Reports on PFAS and Freshwater Fish Are Misleading
Recent news reports following the publication of Barbo et. al are continuing the alarming trend of taking a specific example of PFAS levels detected in the environment and expanding it exponentially into an unscientific, overly broad indictment of hundreds of chemistries that benefit our lives every day. This inaccurate picture about what threat, if any, is posed due to PFAS exposure does a disservice to the public by creating unnecessary alarm, increasing economic challenges to small businesses, and threatening to divert attention, funding, and resources from more pressing priorities.
It’s important for news outlets to make it clear that all PFAS chemistries are not the same. Individual chemistries have their own unique health and environmental profiles. In fact, renewable energy, electronics, health care, transportation and air travel all rely on a particular category of fluorinated chemistries (fluoropolymers) that are of low concern to health and the environment but offer tremendous benefits.
The public should be aware that PFOS and PFOA, two types of PFAS, were voluntarily phased out of production and use by leading manufacturers in the chemical industry. Furthermore, there is disagreement on the health effects of these chemistries by the regulatory community, including disagreement between the EPA and the World Health Organization. It is also notable that levels of PFOS found in humans have dropped by more than 85 percent since 1999, according to the U.S. Centers for Disease Control and Prevention.
Today’s PFAS chemistries have been subject to rigorous review by regulators before being introduced into commerce, and federal and state agencies continue ongoing review of products utilizing these chemistries.
Industry is dedicated to the responsible production, use, and management of PFAS chemistries in a manner that protects the public health and our environment. The manufacturers of PFAS chemistries are employing practices and technologies to minimize environmental emissions, and they continue to research and innovate waste management practices, which would allow potential end-of-life issues to be managed.
EPA Should Not Move Forward with The Proposal Until It Has Established an Appropriate Cleanup Level Based on The Best Available Science
The Proposed CERCLA Designation Would Impose Tremendous Costs on These Parties Without Defined Cleanup Standards, Making It Impossible for These Entities to Prepare for The Impact of This Rule
EPA’s Revised Lifetime Health Advisories (LHAs) for PFOA and PFOS Reflect a Failure of The Agency to Follow Its Accepted Practice for Ensuring the Scientific Integrity of Its Process