HEAL & Fundamental Rights: letter to the federal government

Dutch
French
English
Dutch

At:

Zakia Khattabi
Minister of Climate, Environment, Sustainable Development and Green Deal

Frank Vandenbroucke
Deputy Prime Minister and Minister of Social Affairs and Public Health

Brussels, November 10, 2021

Re:

The involvement of the Belgian federal government in addressing PFAS pollution around Antwerp.

Dear Minister Khattabi,
Dear Minister Vandenbroucke,

We are writing to you on behalf of the Health and Environment Alliance (HEAL) and Grondrecht to ask for the involvement of the Belgian federal government in addressing the pollution in Antwerp and Zwijndrecht with highly persistent per- and polyfluoroalkyl substances (also known as PFAS and 'forever chemicals').

The Health and Environment Alliance is the leading European not-for-profit organisation addressing the impact of the environment on health in the European Union. Together with more than 90 member organisations across Europe, we work to shape laws and policies that promote the health of people and the planet. We protect those most affected by pollution and raise awareness of the positive health impacts of environmental action. With our programme on harmful chemicals, we advocate not only for a severe reduction in PFAS but also for their replacement in Europe, all in the name of protecting health and preventing disease.

Fundamental right is a collective of concerned citizens that was founded in response to the pollution of the site around the 3M factory in Zwijndrecht. They demand transparency about the scale on which the PFAS pollution has spread in Flanders and what the impact of this is on the health of local residents and the living environment. Grondrecht also advocates for the clean-up of the polluted sites and the implementation of the 'polluter pays' principle.

Background

As you know, the production of the 3M factory near Antwerp has led to the dumping, discharge and emission of harmful PFAS for several years. With PFOS as the most notorious in the entire surrounding area, including the municipality of Zwijndrecht and the city of Antwerp, where together more than half a million people live.

The PFOS contamination came to public attention after it was (re)discovered during excavation works for the Oosterweel infrastructure project. According to recent revelations in the media, local authorities were already aware of the problem in 2017.^[1]

PFOS is perhaps one of the most notorious members of the PFAS family. The substance is included in the Stockholm Convention list of persistent organic pollutants (POPs) due to its extreme persistence in the environment, its potential for bioaccumulation (the substance has been found in animals in the Arctic, far from emission sources) and for long-distance transport, as well as toxicity in animal experiments.^[2] PFOS is classified as a suspected reproductive toxicant (R1B) and a suspected carcinogen (C2) under the European Hazard Classification System.^[3] Human exposure to the substance has been associated with very serious health effects, including but not limited to: interference with the hormonal system, effects on the reproductive system and the development of the unborn child, also on the immune system including the response to vaccines and the development of certain types of cancer (including kidney).^[4]

The International Federation of Gynecology and Obstetrics recently called for an immediate phase-out of all PFAS, including PFOS, highlighting the health risks they pose throughout life, including during vulnerable developmental periods such as early life in the womb and adolescence.^[5]

Our requirements

We invite the Belgian federal government to contribute to the current European efforts on PFAS regulation, as illustrated by the recent request to make the PFAS issue an agenda item at the Council of Environment Ministers of 6 October 2021.^[6] This is a fair recognition of the fact that “It seems essential to establish strong policies as soon as possible to prevent the above-mentioned environmental damage and adverse health effects, but also to support Member States in taking protective, remedial and clean-up measures”.

There is no doubt that coordinated action at EU level is absolutely necessary to prevent future PFAS pollution, to minimise exposure to PFAS chemicals, to remediate the pollution, to address PFAS-related waste and to properly monitor the impact on the health of residents and the environment. In this respect, the current development of a Europe-wide restriction of all non-essential uses of PFAS is an important step in the right direction.

However, we are extremely concerned that too little is currently being done by national governments – including the Belgian one – to address existing cases of PFAS pollution, while it is known that these have an impact on the health of local residents and their living environment.

