Re Advance Notice on the Regulation of Perfluoroalkyl, Polyfluoroalkyl Substances (PFAS) as a Class

December 15, 2020

Over the past few decades per- and poly-fluoroalkyl substances (PFAS) contamination has grown into a serious global health threat. PFAS are extremely persistent, highly mobile in the environment and many have been found to bioaccumulate, or build up, in humans and animals. People are concurrently exposed to dozens of PFAS chemicals daily through their drinking water, food, air, indoor dust, carpets, furniture, personal care products, and clothing. As a result, PFAS are now present throughout our environment and in the bodies of virtually all Americans. PFAS are associated with many serious health effects such as cancer, hormone disruption, liver and kidney damage, developmental and reproductive harm, changes in serum lipid levels, and immune system toxicity - some of which occur at extremely low levels of exposure. Additionally, because PFAS are chemically related, they may have additive or synergistic effects on target biological systems within our bodies. The number of chemicals in the PFAS class is growing rapidly. EPA Comptox Dashboard now indicates there are over 9,000 unique PFAS structures.3 For most of these chemicals there is limited to no data on their potential toxicity to human health and the environment. However, evidence from known PFAS, including both legacy and replacement PFAS, is growing quickly that indicates that they collectively pose similar threats to human health and the environment, often at exceedingly low doses. These toxicity data, combined with concerns over their similar environmental mobility and persistence and widespread human and environmental exposure, have led scientists and other health professionals to express concern about the continued and increasing production and release of PFAS. As a result scientists from around the world have called for PFAS to be managed as a class.

Read the technical comments here.