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PFAS Grouping: An Emerging Scientific Consensus

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Tom Flanagin
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PFAS/Fluorotechnology Enables Life in the 21st Century

Various PFAS products including wind turbines, eletronic devices, an automobile, medical equipment, a construction site and a microchip.

Per- and polyfluoroalkyl substances (PFAS), or Fluorotechnology, are a diverse universe of chemistries that makes possible the products that power our lives – the cellphones, tablets and telecommunications we use every day to connect with our friends and family; the aircraft that power the U.S. military; alternative energy sources critical to sustainability goals; and medical devices that help keep us healthy.

However, all PFAS are not the same. Individual chemistries have their own unique properties and uses, as well as environmental and health profiles.

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According to the U.S. Environmental Protection Agency, “approximately 600 PFAS are manufactured (including imported) and/or used in the United States.” Among these 600 are substances in the solid (e.g., fluoropolymers), liquid (e.g., fluorotelomer alcohols) and gaseous (e.g., hydrofluorocarbon refrigerants) forms. The fundamental physical, chemical, and biological properties of solids, liquids and gases are clearly different from one another. The very distinct physical and chemical properties of the three types of commercial PFAS described demonstrate how varied they are and how a simple grouping approach to risk would be inadequate.

However, some have proposed grouping all PFAS chemistries together for the purposes of regulation. Although the grouping of some substances within the class based on similar physical, chemical, and biological properties may be possible – a proposal to regulate all PFAS as a single class is neither scientifically accurate nor appropriate

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1. ECOS. Processes & Considerations for Setting State PFAS Standards (February 2020).2. https://dec.vermont.gov/sites/dec/files/PFAS/20180814-PFAS-as-a-Class.pdf.3. NASEM. Workshop on Federal Government Human Health PFAS Research, October 26-27. Board on Environmental Studies and Toxicology (2020).https://www.nap.edu/read/26054/chapter/1.4. Goodrum PE et al. Application of a framework for grouping and mixtures toxicity assessment of PFAS:a closer examination of dose additivity approaches. Toxicol Sci: 1-19 (2020). https://doi.org/10.1093/toxsci/kfaa123.

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