Gore Fabrics Position on the “Madrid Statement”
We are aware of the concerns expressed by scientists who have recently signed the Madrid Statement. As a responsible Enterprise, we support and are already following many of the recommendations made in the Madrid Statement, such as the use of best available environmental controls for processing PFAs. However, there are elements in the Madrid Statement that we cannot support:
- It ignores a large body of existing scientific information demonstrating important differences between the health and environmental impacts of long-chain and short-chain PFASs.
- It does not sufficiently acknowledge the reality that fluorotechnology is essential for many aspects of modern life which is a critical consideration for developing a viable social policy on PFASs.
- It does not adequately recognize the substantial and continuing efforts by industry and governments to replace long-chain substances with alternatives that not only limit environmental impacts but also continue to provide the unique benefits of PFAS chemistry. These efforts continue, but more work is needed by all parties to complete this important transition.
Consistent with the Fluorocouncil’s view*, we believe that any assessment of the alternatives to longchain PFASs must be based on all the relevant factors that have historically guided risk assessment, including the cornerstone considerations of a substance’s hazard and exposure potential. Some critiques of PFASs have relied solely on the fact that these substances are persistent in the environment; a feature that is often closely related to their technological advantage as durable materials.
Decisions on the societal acceptability of strategically beneficial materials such as PFASs should not be made on a single attribute such as persistence and should take all environmental and health impacts of alternative technologies that occur along the life cycle of the end product into account. It is important to capture potential effects like increased release of chemicals by more frequently applied re-treatments or shortened life of the end product due to early repellency failure.
Gore Fabrics is supportive of constructive dialogue and engagement in the following areas:
- Strategies to prioritize and complete the transition away from the production and use of long-chain PFASs, a clear area of common ground.
- Identification of areas that warrant further knowledge development and risk assessment.
- Actions that can foster environmental stewardship practices within the supply chain, such as the guidance document on best environmental practices in textile manufacturing recently issued by the FluoroCouncil (FluoroCouncil 2014).
- Optimal methods for sharing information on PFASs with all stakeholders, including the scientific community, in a manner that is relevant to the health and environmental impact of fluorotechnology.
*See also the full response of the Fluorocouncil: http://dx.doi.org/10.1289/ehp.1509910
Product Stewardship of Gore Fabrics
Over the past ten years, Gore has made significant product stewardship efforts and have extensively screened more than 100 published literature studies in peer reviewed journals or by government agencies. We have invested considerable time and resources to understand the environmental impacts of the raw materials used in our durable water repellency (DWR) treatments to ensure that all Gore Fabrics products are not related to fluorinated substances that are a known cause of concern (long-chain PFC, for example PFOA, PFOS, PFNA, PFDA, PFHxS). We have been able to maintain the performance levels required by the end-users of our products via the application of an innovative short-chain fluorinated DWR technology without having to increase the quantities of materials used in the process.
GORE-TEX products are safe to wear, environmentally sound and socially responsible. They meet the criteria set forth in the Oeko-Tex® Standard 100, which is broadly regarded as the state-of-the-art safety standard for consumer textile products. Gore has been a bluesign® system partner since 2010, after having successfully implemented the bluesign® standard in all of its Fabrics production facilities worldwide. In addition to the limits on chemicals in products, bluesign® sets the standard for protecting workers and the environment throughout the supply chain.
As part of our ongoing commitment to product leadership, we do and will continue to broadly seek out and evaluate technologies that offer the potential to further decrease the environmental impact of the DWR technologies we use. While many of the currently available non-fluorinated DWR materials are scientifically interesting, we have not yet identified any capable of meeting the requirements of the end-user with respect to durable performance.