PFAS: Here’s What You Need to Know
Posted on July 25, 2019 | in Environmental Compliance
You may have heard or seen recent news stories about a class of chemicals called perfluoroalkyl and polyfluoroalkyl substances, more commonly referred to as PFAS. But what are PFAS, why are they important, and what do you most need to know about them? In this post, we’ll provide you with an overview of PFAS, their risks, the regulatory activity surrounding their use, and how those regulations may affect you.
What Are PFAS?
PFAS are a group of synthetic chemicals that have been widely manufactured since the 1940s. The most well-known and frequently studied PFAS are perfluorooctanoic acid (PFOA) which is used in the manufacture of Teflon, and perfluorooctane sulfonate (PFOS), a common ingredient in fabric protectors and stain repellants.
Additional products containing PFAS, and locations where PFAS contamination have been found include:
- Commercial household products, including polishes, waxes, paints, cleaning products, firefighting foams, nonstick products (including Teflon) such as cooking ware, and stain and water-repellant fabrics
- Packaging, including packaging for some food products
- Workplaces that commonly use PFAs including production facilities or industries, such as chrome plating, electronics manufacturing, or oil recovery.
- Drinking water, when locally impacted by specific industries that use PFAS. This is an issue that has understandably attracting a great deal of recent attention.
Why Are People Concerned About PFAS?
Studies of PFOA and PFOS indicate that they can cause reproductive and developmental defects, liver and kidney damage, immunological effects in laboratory animals, and may cause the development of tumors. Findings also consistently show increased cholesterol levels among exposed populations.
There is also limited evidence of a link between PFAS exposure and the following health effects:
- Low infant birth weight
- Effects on the human immune system
- Cancer (for PFOA exposure, specifically)
- Thyroid hormone disruption (for PFOS exposure, specifically)
A further concern is that studies show PFAS are highly persistent in both the environment and in human tissues, meaning that they don’t easily break down and therefore accumulate over time.
One tragic example of the impact of PFAS is the existence of a 25-square mile swath of contamination in Western Michigan resulting from decades of nearby manufacturing activities. According to local news reports, blood test results for one resident of that area showed PFOS concentrations that were approximately 750 times the national average.
What is Being Done About PFAS?
Voluntary phase-outs of PFAS have already occurred, including the PFOA Stewardship Program in which eight major chemical manufacturers agreed to eliminate the use of PFOA and PFOA-related chemicals in their products, as well as emissions of those chemicals from their facilities. Currently PFOA and PFOS are no longer manufactured in the United States, but still enter the country via imports of consumer goods such as carpeting, leather and apparel, textiles, paper and packaging, rubber and plastics.
Growing public concern over PFAS has also prompted EPA to develop its PFAS Action Plan outlining the steps the Agency is taking to protect the public from PFAS exposure. The Action Plan involves a concerted effort encompassing a number of strategies, and the participation of several departments within the Agency. Some of the key actions EPA is taking include:
- Research — EPA continues to conduct and analyze research to assess levels of PFAS present in the environment, including in drinking water, and to better understand health effects and potential remediation methods.
- Monitoring — The Agency will propose nationwide drinking water monitoring for PFAs under the next Unregulated Contaminated Monitoring Rule (UCMR) monitoring cycle. Additional monitoring results will improve understanding of the frequency and concentration of PFAS in drinking water, which can inform future regulatory actions.
- Cleanup — EPA has designated PFOA and PFOS as hazardous substances in an effort to strengthen enforcement authority and cleanup strategies, and is developing interim groundwater remediation recommendations. Information in the Spring 2019 Regulatory Agenda indicates that EPA is tentatively targeting October 2019 for a Notice of Proposed Rulemaking (NPRM) to designate PFOA and PFOS as “hazardous substances” under section 102 of the Comprehensive Environmental Response, Compensation, and Recovery Act (CERCLA), commonly known as “Superfund.”
- Drinking Water — Since drinking water contamination is one of the most serious public concerns regarding PFAS, EPA is moving forward with the Maximum Contaminant Level (MCL) process for PFOA and PFOS, while also gathering information to determine if regulation is warranted for a broader class of PFAS. According to information in the Spring 2019 regulatory Agenda, EPA intends to make preliminary regulatory determinations for PFOA and PFOS by the end of 2019, which could bring the Agency closer to establishing MCLs for those chemicals.
- Reporting — EPA recently disclosed that they are beginning the process of collecting information to determine whether to add certain PFAS to the list of chemicals reportable under Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA), otherwise known as Toxic Release Inventory (TRI) or “Form R” reporting. Should EPA add certain PFAS to the list of reportable chemicals, facilities that manufacture, process or otherwise use amounts of those PFAS above threshold quantities would need to complete and submit Form R reports for them by July 1 of each year.
- Enforcement —Enforcement spans all of EPA’s current and future regulatory actions related to PFAS. According to a fact sheet on the Action Plan, EPA will take appropriate actions “to address PFAS” exposure in the environment and assist states in enforcement activities.”
As public concern continues to grow, we expect to hear more about PFAS in the media. In fact, corporate responsibility for addressing the environmental impacts of PFAS was the focus of a Congressional subcommittee hearing on July 24, 2019 during which various stakeholders including members of communities affected by PFAS pollution will seek to increase awareness, spur future action and hold chemical companies more accountable.
How Does This Affect Me?
As more information becomes available about the extent and health effects of PFAS exposures, and as regulatory scrutiny continues to increase, it’s going to be more important than ever to know exactly how your business will be impacted. As with many other modern chemical management challenges, this is not simply a regulatory issue. Both internal and external stakeholders are demanding greater accountability from corporations with regard to their sustainability and chemical stewardship activities.
The essential starting point is to know whether you have products containing PFAS in your chemical inventory. That means not only having an up-to-date inventory list of all of your chemical products, but also having insight into the ingredients of those chemicals, since the name of a product may not necessarily reveal whether it contains PFAS. Visibility of your chemical inventory at the ingredient-level will help you know not only whether PFAS are present in your facilities, but also where they are located and how much is present.
You’ll also need to be prepared to start tracking the movement of certain PFAS through your inventory for the purposes of TRI reporting, should EPA add those substances to the list of TRI-reportable chemicals. TRI requirements are highly technical, and affected businesses would be wise to consider the advantages of modern EHS software for coordinating your chemical management systems, including chemical inventory tracking and TRI reporting compliance.
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From all of us here at VelocityEHS, we wish you good luck, and many safe and happy days.