In Belgium, PFOS pollution around Antwerp is a reality which was confirmed by various measurements in the area since the early 00s. It is alarming that the eggs of chickens – within a radius of 15 kilometers around the 3M factory in Zwijndrecht – pose a health risk, as was established by researchers from the University of Antwerp. In particular for children (due to a higher intake in relation to their weight).^[7] In the summer of 2021, blood samples were taken by Grondrecht and analyzed by researchers from the Vrije Universiteit Amsterdam. Extremely high PFOS concentrations were found in the blood of residents living near the 3M factory. All samples exceeded the recently adjusted safety threshold for the sum of PFOA, PFNA, PFHxS and PFOS of the European Food Safety Authority (EFSA).^[8] This alarming situation was confirmed once again by the recent publication of the results of the Flemish Agency for Care and Health, at the end of October. Again, an excessively high presence of PFOS values in the blood was found in more than half of the 800 residents tested.^[9]

The situation calls for urgent action at three levels, namely environmental and health monitoring, cleaning up the site and holding the polluting companies accountable.

We are aware that a Flemish investigation committee is currently investigating the responsibilities within the regional authorities and administrations and that an administrative procedure is investigating the circumstances in which the Antwerp factory reported on the waste emissions linked to their production.

Nevertheless, to our knowledge, apart from the guidelines regarding food consumption, few measures have been taken to highlight the pollution and the known health risks that local residents are faced with. The Belgian federal government has already shown great willingness to tackle the PFAS problem thoroughly at European level. That is why we would like to hear from you whether concrete measures have already been taken and/or which measures are in development to better protect the affected communities in Antwerp and Zwijndrecht against the current toxic exposure. Given the current complex Belgian state structure and because many powers are divided among the different authorities, we are convinced that this should be tackled at a federal level.

Therefore, through this writing, we would like to ask you to inform us of what the federal government's plans are to:

• to support affected communities in their demand for transparency and accountability regarding pollution, as well as related health risks, environmental damage and habitat loss.
• to guarantee that all polluted areas will be cleaned up and remediated, as well as the current site and the projects already completed in the context of the Oosterweel connection.
• the guarantee that constant monitoring provides insight into the further spread of pollution through measurements in water, air and soil.
• the guarantee that affected communities have access to clean water and safe food. 
• the guarantee that the long-term health-related risks for residents and ex-employees of polluting companies are further monitored and controlled. This is done through large-scale bio-monitoring projects for exposure to PFAS. Furthermore, the Flemish government is not yet making plans to give all potential victims the opportunity to be tested, such as children under the age of 12, people who have moved but have lived in Zwijndrecht or Antwerp for a long time and residents of Antwerp who live on the right bank. There is also no long-term monitoring of the evolution of the individual health situation. We therefore ask the federal government to intervene in this. 
• the guarantee that the “polluter pays” principle is applied to the responsible companies, so that they remain responsible for the damage suffered.

We thank you in advance for your prompt response to these urgent questions and remain available to discuss this further.

Yours faithfully,

Genon K. Jensen Jonas Vernimmen
Executive DirectorCoordinator
Health and Environment Alliance (HEAL)LAND RIGHT

Contacts:

Natacha Cingotti: natacha@env-health.org
Jonas Vernimmen: jonas@grondrecht.eu

---

1. https://www.brusselstimes.com/news/belgium-all-news/174208/revealed-flemish-government-knew-about-pfos-problem-in-2017/
2. Stockholm Convention, SC-4/17, Listing of perfluorooctane sulfonic acid, its salts and perfluorooctane sulfonyl fluoride, available at http://chm.pops.int/Implementation/IndustrialPOPs/PFOS/Decisions/tabid/5222/Default..aspx, accessed on 7 October 2021.
3. ECHA, Substance Infocard, https://echa.europa.eu/fr/substance-information/-/substanceinfo/100.015.618.
4. See, among others, HBM4EU, Scoping Document for PFAS, 2019, Section 1.1.2 Hazardous Properties, https://www.hbm4eu.eu/wp- content/uploads/2019/03/HBM4EU_D4.9_Scoping_Documents_HBM4EU_priority_substances_v1.0- PFAS.pdf; pp. 1-2.
5. FIGO, FIGO calls for global ban on PFAS use, May 25, 2021, https://www.figo.org/figo-calls-removal-pfas-global-use.
   See also the FIGO-UCSF-HEAL multilingual infographic on the health risks associated with PFAS exposure: https://www.env-health.org/how-pfas-chemicals-affect-women-pregnancy-and-human-development-health-actors-call-for-urgent-action-to-phase-them-out/.
6. “The need for a coordinated action against PFAS – Information from the Belgian delegation”, Information note, 24th September 2021, https://data.consilium.europa.eu/doc/document/ST-12150-2021-INIT/en/pdf , accessed 4th October 2021.
7. Groffen Thimo, Lopez Antia Ana, D' Hollander Wendy, Prinsen Els, Eens Marcel, Bervoets Lieven. Perfluoroalkylated acids in the eggs of great tits near a fluorochemical plant in Flanders, Belgium https://doi.org/10.1016/J.ENVPOL.2017.05.007.
   See also: https://www.brusselstimes.com/news/belgium-all-news/173456/3m-pollution-pfos-eggs-hatched-within-15-km-of-factory-in-antwerp-pose-health-risks- says-uantwerp/.
8. Fundamental right, Press release blood test Zwijndrecht, August 4, 2021,
   http://rggtvqo.cluster031.hosting.ovh.net/facts/actueel/persbericht-bloedonderzoek-zwijndrecht/.
9. Care and Health Agency, Blood test shows high PFOS levels in more than half of participants – no-regret measures are being expanded, October 26, 2021, https://www.zorg-en-gezondheid.be/bloedonderzoek-toont-hoge-waarden-van-pfos-bij-meer-dan-de-helft-van-de-deelnemers-%E2%80%93-no.

