Baby Steps towards Regulating PFOA and PFOS

Late last week the U.S. Environmental Protection Agency (EPA) announced their Per- and Polyfluoroalkyl Substances (PFAS) Action Plan, taking the first steps in the process to create a maximum contaminant level (MCL) for perfluorooctane sulfonic acid (PFOS) and perfluorooctanoic acid (PFOA) to regulate these chemicals under the Safe Drinking Water Act. The EPA press release stated that the EPA plans to move forward with the MCL process required under the Safe Drinking Water Act for PFOA and PFOS the two most prevalent PFAS chemicals. According to the EPA, they will propose a regulatory determination by the end of the year, which is the next step in the Safe Drinking Water Act process for establishing an MCL, but far from taking action. When the MCL will be established is unknown, EPA has yet to determine a MCL for perchlorate that it decide and announced its intent to regulate in 2011.

The manufacture and import of PFOA has been phased out in United States as part of the PFOA Stewardship program. The last time PFOS manufacture was reported to EPA was 2002, existing stocks of PFOA might still exist and there might be PFOA in some imported articles. However, ceasing to manufacture these chemicals did not begin to solve this widespread problem. PFOA waste was buried in unlined pits and has contaminated Parkersburg, West Virgina migrated into streams and groundwater contaminating parts of the Ohio River and the groundwater basin.  In addition, there are many different types of PFAS besides PFOA and PFOS.

PFAS was used to keep food from sticking to cookware (original Teflon pans), to make sofas and carpets resistant to stains (Scotchguard), to make clothes and mattresses more waterproof, and to make some food packaging resistant to grease absorption as well as use in some fireproof materials like baby cloths. Because PFAS help reduce friction, they are also used in a variety of other industries, including aerospace, automotive, building and construction, and electronics.

PFAS are synthetic chemicals that do not occur naturally in the environment. PFAS are extremely persistent in the environment and resistant to typical environmental degradation processes. Some long-chain PFAS bioaccumulate in animals and can enter the human food chain. PFOS and PFOA are two of the most studied PFAS. Exposure to PFOA and PFOS is widespred. More than 95% of the U.S. Population has measurable blood levels of PFOS and PFOA. Babies are born with PFOA in their blood. These chemicals persist in the human body and are eliminated very slowly. 

According to a an Interim Guidance from the CDC, there are many routes to exposure:

• Drinking contaminated water.
• Ingesting food contaminated with PFAS, such as certain types of fish and shellfish.
• Until recently, eating food packaged in materials containing PFAS (e.g., popcorn bags, fast food containers, and pizza boxes).  Using PFAS compounds has been largely phased out of food packaging materials.
• Hand-to-mouth transfer from surfaces treated with PFAS-containing stain protectants, such as carpets and upholstery.
• Individuals can also be exposed by breathing air that contains dust contaminated with PFAS (from soil, carpets, upholstery, clothing, etc.), or from certain fabric sprays containing this substance.
• And finally, workers in industries that manufacture  or use products containing PFAS may be exposed to higher levels than the general population as in the very sad story of “The Devil We Know.”

 Much of what we know about the health impacts of PFOAs if from “The C8 Health Project.” “This was a large epidemiological study conducted because drinking water in six water districts across two states near Parkersburg, West Virginia were contaminated by release of PFOA (also called C8) from the 1950s until 2002 (when the contamination was discovered). These releases migrated and contaminated the air, parts of the Ohio River, and ground water. The study included 69,030 persons >18 years of age. The C8 Science Panel analyzed study data and found ... links as determined by litigation. between elevated PFOA blood levels and high cholesterol (hypercholesteremia), ulcerative colitis, thyroid function, testicular cancer, kidney cancer, preeclampsia, as well as elevated blood pressure during pregnancy. Residents in the area of these releases showed 500% higher PFOA-concentrations in blood compared to a representative U.S. population...” The film “The Devil We Know” can be purchased at this link. 

Over the years I came know that Polytetrafluoroethylene (Teflon) starts to dissociate at about 300 degrees Celsius or about 600 degrees Fahrenheit, releasing PFOA into the air. An empty pan can reach 500 degrees F in less than 2 minutes on a high flame. For almost twenty years nonstick pans made with ceramic coatings, anodized aluminum, silicone that do not contain Teflon have been available, buy those. I did because Teflon never stuck to the pan very well.

Because of the extensive public interest since the film was released, the agency has begun the process of taking action. According to the EPA Press Release: “EPA’s Action Plan identifies both short-term solutions for addressing these chemicals and long-term strategies that will help provide the tools and technologies needed to provide clean and safe drinking water and to address PFAS at the source—even before it gets into the water.” The press release went on to say: “Together, these efforts will help EPA and its partners identify and better understand PFAS contaminants generally, clean up current PFAS contamination, prevent future contamination, and effectively communicate risk with the public. To implement the Action Plan, EPA will continue to work in close coordination with multiple entities, including other federal agencies, states, tribes, local governments, water utilities, industry, and the public.”

Action on PFOA and the other PFAS compounds has momentum. Now is the time to act, not back off and wait. In the interest of full disclosure: 40 years ago I worked in Research and Development at DuPont in the Chemicals and Pigments Division at a New Jersey chemical plant for a couple of years when my husband was in graduate school. I was involved in reducing waste and yield improvement on Pyromellitic dianhydride. My work was entirely unrelated to Teflon or its manufacture or that plant’s specific waste practices, but waste practices in the industry at that time were just entering the age of regulation under RCRA.