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ACC Responds to Misleading PFAS Report

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Tom Flanagin
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Today’s article in Environmental Science & Technology Letters makes several misleading claims about PFAS that need to be addressed.

PFAS are a large and 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 aircrafts that power the U.S. military; alternative energy sources; and medical devices that help keep us healthy. In fact, right now, PFAS are being used to support COVID-19 testing equipment and to provide lifesaving protection in medical garments – both uses that are helping save lives around the world in the midst of this pandemic. PFAS are vital to enabling our lives in the 21st century.

However, all PFAS are not the same. Different types of PFAS have different properties and uses, as well as different environmental and health profiles. A one-size-fits-all approach to regulating PFAS is neither scientifically accurate nor appropriate and threatens to take away important products that families and businesses rely on. Furthermore this approach is unnecessary as claims of “thousands” of PFAS chemistries are false. For example, the EPA has identified about 600 PFAS that are active in commerce.

The article also makes a misleading claim about the National Academies of Sciences, Engineering, and Medicine (NASEM), which actually rejected a single class approach to assessing the potential hazards of another class of chemistry.

Furthermore, evaluations of “essentiality” are not and should not be limited to just one factor. It is critical to take a comprehensive approach that considers multiple factors, including chemical safety, product safety, performance, cost, product life cycle, etc. This extends well beyond the chemical that may be substituted and requires a holistic approach to product design.

Consumers should have confidence in the fact that today’s products made with or containing PFAS do not present a significant risk to human health or the environment. Regulators around the world, including the US EPA, have confirmed the safety of the PFAS used in products today based on a robust body of scientific data. Likewise, similar conclusions have been reached by multiple regulatory bodies globally. We support regulation of PFAS when based on sound science and we are committed to being a partner and resource for regulatory bodies and other stakeholders. Our goal is to ensure that PFAS are regulated appropriately – which means they should be regulated by their specific properties and potential risks rather than by a sweeping, broad brush approach with the potential to severely impact the functionality and safety of numerous products we rely on every day.

American Chemistry Council

The American Chemistry Council (ACC) represents the leading companies engaged in the business of chemistry. ACC members apply the science of chemistry to make innovative products and services that make people's lives better, healthier and safer. ACC is committed to improved environmental, health and safety performance through Responsible Care®; common sense advocacy designed to address major public policy issues; and health and environmental research and product testing. The business of chemistry is a $486 billion enterprise and a key element of the nation's economy. It is among the largest exporters in the nation, accounting for ten percent of all U.S. goods exports. Chemistry companies are among the largest investors in research and development. Safety and security have always been primary concerns of ACC members, and they have intensified their efforts, working closely with government agencies to improve security and to defend against any threat to the nation’s critical infrastructure.

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