how do the plethora of PFAS react with ozone? Ozone has the potential to generate more potent oxidised PFAS which have higher mobility and could even enhance the PFAS level in our rivers, ground and drinking water. Again, before this is introduced a full assessment of long-lasting environmental effects needs to be introduced.

Alternative technology can introduce new threats

Another problem of introducing alternatives technologies is that they are often costly but are introduced because they outweigh the problems with the old technology. Take the light bulb, a safe but costly in terms of energy consumption and resulting in a lot of CO₂ emissions, was replaced in 2017 by the energy saving light bulb. What was not considered at the time was that those energy saving light bulbs contain significant amount of mercury. Mercury is bioaccumulative in the food web in the form of organic mercury which is a neurotoxin and highly detrimental for wildlife if used bulbs are not collected in special facilities in which the volatile mercury is captured.

It is crucial that all aspects of the new technology are assessed and not only the immediate factors. Usually that is happening in the EIA. But it is important to weigh out the facts properly when we balance the long-term risk to the environment from the alternative technologies. The Precautionary Principle should surely be followed. This is often not done and cannot be done quantitatively. Which is the more important of the following alternatives: the reduction of CO₂ when less energy is used during the production and the usage and end of life or is it more important to look at compounds which are not degradable and build up in the environment? This is somewhat subjective and often down played.

People favour electric cars in comparison to the fossil fuel old-timers, since less NO₂ and tropospheric ozone is produced. However, there are other environmental factors in the production of the batteries to be considered. Every lithium-based battery contains PFAS membranes. It is necessary to consider how much energy is used and how much and how potent are the waste products which are generated when mining for lithium. What is the impact on the natural environment? Does it matter that this mining is in a faraway rural environment or generated in Scotland? All these are factors which cannot be quantified directly, but need proper consideration.

Decommissioning needs to be factored in

For the Scottish environment, it would be beneficial if renewable energies replaced the oil and gas industry. But the alternative technologies have often also some detrimental effects for the environment. Wind farms are large installations offshore, as are the offshore oil and gas exploration and production facilities. A lot is discussed about the disturbance of the seabed and the noise level during construction of offshore wind turbines on marine mammals, as are the effect of wind turbines to bird migrations. Other less obvious factors are not discussed. For example, it is likely that new toxic metals are introduced into the marine environment. Indium and gallium are used as sacrificial anodes to protect the steel from corrosion. These elements are in fact very rare and do occur only as ultra-traces (nanogram per litre concentrations) in the seawater. With the building of large wind parks, the concentrations of these rare elements will increase significantly and maybe introduced into the food chain with consequences we do not know today. How can we assess this if no scientific knowledge is available? It is recommended that factors which influence the environment in the long-term and which are not reversible and whose effect is unknown should have a high priority in the EIA using the Precautionary Principle.

Often a full environmental impact assessment of the decommissioning phase of a technology has not been considered properly. How important that is has just surfaced recently. For example, the decommissioning of large human-made structures need also be considered. More than 10,000 miles of pipelines from the oil and gas industry need to be decommissioned in the next decades when the oil and gas production will be phased out. Removal of the pipelines would disturb the seabed, hence the preferred option in the UK would be to leave these pipelines where they are and to leave them corroding on the seabed. Recent research however revealed that these pipelines contain mercury in high concentrations which could increase the natural occurring ultra-trace amounts of mercury (nanogram per litre range) in the North Sea significantly. Since mercury is like POPs (persistent organic pollutants) bioaccumulative, top predators could accumulate large amounts of the neurotoxic metal in their brains. This has been highlighted by the high concentrations of mercury in stranded whales and dolphins at the Scottish coast. There is a danger that the mercury reaches a maximum threshold concentration, although nobody knows what this concentration is. This is potentially a significant factor which is detrimental for the well-being of marine mammals. Enhanced mercury loadings to the sea even at ultra-traces could overburden this detoxification since not enough selenium may be available to fulfil its biological function. This may illustrate that we should not only focus on obvious disturbances to the environment but also assess possible pollutants at the ultra-trace level during the construction and working life phases and properly consider the decommissioning phase of a new technology before it is approved.

Non reversible effects need the Precautionary Principle

Another new technology, carbon capture storage (CCS), has become popular amongst environmentalists in Scotland. CCS is a technology which reduces the CO₂ emission to the atmosphere. If a CCS facility is installed and fully functioned, this will have a significant positive effect for Scotland to become CO₂ neutral. However, the long-term risks in storing CO₂ are difficult to judge. In any case, this CO₂ cannot easily be recaptured again; consequently, not reversible. How these long-term effects are being judged in an environmental impact assessment is unclear and its assessment is more political since only limited reliable scientific data are available.

Fracking is also a political hot topic. Quick gains from the extraction of natural gases have seen in the US economy, but have the consequences of the extraction already being assessed? The controversial discussion mainly focusses on the anticipated physical tremors or the injection of a cocktail of chemicals in an ancient aquifer. But the fact that the chemistry in the sediment might be influenced and might mobilise toxic elements into the groundwater is not often calculated; again due to the lack of data.

Engineered nanoparticles have been used in consumer products and has increasingly been used in nanomedicine. How do these nanoparticles behave when they are released into the environment? Do they present a new type of pollution, and can we prevent them to be released?

Recommendations – Safe-and-Sustainable by Design (SSbD)

In general, introducing alternative technology have nowadays buzzwords such as sustainability and eco-friendly. But are all aspects being assessed? The use of natural renewable resources for the chemical industry to replace the petrochemistry is commendable. A lot of new technologies are introduced under the term circular molecular economy or ecology. Using renewable raw materials such as wood for making stock chemicals for the production of pharmaceuticals, consumer products etc. is envisaged. How are these products formally assessed, and can we afford to use our woods to replace all fossil resources? This commendable move from fossil to renewable resources should benefit the natural environment. But using wood as a raw material on a large scale can have devastating effects for the natural environment, as we have seen in Scotland at the start of the industrialisation period. Hence this needs serious planning. We recommend having a SSbD panel for every new technology. SSbD is the Safe-and-Sustainable by Design principle which the EU reinforces in a newly launched EU framework. Here not only the hazard assessment during production, but also the usage and the end-of-life phases in the life cycle will be assessed. The question remains though, what is the weighting of these risks which are mostly based on predicted values? We would advocate an independent multi-disciplinary body looking at especially long-term effects during all stages of the introduction of alternative technologies. Pollution, even at ultra-trace levels and not reversibly released into the environment, should be assessed with regards to the risk to our natural environment with care. Hence, an independent body of scientists are needed to make a judgement on the risks to introduce alternative novel technologies.

Conclusions

Replacement materials and new technologies often create as many problems as those products they are replacing. This leads to the conclusion that more rigorous assessments are needed at the design and development stages as opposed to following introduction. There must be more assessments of potential side effects of new products before they are introduced. These means examining systematically the longer-term potential effects on animals, humans and the environment;  a whole life cycle analysis of the products and technologies. There should be SSbD Panels for each technology to make independent assessments. There should be overseeing bodies to determine the societal risk as well as the technological risk and provide advice to decision makers. The difficulty will be to find people for those overseeing bodies and panels who have enough knowledge on sustainability but are totally unbiased.

• This article is part of a series from the RSE’s Environment Community of Interest. The aim is to stimulate informed public debate on the many aspects and elements of this complex and vexed subject. We’d love to hear your thoughts about this piece, email us on publicpolicy@therse.org.uk.
• To be notified when the next article in this series is live, sign up to the RSE’s monthly policy advice newsletter.