Fluorinated chemicals, or per- and polyfluoroalkyl substances (PFAS), are a large and diverse family of chemistry that makes possible the products that power our lives, including cell phones, aircrafts, alternative energy sources and medical applications. PFAS are vital to enabling our lives in the 21st century.
In recent years, PFAS have been the subject of debate over their potential impact on the environment and human health. Federal and state regulators are closely examining these substances and have taken significant action, including new laws and regulations enacted by Congress and the States, as well as ongoing implementation of EPA’s PFAS Action Plan — one of the most comprehensive plans ever deployed by the agency.
Throughout this process it is critical to recognize that not all PFAS are the same. The review and regulation of PFAS must take into account the significant differences across the many compounds that are part of the PFAS family.
In a recent op-ed published in Chemical Watch, Rob Simon, Vice President of ACC’s Chemical Products and Technology Division, explains how industry has a proven track record of working with regulators and lawmakers to effectively manage and regulate chemicals on the basis of sound science, including with PFAS.
Read Rob Simon’s Op-Ed below or on Chemical Watch here
Why PFAS regulation must recognise the significant differences between compounds
Feb 17, 2020
Fluorinated chemicals – or per- and polyfluoroalkyl substances (PFASs) – are a large and diverse chemical family that makes possible products that power our lives – the cellphones, tablets and telecommunications we use every day; aircraft; alternative energy sources; and even medical equipment.
In recent years, PFASs have been the subject of debate over their potential impact on the environment and human health. US federal and state regulators are examining them closely, and have taken significant steps including enacting new laws and regulations – and implementing the US EPA’s comprehensive PFAS Action Plan.
As an industry, we are committed to addressing potential concerns with PFAS chemistries, and support strong regulations that protect human health and the environment. We welcome this conversation and support rigorous efforts to understand and regulate these chemicals appropriately.
However, throughout this process it is critical to recognise that not all PFASs are the same. Their review and regulation must take into account the significant differences among the many compounds that are part of the PFAS family. Rather than rushing to use a one-size-fits-all approach, we need a fact-based discussion about the nature of these substances, how they differ from each other and what they do affect – and what they don’t – in terms of human health and the environment.
Industry has a track record of working with regulators and lawmakers to manage and regulate chemicals on the basis of sound science. The American Chemistry Council (ACC) worked with lawmakers of both parties as well as industrial, environmental, public health, animal rights and labour organisations in the run up to the 2016 amendments to TSCA. The amendments strengthened the process for regulating chemicals to better protect human health and the environment as well as enhancing public confidence in the federal chemical regulatory system.
With regard to PFASs, eight major industry players voluntarily joined the EPA’s PFOA Stewardship Program, investing more than $700m in research. They also ceased manufacture and use of PFOA and PFOA-related chemicals, and agreed that all new PFAS chemistry undergo enhanced regulatory review before being permitted on the market.
This has led to the development of PFASs that have been subject to strict regulatory review and rigorous scientific research requirements, including testing related to: cancer, reproductive factors; systematic toxicity; bioretention; ecological endpoints; environmental fate; and transport.
Any PFASs that are brought to market have been reviewed and regulated according to their specific properties and behaviours.
With this in mind, the ACC is very concerned by the growing belief that the substances should be banned, restricted, or regulated as an entire class of chemicals, without acknowledging individual properties and behaviours of specific PFASs, or categories of them. This belief is neither scientifically accurate, nor appropriate.
PFASs encompass a wide and diverse array of substances that are characterised by the strong fluorine and carbon (C-F) bond. Even though all share this, the broad universe includes those with very different physico-chemical properties, hazard profiles and uses.
High molecular weight fluoropolymers are one type of PFAS, providing strength, durability and unique electrical properties. They enable medical equipment such as MRI machines and pacemakers to function – also fuel components and electronics used in aircraft. Fluoropolymers are considered of low concern because they are inert, extremely stable, not water soluble and do not present significant toxicity.
Another type of PFAS, fluorotelomers, provide water, oil and soil repellency – properties essential to medical garments that prevent transmission of fluid-borne pathogens. Their hazard profile generally includes an assessment of their breakdown product, perfluorohexanoic acid (PFHxA), which studies have shown does not cause cancer; does not disrupt endocrine activity; does not cause negative effects on human development or reproductive systems; does not build up in the human body; and does not become concentrated in the bodies of living organisms.
Differences like those outlined above are the critical scientific distinctions that must inform the basis of regulating these chemicals. A one-size-fits-all short-cut disregards the specific properties and uses of individual PFAS compounds, and could have unintended consequences.
Rather than blanket regulations or restrictions, a more deliberate approach would assist in prioritising those substances. This would consider the differences between them and offer a pathway for prioritising research and data on this complex chemistry.
We support regulation of PFASs when based on sound science and are committed to being a partner and resource for regulatory bodies and other stakeholders. Our goal is to ensure that they are regulated appropriately – which means according to their specific properties and potential risks rather than by a sweeping, broad brush approach with the potential to severely impact the function and availability of numerous products on which we rely.
Fluorinated chemicals are an engine of innovation in the 21st century. And we must work to ensure that regulation does not stifle the development of products and solutions today’s society needs – but rather fuels their evolution in a way that is sustainable and scientifically sound.
Copyright 2020: This article was re-published with the permission of Chemical Watch www.chemicalwatch.com