French

A:

Zakia Khattabi
Ministre du Climat, de l'Environnement, du Développement durable et du Green Deal

Frank Vandenbroucke
Vice-Premier Ministre, Ministre pour les Affaires Sociales et la Santé Publique

Brussels, November 10, 2021

Object:

Implication of the Belgian Federal Government of the contamination risk of the PFAS autour d'Anvers.

Madam Minister,
Mr. Minister,

In the context of the Alliance for Health and Environment (Health and Environment Alliance – HEAL) and Fundamental Law, new addresses are available in the application for the Federal Government's response to the contamination of the zone. d'Anvers et Zwijndrecht par des pollutants per- et polyfluoroalkylés hautement persistants (également appelés PFAS or "pollutants éternels").

L'Alliance pour la Santé et l'Environnement (HEAL) The principal organization is but not lucrative because it does not affect the environment in terms of human health in the European Union (UE). There are 90 organizations involved, including contributions to the labor and public policy processes that contribute to the health of the planet and the human environment and the protection of persons and pollution, as a result of the great conscience of the beneficiary. 'action environnementale sur la sante. In addition to the program for the treatment of the substances that are toxic, the use of large-scale restrictions on the composition of PFAS involves substitution in Europe for the protection of health and prevention of maladies.

Fundamental right is a collection of river basins, forms and responses to the pollution of the localized sites in the 3M environment in the Anvers and Zwijndrecht zones, for greater transparency regarding the contamination of the PFAS and Flandre compounds. the consequences of the health of the communities and of l'environnement proches, depollution des sites contaminés, et l'application du principle pollueur-payeur.

Context

Comme vous le savez, l'exploitation de l'usine 3M près d'Anvers au pour conséquences le déversement et l'émission de polluants PFAS nocifs que la discharge de déchets leur étant liés pendant plusieurs années – le plus connu d'entre eux étant le PFOS – à travers la zone environment, and the municipality of Zwijndrecht and the ville d'Anvers, do not combine the population with more than a million people.

The contamination of PFOS is a continuous publication suite that involves (re)-découverte during the excavation process and lies in the context of the mismanagement of the project infrastructure of the Oosterweel liaison. After the recent developments, the local authorities are informed about the current problems in 2017.^[1]

Le PFOS is one of the most important people in the world of PFAS compositions. The substance is listed as pollutant organic persistent (POP) due to the Stockholm Convention due to the extreme persistence of the environment, the potential for bioaccumulation ) and long-distance transport, causing toxicities during the afternoon les études animales expérimentales.^[2] The PFOS is classified according to the presumptive toxicity of reproduction (R1B) and cancérogène suspecté (C2) according to the European system of classification of dangers.^[3] The human exposition of the substance associated with the effects of the sévères, which includes the limits: the interactions with the hormonal system, the effects of the reproductive system and the development of the enfants of the child gestation, sur le immunitaire système y compris la réponse aux vaccines, et le développement de certains cancers (comme celui du rein).^[4]

The International Federation of Gynécologues and Obstetricians is a procedure for a public appeal against the elimination of PFAS, noting the PFOS, and insisting on the risk of the compositions during the long period of time, and compris durant des fenêtres the development vulnérables comme le tout début de la vie in utero, l'adolescence, ou la grossesse.^[5]

Our demands

The latest reports on the current bill for the Belgian Federal Government contribute to current European efforts for the current PFAS regulations, as illustrated by the current demand for the PFAS agenda on October 6, 2021.^[6] Cette dernière reconnaît avec justesse qu '« The equipment essential for adopting the political strengths that are more than possible for the environment surrounding the cities and the effects of safety, but also for the survival of the measures involved in the protection measures, the remedies and the depollution».

