This blog is adapted from an Op-Ed originally published by Environmental Health News on Nov. 23 and is authored by Lauren Ellis, Research Analyst and Maricel Maffini, consultant.
Per- and polyfluoroalkyl substances (PFAS) are a group of highly persistent chemicals used in hundreds of products. Many PFAS are toxic and have been detected in the bloodstream of virtually all Americans. It’s an ongoing public health and environmental emergency that requires immediate and comprehensive action.
The good news is the White House recently outlined its plan to tackle PFAS pollution already in our water, air and food.
These are worthy efforts, and EDF commends the Biden-Harris Administration for taking these important steps. In addition to these initial actions aimed at addressing legacy pollution, it is also crucial to prevent additional PFAS from entering commerce and further polluting our environment.
In an Op-Ed published today by Environmental Health News, EDF Environmental Health Research Analyst Lauren Ellis and EDF consultant Maricel Maffini laid out seven steps the federal government should take to address PFAS in commerce and help turn off the tap on new PFAS pollution. The recommendations range from adopting a comprehensive definition for PFAS and taking a class-based approach to regulating the chemicals to phasing out all but essential uses of the substances.
The nation’s growing PFAS problem
PFAS are a broad category of widely used synthetic chemicals that can effectively repel water, resist stains, lubricate surfaces and more. They are often added to clothing, furniture, cosmetics, and food packaging, leading to human exposures. Additionally, decades of manufacturing, use, and disposal of PFAS and PFAS-containing products have significantly contaminated the environment, leading to further exposures via polluted air, water, and food.
In addition to being detected in the bloodstream of most Americans, recent studies have found PFAS in umbilical cord blood and breast milk, indicating that exposures begin in the womb and continue through one’s lifetime. This poses a major public health concern, as epidemiological evidence suggests that PFAS exposure may lead to health problems such as cardiovascular disease, cancer, low birth weights, and impaired immune responses.
While the country has moved away from the use of some PFAS – for example, through corporate phase-outs or regulatory restrictions on PFOA and PFOS, where evidence of their harm is overwhelming – the fluorochemical industry continues to develop new chemicals in that family in the name of innovation and economic profit. These newer iterations – often promoted as safer alternatives or pushed through regulatory loopholes – not only persist like those they attempted to replace, but they pose many of the same public health risks.
PFAS are often added to food packaging and other commonly used items, leading to human exposures.
Recommendations
Here are seven recommendations for a whole-of-government approach to address PFAS still being used and avoid putting more unsafe chemicals into commerce:
1. Adopt a comprehensive PFAS definition and regulate PFAS accordingly:
- Require all federal agencies to use OECD’s PFAS definition to ensure a clear and consistent definition that accounts for all relevant fluorinated substances.
- Regulate all PFAS as a class, given their persistence and potential for similar impacts.
2. Demand adequate data for assessing risks from PFAS, new and old:
- Develop a national PFAS testing strategy to require companies to fund and conduct studies on new and existing individual PFAS and PFAS mixtures. EPA’s testing strategy is a first step, but a broader testing plan is needed across the entire federal government.
- Require companies to provide sufficient data for PFAS risk assessment, which should include data on bioaccumulation in plants, animals and humans; testing on relevant complex health endpoints like cancer; developmental and reproductive toxicity; immune, endocrine, and neurobehavioral toxic effects; and information on exposures from all sources, especially during pregnancy.
3. Enhance reporting of PFAS uses and exposure:
- Build upon EPA’s proposed PFAS reporting rule by mandating that agencies require companies to report the same information on PFAS, regardless of regulatory jurisdiction or production volume.
- Eliminate reporting loopholes for PFAS mixtures by requiring that all discharges of PFAS mixtures, regardless of their concentration, be reported by industry to EPA’s Toxics Release Inventory.
- Require PFAS manufacturers to submit analytical standards to fingerprint their chemicals. Analytical standards are crucial to the federal government’s efforts to improve its testing methods, identify contaminants, and initiate enforcement actions.
4. Pause authorization of new PFAS and PFAS uses:
- Issue a moratorium on the production of new PFAS and expanded use of PFAS already on the market, unless and until adequate data are available to make a proper safety determination.
- Eliminate safety review exemptions for new PFAS and new uses of existing PFAS regardless of production volume or type of use.
5. Reassess previous decisions that allowed PFAS to come to market.
- Use a cumulative risk assessment framework that considers co-exposures to other environmental chemicals, including other PFAS, and non-chemical environmental stressors.
- Incorporate environmental justice considerations such as the disproportionately high exposures faced by populations living near facilities that manufacture or use PFAS, and workers involved in the production and use of PFAS or PFAS-containing products.
6. Monitor and restrict domestically produced and imported PFAS:
- Establish a national program to monitor PFAS using broad screening tools such as total organic fluorine methods, which will allow regulators to move beyond looking at one PFAS at a time and improve their understanding of the presence of these chemicals in the environment.
- Conduct inspections and take enforcement actions when companies that manufacture PFAS or PFAS-containing products do not comply with regulations.
- Establish controls on imported products, as it is well known that PFAS-containing products, including some that contain chemicals banned or no longer manufactured in the U.S., such as PFOA, are manufactured abroad.
7. Apply the concept of essential use in PFAS regulation
- Define criteria for essential and non-essential PFAS uses across the federal government.
- Develop a path to eliminate non-essential uses of PFAS and substitute all uses with available non-PFAS alternatives.
- Use the administration’s procurement power to purchase products free of non-essential PFAS.
We urge the administration to consider these recommendations to protect the environment and public health from continued PFAS pollution.