The high persistence of PFAS is sufficient for their management as a chemical class

Abstract

Per- and polyfluoroalkyl substances (PFAS) are a class of synthetic organic substances with diverse structures, properties, uses, bioaccumulation potentials and toxicities. Despite this high diversity, all PFAS are alike in...

Regulating PFAS as a Chemical Class under the California Safer Consumer Products Program

“…The available information demonstrates that all PFAS or their degradation, reaction, or metabolism products have at least one hazard trait of concern to the State of California: environmental persistence. As others have argued, high persistence alone can be a sufficient criterion for regulatory action (Cousins et al 2019b(Cousins et al , 2020b). In the case of PFAS, we believe that all members of the class have a potential for significant and widespread adverse impacts due to their extremely high environmental persistence, coupled with growing evidence for human and ecological health hazards for the impurities, metabolites, and degradation products of the subset commonly used in consumer products.…”

Validation of a new cavity ring-down spectrometer for measuring tropospheric gaseous hydrogen chloride

“…The silanization of glass to form an inert fluorinated or silicon coating on a virtual impactor or the introduction of a gaseous fluorinated compound that adsorbs competitively to instrument surfaces in place of the analytes have been demonstrated to substantially reduce surface adsorption on PFA (Ellis et al, 2010;Moravek et al, 2019;Pollack et al, 2019;Roscioli et al, 2016;Wilkerson et al, 2021). However, environmental impacts must be considered when constantly adding fluorinated compounds to sampling flows as they may have deleterious environmental consequences (Cousins et al, 2020). In particular, perfluorobutanesulfonic acid, the fluorinated chemical suggested for passivating inlets (Roscioli et al, 2016), is subject to usage restrictions in some European countries (ECHA, 2020) based on potential negative human and environmental health impacts (Benskin et al, 2012;Sunderland et al, 2019).…”

The P-Sufficient Approach: A Strategy for Regulating PFAS as a Class

“…In addition, the authors wrote that other chemical classes may lend themselves to the P-sufficient approach, including nonylphenol ethoxylates in laundry detergents and microplastics. 3 Although many environmental scientists believe a P-sufficient approach is a step in the right direction when it comes to PFAS, 7 it does not completely solve the problem of regrettable substitutions. "Just because something is nonpersistent, doesn't mean that it is safe," Cousins says.…”

“…7 The idea behind the P-sufficient approach is that the persistence of PFAS is a sufficient basis to warrant regulation regardless of, say, the chemicals' bioaccumulation potential or toxicity. 7 That is different from most chemical regulatory approaches, which tend to focus on hazard traits, such as whether a chemical is suspected or known to cause adverse health effects, Cousins explains. "We know that if we keep emitting PFAS, their concentrations in the environment will increase, because they do not degrade, and ultimately some known or unknown 'effects threshold' will be Greaseproof paper food packaging can expose people to PFAS if the chemicals migrate into the packaged food.…”

“…Cousins and other environmental scientists have advocated for a persistence-sufficient, or “P-sufficient,” approach to regulating PFAS. 7 The idea behind the P-sufficient approach is that the persistence of PFAS is a sufficient basis to warrant regulation regardless of, say, the chemicals’ bioaccumulation potential or toxicity. 7 That is different from most chemical regulatory approaches, which tend to focus on hazard traits, such as whether a chemical is suspected or known to cause adverse health effects, Cousins explains.…”