It is necessary to ensure that the action coordinated at European level is absolutely necessary for the removal of new pollutions of PFAS in the future, minimizing the additional exposure of substances, removal of pollution, treatment of the effects of the pollution, and monitor the appropriate manner of impacts la sanity et l'environnement. The ce point de vue, the development and cours d'une restriction européenne couvrant the group entier of PFAS and tous les usages dits non-essentials représente une avancée majeure.

We are constantly inquiring into the nature of the actions taken in the course of the national authorities, taking into account the Belgian authorities, considering the existence of pollution caused by PFAS, and not the impacts on the local communities and the environment. déjà connus.

In Belgium, the pollution caused by PFOS autour d'Anvers is real, come with confirmation of the measurements of the PFOS prices in the summer of 2018. The method of choice, the production methods of a 15 kilometer automotive area of 3M d'Anvers, should be considered according to the risk factors for the safety part les chercheurs de l'Université d'Anvers, spécifiquement pour les enfants (à cause de leur potential d'ingestion plus grand par rapport à leur poids).^[7] Durant l'été 2021, the analyzes organized by land law and realizations by the researches of the Université libre d'Amsterdam with the concentration of excessive concentrations of PFOS in the sang of the rivers, and notamment for the échantillons, and dépassement de la limite sanitary for the sum of PFOA, PFNA, PFHxS and PFOS are part of the European Food Safety Authority (EFSA).^[8] The alarm characteristics of the current situation and confirmation of the recent publication of the results of the analyzes of the Soin Flamande and Santé Agency (Care and Health Agency) at the end of October, according to the results Levels of PFOS excesses can lead to increased mobility 800 citizens testés.^[9]

The situation arises from the urgent actions at three levels of principle, from the environmental and sanitary surveillance, from the contamination of the site, from the responsibility of the pollutants to the rivers and from the authorities.

Nowadays we are aware of the parliamentary questions and the training of the surveyors on the chain of responsibility for the government and the regional administration and the administrative analysis procedure that determines the conditions of the use of the system. Another communiqué about the details of the situation le cadre de ses opérations.

During the day and not to be connaissance, the measures are taken in the place where the pollution is caused by the environment, but also the risks associated with the environment and the results of the additional font face of the environmental communities, which is part of the lignes directives adaptées pour la consommation alimentaire. The level of engagement poster by the Belgian federal authorities by report on the report on the pollution of PFAS on the level of Europe, new methods are used to ensure that the measures taken during the inspection and/or the development process are completed. real consequences the situation for the communities in the zone d'Anvers and Zwijndrecht. Non-existent is the complex institutional structure of the Belgian institutions and the part of the responsibility of the regional and national levels, the serious characteristics of the situation and the consequences of the potential consequences of the additional implications of the federal institutions.

This is the reason why the demander is asked by the ministries respecting the visa agent's fairness:

• Assessment of the transparency and responsibility of local communities regarding pollution and environmental consequences;
• Guarantee the detailed mapping of the sites to ensure decontamination is carried out in order to ensure effective cell placement, and compris the site or the Osterweel project during the development process;
• Guaranteeing adequate surveillance of the evolution of environmental contamination (by monitoring the regular regulations of the environment and the sols);
• Guarantee of the existence of certain conditions and application for the insurance of the local communities for the maintenance and maintenance requirements;
• Assurer la surveillance adéquate des risques de santé liés à l'exposition à long-term au PFOS pour le communautés environnantes (y compris à travers une biosurveillance régulière et large pour aux les rivers ainsi qu'un vivi medical pour les plus à risques) ainsi que pour les travailleurs des entreprises concernées. In the current situation, the government is not only the intention of the proposed test persons for the ensemble of the riverine concerns (by example for the children, the riverains ayant quitté la zone, the habitants d'Anvers) and long-term medical personalization. This is the action that demands the impact of the federal level.
• Guaranteeing the application of the pollueur-payeur principle, to ensure that the companies responsible for pollution are responsible for the environment and financial responsibility.

