Industry has proactively innovated to develop new FluoroTechnology chemistries and adopted best practices to help minimize emissions.

  • Globe and Sun Most of the attention to date on PFAS has focused on a handful of substances which are no longer produced in the U.S., Europe, or Japan.
  • Working closely with EPA and other regulators, starting in the early 2000s, industry voluntarily phased out long-chain PFAS chemistries.
  • As a result of these actions, blood levels of legacy PFAS (e.g., PFOA, PFOS) have declined dramatically according to data collected by the Centers of Disease Control and Prevention (CDC). Moreover, recent comprehensive monitoring of PFAS in drinking water conducted in Michigan and elsewhere suggests a low frequency of detection and low levels observed when detected.
  • In conjunction with the phase out of long-chain PFAS chemistries, industry developed new short-chain PFAS chemistries. These new chemistries have been thoroughly reviewed by regulators prior to introduction into commerce, are subject to ongoing review, and are supported by a robust body of rigorous scientific health and safety data.
  • In the US these substances have been reviewed under the new chemicals review program of the Toxic Substances Control Act (TSCA) with specific testing requirements related to cancer, reproductive/developmental factors, systematic toxicity, bioretention, ecological endpoints, environmental fate, transport and other factors. See New Chemicals Program Review of Alternatives for PFOA and Related Chemicals.
  • In addition, manufacturers and many users of today’s PFAS are implementing a variety of practices and technologies to help minimize environmental emissions.  Best practice guidance documents have been developed for the textile and firefighting foam industries.

The scientific and safety data on specific PFAS substances should guide public policy.

  • Effective chemical regulation, regardless of the substance, includes consideration of a substance’s hazard characteristics, its uses, and actual levels of exposure to assess potential risk and determine whether risk management measures are necessary.
  • A large body of scientific evidence, including decades of research by industry, academia, and independent parties, is available on long-chain PFAS materials and should be utilized to guide the assessment and regulation of these substances.
  • A large body of data on today’s short-chain PFAS has also been developed and provided to regulators in the U.S. and globally as part of their chemical review processes, including EPA’s New Chemicals Program under the Toxic Substance Control Act (TSCA).
  • For example, new PFAS chemistries undergo rigorous testing and regulation before they can be placed on the market. This includes ongoing review and data requirements through enforceable orders that are in place with U.S. regulatory authorities.

Taking an overly broad and non-scientific approach to addressing PFAS will make it difficult to implement effective regulatory policies and will impact a broad swath of the economy.

  • Industry has proactively innovated to develop new FluoroTechnology chemistries and adopted best practices to help minimize emissions. The chemical Industry supports a comprehensive approach to chemical management that protects human health and the environment.
  • There are clear scientific rationales for not treating all PFAS the same. For these reasons, different PFAS require different regulatory approaches. Given these differences, efforts to regulate all PFAS together will not be effective and will not address current regulatory priorities.
  • PFAS are an important enabling technology for essential parts of the economy, so restricting all PFAS could have significant implications for a broad range of industries and the important products they provide.
  • An overly broad approach could also have substantial implications for public entities such as airports, hospitals, drinking water facilities, towns and municipalities.
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