EPA Flunks PFAS Chemistry Test

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Monday, June 27, 2022
Kyla Bennett (508) 230-9933

EPA Flunks PFAS Chemistry Test

New Advisories Ignore Precursors That Transform into Most Toxic Fluorinated Chemicals


Washington, DC —By setting strict health advisories for PFOA and PFOS (two of the thousands of PFAS or per- and polyfluoroalkyl substances), the U.S. Environmental Protection Agency must now rapidly move to set health advisories for all PFAS chemicals that transform into these two PFAS, according to Public Employees for Environmental Responsibility (PEER). In a letter to Radhika Fox, EPA’s Assistant Administrator for Water, PEER asks EPA to also address the many PFAS whose terminal end products are PFOA and PFOS.

Earlier this month, EPA issued interim drinking water Health Advisories for PFOA at 4 parts per quadrillion (ppq) and 20 ppq for PFOS. While saying in essence that there are no safe levels of PFOS and PFOA in drinking water, EPA did not address the many PFAS whose terminal end products are PFOA and PFOS. This chemical transformation can occur during incineration, chlorination, ozonation, and metabolic breakdown.

“By failing to issue Health Advisories on PFAS that break down into PFOA and PFOS as terminal degradation products, EPA is negating what it is trying to achieve,” stated PEER Science Policy Director Kyla Bennett, a scientist and attorney formerly with EPA. “This illustrates the utter folly of EPA’s chemical-by-chemical approach to PFAS. To effectively protect human health and the environment, PFAS need to be regulated as a class of chemicals.”

The agency appears to concede this concern. In its latest Advanced Notice of Proposed Rulemaking, filed this month, EPA disclosed:

“The EPA… will seek public input on further PFAS-related designations under CERCLA [Superfund]. As examples, the Agency may request input regarding the potential hazardous substance designation of precursors to PFOA and PFOS; hazardous substance designation of additional PFAS; and designation, or designations of classes or sub-classes of PFAS as hazardous substances.” [Emphasis added]

“EPA should already have collected input on precursors, rather than deferring this inquiry to sometime in the future,” added PEER Executive Director Tim Whitehouse, a former EPA enforcement attorney, noting the agency has yet to act on a more than two-year-old PEER rule-making petition to classify PFAS as hazardous waste. “EPA continues to approach the PFAS crisis in a time-consuming and ultimately futile piecemeal fashion, without a coherent comprehensive plan.”

In its letter to Assistant Administrator Fox, PEER urged EPA to immediately begin identifying and publicizing the list of all PFAS currently in commerce that have PFOA and PFOS as terminal end products. Once that determination is made, PEER asks that the agency take commensurate regulatory action.


Read the PEER letter to EPA

Look at EPA plan to search for precursors

See EPA’s lack of consistent PFAS definition

Examine PEER analysis of new EPA PFAS Advisories

Revisit PEER’s still pending hazardous waste petition

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