RSC PFAS Decision Tree


The Royal Society of Chemistry has published its "PFAS Policy Position", including a handy PFAS Use Decision Tree.

On their website, the RSC state:

"We believe that the chemical sciences are making an important contribution. We have developed our initial policy position on risk-based regulation for PFAS, including our proposal of a 'traffic light' approach to prioritisation."

Our opinion on C6 foams:

We believe that, using their proposed risk-based Decision Tree framework around PFAS usage and following the guidelines from the Policy Position reported by RSC in December 2021, offshore platforms could be permitted derogation from potential PFAS restrictions.

Step 1:   Determine if chemical(s) concerned is PFAS, based on the OECD (2021) definition. PFAS is present in modern C6 foams.
Step 2:   Foam is determined as the end-product which contains PFAS. Continue to step 4.
Step 4:   We believe that modern freeze protected C6 foams are of vital use for society. Currently, from our research, there are no suitable alternatives for freeze protected C6 AFFF foams. These foams are vital for the safety of all personnel boarded on these isolated platforms. Continue to step 5.
Step 5:   There is sufficient safety data available for vital PFAS currently used in current C6 foams (see OECD study linked above). Continue to step 6.
Step 6:  

PFAS safety data is assessed by a regulatory body and risk assessment manifested.

  • If the concerns are determined as low, there shall be no restrictions on use for the permitted product. Foams included on Green List B.
  • If the concerns are determined as medium or high, permission is determined by a ‘PFAS Jury’ and impact assessments conducted.
Possible outcomes:

If the jury assessment concludes the PFAS use is not vital, possible outcomes are:

  • Red List A – phase out
  • Red List B – find alternative and phase out
  • Amber list – restrict levels and use.

Due to the vitality of effective fire protection in isolated locations of offshore platforms using AFFF C6 foams, we believe a Green or Amber list allocation should be considered.

The full Decision Tree can be seen below:

RSC Decision Tree1RSC Decision Tree2

For further information and to download their full policy document, click or tap here.

If you have any questions or would like to discuss this further, please don't hesitate to contact us.