Read the full article by Maria Doa (Environmental Defense Fund)
“EDF this week sent EPA a letter identifying opportunities for the agency to improve the effectiveness and transparency of its strategy for testing per- and polyfluoroalkyl substances (PFAS).
EPA unveiled its National PFAS Testing Strategy (Testing Strategy) last fall, laying out its plan to better understand the class of chemicals and inform its future regulatory efforts. PFAS are a large group of synthetic chemicals used to impart water, oil, grease, and stain resistance to various materials, and they are used in hundreds of everyday products, from water-proof clothing to grease-proof food packaging. By its own count, EPA says there are more than 12,000 individual PFAS.
In their letter to EPA, EDF analyst Lauren Ellis and post-doctoral fellow Lariah Edwards commended the agency for developing a strategy to address some of the significant data gaps that exist around PFAS and committing to use its authority under the Toxic Substances Control Act (TSCA) ‒ the country’s main chemical safety law ‒ to require manufacturers to provide toxicity data on the chemicals.
As the letter points out, however, in its current state, the Testing Strategy lacks sufficient detail and is too narrow to fulfill the agency’s intended purpose to understand and regulate PFAS in a way that is protective of both human health and the environment.
PFAS have been dubbed ‘forever chemicals’ because they do not easily break down and are extremely persistent in the environment. They have been detected across the country, in California well-water, milk from Maine dairy farms, and even raining down around the Great Lakes. As such, it is critical that EPA not delay action to reduce exposures to this class of chemicals as it develops information through the Testing Strategy.
What we have learned about the health and environmental effects associated with a small set of these chemicals is troubling, revealing serious concerns about PFAS’ toxicity and their potential to bioaccumulate in plants, animals, and humans. Given the established threat of PFAS such as PFOA and PFOS, as well as some of their replacements like GenX, many people, particularly in communities exposed to multiple PFAS, are legitimately concerned about the potential risks presented by the entire class.
This makes it vitally important to develop an effective and health protective strategy for testing PFAS. The following are six steps the EPA can and should take to enhance its Testing Strategy:
- Adopt a broader definition of PFAS. The current strategy applies an overly narrow definition of PFAS, representing approximately 2,350 substances, or about one in five of the more than 12,000 individual PFAS that EPA has identified. EPA should modify its definition of what constitutes a PFAS to include any chemical substance containing at least one fully fluorinated carbon atom. Such a definition is consistent with that used by other authoritative bodies in the United States and around the world, such as the OECD.”…