Please take note of the responses for important questions and urgent questions and the appreciation of the opportunity to change them and the details of the meeting during the meeting.

Nous vous prions d'agréer, Madame la Ministre, Monsieur le Ministre, l'expression de nos salutations distinguées.

Genon K. Jensen Jonas Vernimmen
Director executive coordinator
Health and Environment Alliance (HEAL)LAND RIGHT

Contacts:

Natacha Cingotti: natacha@env-health.org
Jonas Vernimmen: jonas@grondrecht.eu

---

1. https://www.brusselstimes.com/news/belgium-all-news/174208/revealed-flemish-government-knew-about-pfos-problem-in-2017/
2. Convention de Stockholm, SC-4/17, Listing of perfluorooctane sulfone acid, which is used for perfluorooctane sulfonyl fluorine, available for use http://chm.pops.int/Implementation/IndustrialPOPs/PFOS/Decisions/tabid/5222/Default..aspx, consulted on October 7, 2021.
3. ECHA, fiche d'information substance, https://echa.europa.eu/fr/substance-information/-/substanceinfo/100.015.618.
4. Voir par example, HBM4EU, Document de scoping pour les PFAS, 2019, Section 1.1.2 Propriétés de danger, https://www.hbm4eu.eu/wp- content/uploads/2019/03/HBM4EU_D4.9_Scoping_Documents_HBM4EU_priority_substances_v1.0- PFAS.pdf; pp. 1-2.
5. FIGO, FIGO calls for removal of PFAS from global use, May 25, 2021, https://www.figo.org/figo-calls-removal-pfas-global-use.
   For information about the multilinguistic information FIGO-UCSF-HEAL about the risk associated with PFAS exposure: https://www.env-health.org/how-pfas-chemicals-affect-women-pregnancy-and-human-development-health-actors-call-for-urgent-action-to-phase-them-out/.
6. Conseil européen, “The need for a coordinated action against PFAS – Information from the Belgian delegation”, note d'information, 24 September 2021, https://data.consilium.europa.eu/doc/document/ST-12150-2021-INIT/en/pdf, consultation on October 4, 2021 and traduit de l'anglais.
7. Groffen Thimo, Lopez Antia Ana, D' Hollander Wendy, Prinsen Els, Eens Marcel, Bervoets Lieven. Perfluoroalkylated acids in the eggs of great tits near a fluorochemical plant in Flanders, Belgium https://doi.org/10.1016/J.ENVPOL.2017.05.007.
   See also: https://www.brusselstimes.com/news/belgium-all-news/173456/3m-pollution-pfos-eggs-hatched-within-15-km-of-factory-in-antwerp-pose-health-risks- says-uantwerp/.
8. Fundamental right, Press release blood test Zwijndrecht, August 4, 2021,
   http://rggtvqo.cluster031.hosting.ovh.net/facts/actueel/persbericht-bloedonderzoek-zwijndrecht/.
9. Care and Health Agency, Blood test shows high levels of PFOS in more than half of participants – no-regret measures are being expanded, October 26, 2021, https://www.zorg-en-gezondheid.be/bloedonderzoek-toont-hoge-waarden-van-pfos-bij-meer-dan-de-helft-van-de-deelnemers-%E2%80%93-no.

English

To:

Zakia Khattabi
Minister for Climate, Environment, Sustainable Development and Green Deal

Frank Vandenbroucke
Deputy Prime Minister, Minister for Social Affairs and Public Health

Brussels, November 10th 2021

RE:

Belgian federal government involvement regarding the addressing of the PFAS contamination around Antwerp.

Dear Minister Khattabi,
Dear Minister Vandenbroucke,

We are writing you on behalf of the Health and Environment Alliance (HEAL) and Grondrecht, in order to ask for the involvement of the federal government in addressing the contamination of the area of Antwerp and Zwijndrecht by highly persistent per- and polyfluoroalkyl substances (also referred to as PFAS or “forever chemicals”).

The Health and Environment Alliance is the leading European not-for-profit organization addressing how the natural and built environments affect health in the European Union. Together with our over 90 member organizations around Europe, we work to shape laws and policies that promote planetary and human health, protect those most affected by pollution, and raise awareness on the benefits of environmental action for health. Through our program on harmful chemicals, we promote large restrictions and substitutions of PFAS across Europe in view of health protection and disease prevention.

