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      Food for Thought: Why A “One-Size-Fits-All” Approach Has a Bad Taste

      Imagine a world without fuel for our cars, medications to treat diseases or even technologies like the device you are using right now. Every day, we rely on the innovations of modern chemistry to help make our lives safer, healthier and more sustainable.

      But what if policies were being enacted that could put these chemistries and innovations at risk? When activist groups, such as Safer Chemicals Healthy Families, tout a “one-size-fits-all” approach to ban, restrict or regulate entire classes of chemistry, it promotes a misguided measure that could have a major impact on our society.

      The truth is it doesn’t make for effective science-based policy. As an industry, the American Chemistry Council (ACC) is committed to addressing potential concerns about chemicals and supports strong regulations that protect human health and the environment. However, the growing practice of banning, restricting or regulating entire classes of chemicals, without acknowledging their individual properties and behaviors, is neither scientifically accurate nor appropriate.

      Let’s think of this in terms of something we’re all very familiar with: berries. There are the ones we eat — like blueberries, raspberries and strawberries. And then there are the ones that are inedible — like holly berries and ivy berries. If consumed, those berries can make you sick.

      They may all be called “berries” — but they are all very different.

      Banning ALL berries — because one presents a potential risk — doesn’t make sense. The same goes for chemicals, such as phthalates, bisphenols, fluorinated chemistries and flame retardants. While the names of the chemicals may be similar, the differences in their use, structure, safety and environmental profiles make them unique.

      Today, those working in the chemical industry are focused on the needs of tomorrow. In order to build a more sustainable future, chemistry is vital. By banning entire chemical families, we are eliminating many of the achievements, innovations and useful products that the individual chemicals within these families can make possible now and in the future. The result can be a safer, more sustainable and more innovative world for us all.

      Interested in a little more food for thought? ACC and its members collaborate with downstream users, retailers, manufacturers and government regulators to support the safe use of chemicals in consumer products. Come visit MindtheScience.org to learn about science-based information on how some of the chemicals you may read about may be used in consumer products; the important benefits that they can provide; and safety testing and evaluations these chemicals have undergone.

      Latest Research Reveals Flaws in Grouping

      But don’t take our word for it. A scientific consensus is emerging that it is not accurate or even possible to group all PFAS chemistries together for the purpose of regulation. Indeed, state and federal entities that have explored the possibilities of a class-based approach have recognized the significant challenges.

      For instance:

      • ECOS1 – the Environmental Council of the States – which represents state and territorial environmental agency leaders, several of whom have implemented regulatory programs in their home states, has said: “Many regulators and subject-matter experts advise against grouping PFAS as an entire class.”
      • The Vermont Department of Environmental Conservation2, which was specifically charged by the legislature to develop a class regulation or to explain why such a regulation wasn’t possible said, “The Review Team spent over a year deliberating, researching, and discussing the potential to regulate PFAS as a Class. After reviewing the current peer-reviewed literature, as well as the available toxicology data for PFAS, the Review Team determined that at the current time it is not feasible to regulate PFAS as a Class.”
      • And federal scientists participating in a workshop convened last fall by the National Academies of Science, Engineering, and Medicine (NASEM) to review the federal PFAS research program acknowledged the broad diversity of properties with this group of substances, concluding that3 “PFAS substances thus present unique challenges for grouping into classes for risk assessment.”
      • These state and federal entities findings are also echoed in a recent scientific, peer-reviewed publication4 evaluating possible grouping frameworks to assess PFAS.

      1. ECOS. Processes & Considerations for Setting State PFAS Standards (February 2020).
      2. https://dec.vermont.gov/sites/dec/files/PFAS/20180814-PFAS-as-a-Class.pdf.
      3. NASEM. Workshop on Federal Government Human Health PFAS Research, October 26-27. Board on Environmental Studies and Toxicology (2020). https://www.nap.edu/read/26054/chapter/1.
      4. Goodrum PE et al. Application of a framework for grouping and mixtures toxicity assessment of PFAS: a closer examination of dose additivity approaches. Toxicol Sci: 1-19 (2020). https://doi.org/10.1093/toxsci/kfaa123.

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