April 13, 2011

PFCs – Still An Emerging Contaminant?

Posted on April 13, 2011 by Mary Ryan

I ran across perfluorinated chemicals (PFCs) as a site contaminant of concern for the first time last year when EPA required further assessment for PFCs at a site that was about to be closed out with no further action. I wanted to learn more about them and thought you might too, if this was a new acronym for you as well. PFCs have been used in a wide range of products, including consumer goods like Teflon, Scotchgard and Gore-Tex. PFCs consist of only carbon and fluoride. They are often referred to as “emerging contaminants” by EPA officials (from the National Exposure Research Laboratory and Office of Superfund Remediation and Technology Innovation) and others. Two of the most common PFCs are PFOS (perfluorooctane sulfonate) and PFOA (perfluorooctanoic acid, also known as C8). PFOS is no longer manufactured in the United States and PFOA is the subject of EPA’s 2010/2015 PFOA Environmental Stewardship Program, under which the phase-out of PFOA manufacturing by eight major companies is targeted for 2015.

PFCs have garnered world-wide attention over the last few years because of their prevalence and persistence. According to an expert I consulted, in the last two years there have been more than twenty papers on PFCs published in Environmental Toxicology and Chemistry, the journal of the Society of Environmental Toxicology and Chemistry. One environmental watchdog group suggests PFCs are “destined to supplant DDT, PCBs, dioxin and other chemicals as the most notorious, global chemical contaminants ever produced.” 

While not on the Hazardous Substance List, EPA has been actively dealing with PFCs since 2000, as described in the December 30, 2009 TSCA Action Plan for PFCs. There, EPA reported that while PFCs are found world-wide in the environment, wildlife and humans, significant adverse human health effects have yet to be found, though there is evidence of adverse effects in wildlife and laboratory animals. EPA is concerned about possible future human health effects. Further regulatory action under TSCA is expected in 2012. 

Earlier in 2009, the EPA Office of Water issued Provisional Health Advisories for PFOA and PFOS. EPA’s Office of Solid Waste and Emergency Response then developed toxicity values, which can be used as the basis for cleanup levels and risk-based screening levels in water and other media. As a result, sites where no hazardous substances had been found, or where known hazardous substances were remediated, may now need to be re-evaluated for PFOA and PFOS. Pending or completed property transfers may also be affected. Three states (New JerseyMinnesota and North Carolina) have addressed levels of PFOS/PFOA in drinking water. 

Given the high level of interest in PFCs in the scientific community and the evolving regulation of PFCs, is it time to say PFCs have arrived as an environmental contaminant, though they may still be an emerging issue for environmental lawyers? More importantly, it remains to be seen how wide an impact the growing knowledge and increasing regulation of PFCs will have, at what cost, and where this should rank among priorities for federal and state regulation.

Tags: Hazardous Materials

Hazardous Materials

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