Fundamental right is a collective of concerned citizens that formed in response to the pollution of the sites surrounding the 3M factory in the area of Antwerp and Zwijndrecht in order to demand transparency about the scale of PFAS contamination in Flanders and its related consequences for the health of the nearby communities and the environment, clean-up of the contaminated sites and the implementation of the polluter-pays principle.

Background

As you are aware, the operation of the 3M factory near Antwerp has resulted in the dumping, discharge and emission of harmful PFAS for several years, with PFOS being the most notorious one, all across the surrounding area, including the municipality of Zwijndrecht and city of Antwerp, which together house over half a million people.

PFOS contamination caught public attention after it was (re)discovered during the excavation work that took place in the context of the Oosterweel infrastructure project. According to recent media reveals, local authorities appear to have been informed about the problem already back in 2017.^[1]

PFOS is perhaps one of the most infamous members of the PFAS family. The substance is listed as a Persistent Organic Pollutant (POP) under the Stockholm Convention due to its extreme persistence in the environment, its potential for bioaccumulation (the substance has been found in Arctic animals, far from emission sources) and for long-range transport , as well as toxicity according to animal experimental studies.^[2] PFOS is classified as a presumed reproductive toxicant (R1B) and a suspected carcinogen (C2) under the European hazard classification system.^[3] Human exposure to the substance has been associated with very severe health outcomes, which include but are not limited to: interferences with the hormonal system, effects on the reproductive system and the development of the unborn child, on the immune system including the response to vaccines , the development of certain cancers (including kidney).^[4]

The International Federation of Gynecologists and Obstetricians recently called for an immediate phase-out of all PFAS, including PFOS, stressing the health risks they pose throughout the lifetime, including in vulnerable development windows such as early-life stages in utero, adolescence, or pregnancy .^[5]

Our requests

We welcome the Belgian federal government willingness to contribute to current European regulatory efforts on PFAS, as illustrated by the recent request to address the issue of PFAS as part of the agenda points of the recent council of Environment Ministers (October 6th 2021).^[6] The latter rightly acknowledges that “it seems essential to adopt strong policies as soon as possible to avoid the above environmental damage and adverse health impacts, but also to support Member States in taking protective, remedial and clean-up measures”.

There is no doubt that coordinated action at EU level is absolutely necessary to prevent future PFAS pollution, minimize exposure to PFAs chemicals as much as possible, remediate pollution, address PFAS-originating waste, and duly monitor impacts for the health of population and the environment . In this regard, the current development of a Europe-wide group restriction of all non-essential uses of PFAS is an important step forward.

We are however concerned that very little is currently being done by national authorities, including Belgian ones, to address existing PFAS pollution cases, which are known to already impact the health of local communities and their environment.

In Belgium, PFOS pollution around Antwerp is a reality, as confirmed by the measurement of PFOS in the soil in 2018. Shockingly, eggs hatched within a 15-kilometer radius of the 3M factory of Antwerp were found to pose health risks by researchers of the University of Antwerp, especially for children (due to higher ingestion relative to their weight).^[7] In the summer 2021, sampling organized by Grondrecht and carried out by researchers of the Free University of Amsterdam found excessively high PFOS concentrations in the blood of local residents, with all samples exceeding the recently updated safety threshold for the sum of PFOA, PFNA, PFHxS and PFOS of the European Food Safety Agency (EFSA).^[8] This alarming situation was again confirmed by the recent publication of the results of the analysis of the Flemish Care and Health Agency (Agentschap Zorg en Gezondheid) at the end of October, which find excessive PFOS levels in the blood of more than half of the 800 citizens tested.^[9]

The situation requests urgent action on three main levels, namely environmental and health monitoring, clean-up of the site, and accountability of the polluting companies towards residents and authorities.

We are aware that a Flemish parliamentary inquiry is currently investigating the chain of responsibilities within the regional government and administration and that an administrative procedure is looking into the conditions, in which the Antwerp factory reported for the waste emitted in relation to its operations.

However, to date and as far as we are aware, very few measures have been taken to address the pollution itself in order to cater for the known and presumed health risks encountered by the surrounding communities, besides adapted heath guidelines for food consumption. Given the level of commitment displayed by the Belgian federal authorities with regards to the challenge of PFAS pollution at the European level, we would like to inquire about measures currently being considered and/or developed to address the real-life consequences of the situation of communities in the area of Antwerp and Zwijndrecht. Notwithstanding the complex institutional set-up of the Belgian institutions and split of responsibilities between the regional and national levels, we believe that the seriousness of the situation and its potential far-reaching impacts require the involvement of the federal institutions.

