Response to “Comment on Scientific Basis for Managing PFAS as a Chemical Class

By Carol F. Kwiatkowski, David Q. Andrews, Linda S. Birnbaum, Thomas A. Bruton, Jamie C. DeWitt, Detlef R.U. Knappe, Maricel V. Maffini, Mark F. Miller, Katherine E. Pelch, Anna Reade, Anna Soehl, Xenia Trier, Marta Venier, Charlotte C. Wagner, Zhanyun Wang, and Arlene Blum
Environ. Sci. Technol
February 1, 2021
DOI: 10.1021/acs.estlett.1c00049

Our recent publication titled, “Scientific Basis for Managing PFAS as a Chemical Class”, concludes that the combination of high persistence, accumulation potential, mobility, and known and potential harm of the thousands of PFAS (per- and polyfluoroalkyl substances) identified to date justifies managing them as a single class of chemicals. Class-based approaches have been applied to other chemicals as a more efficient and effective alternative to the traditional approach of addressing one chemical at a time that is time-consuming and costly. Regulatory work in the European Union has recently begun to apply this framework to PFAS in its Chemicals Strategy for Sustainability.

Here we are responding to the comment by Singh and Papanastasiou (DOI: 10.1021/acs.estlett.0c00765) who disagree with a class-based approach to PFAS and build their argument around hydrochlorofluorocarbons (HCFCs), hydrofluorocarbons (HFCs), and hydrofluoroolefins (HFOs), which are fluorinated gases used in refrigeration, air conditioning, and other applications. It is worth noting that the authors work for Honeywell International Inc., a major manufacturer of PFAS refrigerant gases and other fluorinated products, as they disclosed. We are grateful for this opportunity to expand the public discourse regarding specific uses of PFAS and to provide examples demonstrating the importance of managing the entire class of PFAS.

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