Therefore, with this letter, we would like to ask you what your respective ministries are planning to do in order to:

• Respond to and support the local communities' request for transparency and accountability about the pollution and the related health and environmental consequences;
• Guarantee the precise mapping of the sites requesting cleanup and their effective decontamination, including the site where the Oosterweel project is currently being developed;
• Ensure the due monitoring of the evolution of environmental contamination (through regular measurements in water and soil);
• Guarantee that every possible measure is being implemented to ensure that local communities can have access to clean and safe water and food;
• Ensure the due monitoring of the health-related risks of long-term exposure to PFOS for surrounding communities (including through regular large-scale human biomonitoring for all nearby residents and health follow up for those most at risk) and workforces of the companies concerned. Currently, the Flemish government does not plan to provide individualized testing for all (eg for children, for people who have moved out of the area, for inhabitants of Antwerp) and long-term monitoring of individual health situations. Because of this lack of action, we appeal to the federal government to step in.
• Guarantee that the polluter-pays principle is being implemented, namely that the companies responsible for the pollution in the first place are legally and financially kept accountable.

We look forward to your responses on these important and urgent questions and we would welcome the opportunity to exchange with you in details during a meeting at your earliest convenience.

Yours sincerely,

Genon K. Jensen Jonas Vernimmen
Executive DirectorCoordinator
Health and Environment Alliance (HEAL)LAND RIGHT

Contacts:

Natacha Cingotti: natacha@env-health.org
Jonas Vernimmen: jonas@grondrecht.eu

---

1. https://www.brusselstimes.com/news/belgium-all-news/174208/revealed-flemish-government-knew-about-pfos-problem-in-2017/
2. Stockholm Convention, SC-4/17, Listing of perfluorooctane sulfonic acid, its salts and perfluorooctane sulfonyl fluoride, available from http://chm.pops.int/Implementation/IndustrialPOPs/PFOS/Decisions/tabid/5222/Default.aspx, accessed October 7th 2021.
3. ECHA, Substance Infocard, https://echa.europa.eu/fr/substance-information/-/substanceinfo/100.015.618.
4. See for instance, HBM4EU, Scoping Document for PFAS, 2019, Section 1.1.2 Hazardous Properties, https://www.hbm4eu.eu/wp- content/uploads/2019/03/HBM4EU_D4.9_Scoping_Documents_HBM4EU_priority_substances_v1.0- PFAS.pdf; pp. 1-2.
5. FIGO, FIGO calls for removal of PFAS from global use, May 25th 2021, https://www.figo.org/figo-calls-removal-pfas-global-use.
   See also joint FIGO-UCSF-HEAL multilingual infographic on the health risks associated with PFAS exposure: https://www.env-health.org/how-pfas-chemicals-affect-women-pregnancy-and-human-development-health-actors-call-for-urgent-action-to-phase-them-out/.
6. “The need for a coordinated action againt PFAS – Information from the Belgian delegation”, Information note, September 24th 2021, https://data.consilium.europa.eu/doc/document/ST-12150-2021-INIT/en/pdf, accessed October 4th 2021.
7. Groffen Thimo, Lopez Antia Ana, D' Hollander Wendy, Prinsen Els, Eens Marcel, Bervoets Lieven. Perfluoroalkylated acids in the eggs of great tits near a fluorochemical plant in Flanders, Belgium https://doi.org/10.1016/J.ENVPOL.2017.05.007.
   See also: https://www.brusselstimes.com/news/belgium-all-news/173456/3m-pollution-pfos-eggs-hatched-within-15-km-of-factory-in-antwerp-pose-health-risks- says-uantwerp/.
8. Fundamental right, Press release blood test Zwijndrecht, August 4th 2021,
   http://rggtvqo.cluster031.hosting.ovh.net/facts/actueel/persbericht-bloedonderzoek-zwijndrecht/.
9. Care and Health Agency, Blood test shows high levels of PFOS in more than half of participants – no-regret measures are being expanded, October 26th 2021, https://www.zorg-en-gezondheid.be/bloedonderzoek-toont-hoge-waarden-van-pfos-bij-meer-dan-de-helft-van-de-deelnemers-%E2%80%93-no.