By Genna Reed, Union of Concerned Scientists
I spent Thursday and Friday of last week at the National Academies of Science Environmental Health Matters Initiatives (EHMI) workshop, “Identifying Opportunities to Understand, Control, and Prevent Exposure to PFAS” which brought together scientists, community members, NGOs, regulators, and industry representatives to think about some of the challenges and potential solutions related to the PFAS contamination issue plaguing our country. You can take a look at the full agenda here. The brand new EHMI was developed to “explore innovative solutions to the nation’s most significant environmental health challenges” with the ultimate goal of protecting public health. As some of the leading researchers on the impacts of PFAS exposure and remediation chatted throughout the workshop, there were some key themes that stood out to me that can translate into strong, science-based policy solutions, some of which are already in the works.
Prevention should be the primary focus
Though it was the last in the string of verbs describing the workshop, prevention is clearly where the focus needs to be as we talk about reducing exposure. Because PFAS are persistent, highly mobile chemicals, they will not be going away anytime soon. Instead, they will continue to move across media, traveling around the world to places you wouldn’t expect to find them, like in the blood of polar bears in the Arctic. The only way to reduce exposure is to turn off the tap of legacy compounds and regrettable substitutions. The National Institute of Environmental Health Science’s (NIEHS) departing head, Linda Birnbaum, said it best near the end of the meeting:“why do we want to make products that never, ever leave our environment?” This sentiment was expressed throughout the meeting by scientists who have worked on (and are still working on) persistent chemicals like PCBs and dioxins.
Carla Ng from the University of Pittsburgh discussed a path forward for prevention, by taking a close look at the non-essential uses of PFAS and moving toward alternatives as soon as possible. For example, there are likely certain uses of PFAS that would be deemed essential, like in life-saving medical device technology. But there are all sorts of products for which the use of PFAS is either non-essential (cosmetics, dental floss, certain water-repellant clothing) or could be substituted with an alternative (fire-fighting foams). We need to do more to prevent these forever chemicals from entering the environment in the first place.
Radical transparency, community inclusion, and equity considerations are essential
The first panel on understanding PFAS exposure brought up a host of uncertainties and gaps and areas of concern that are begging to be studied, including dietary exposure to PFAS and sources in food, indoor sources of PFAS, dermal exposure to PFAS-containing cosmetics, and unidentified PFAS in the blood. Scientists coalesced around the fact that there are still a lot of unknowns because it’s nearly impossible to connect exposure back to certain products. That information is not available to the public. In some cases, manufacturers of certain products might not even know that a process they’re using employs PFAS. We don’t have a comprehensive list of all of the properties that are releasing (or have released) PFAS into the environment. How can we fully understand the scope of the PFAS problem and study the routes of exposure if the companies using this class of chemicals won’t hand over that critical information? Panel members called for radical transparency in the form of disclosure from companies first and foremost, with consumer labeling a secondary priority.
Obviously this is necessary. The chemical industry has a long history of keeping important information from the public, and it needs to stop. Though it was not brought up during this meeting, we all know by now about how 3M and DuPont, the manufacturers of PFOA and PFOS, knew about its toxicity and impacts on human health as early as the 1950s and kept the science hidden from the regulators and the public for decades. Despite this, as recently as this month 3M has denied that these chemicals are hazardous. They are actively lobbying against measures that would finally jumpstart the process to regulate PFAS as hazardous waste and help prioritize cleanups of contaminated sites. Companies need to provide information to scientists so that they can comprehensively study these chemicals, understand exposure pathways and associated health impacts. Likewise, members of the public have the right to know where and how much PFAS is being released into the environment, which the EPA can compel companies to do once listed under the Toxics Release Inventory.
Anthony Spaniola from Oscoda, Michigan was on the first panel, and grounded the event in the experience of those who have faced serious contamination in their neighborhoods. He called on the scientific community to have an ongoing, proactive dialogue with the individuals exposed to these chemicals firsthand, working together to find solutions. Combining local wisdom with scientific expertise is a powerful force that must continue to be used to drive science-based policy changes. And there needs to be more attention given to the entire lifecycle of PFAS, especially the disposal of these chemicals which end up in landfills or at incinerators that are often located in communities of color and low-income communities that are already facing tremendous environmental burdens.
The chemical industry continues to be part of the problem
During the meeting, Linda Birnbaum asked the Fluorocouncil and American Chemistry Council representative, Steve Korzeniowski, for quantitative information about how much PFAS are being produced and where they are. She later expressed disappointment that he failed to provide the data to her. Korzeniowski spent much of his air time sticking close to talking points urging people not to conflate all PFAS into one vilified group, focusing on the PFAS that provide benefits to consumers like medical devices. He claimed that the industry will continue to be cooperative and develop alternative technologies. He lost me at hello.
3M and DuPont unleashed these forever chemicals into the environment, hid the data from us, shirked responsibility for cleaning up the mess, and continue to lobby members of Congress to fend off regulation. Enough irresponsible behavior straight from the disinformation playbook. This is a problem requiring an urgent, multi-stakeholder response, and industry needs to be footing the bill for cleaning up its mess, providing important historical and current PFAS use information to the scientific community and consumers, and paying for no-strings-attached research to develop alternatives.
Government needs to do more
Another thread that ran throughout this meeting is that there are certainly gaps in the knowledge about PFAS (much of which is thanks to lack of cooperation from industry), but at this point, there is enough evidence to warrant government action. Not only is federal regulation necessary, but there needs to be a joint effort across agencies since we know that the routes of exposure, and thus statutory jurisdiction, are complex. Regulation would be a huge opportunity for innovation in a variety of sectors. Government regulation in the face of threats (like the hole in the ozone layer) has spurred innovation in the past and, this time, we need incentives for scientists to develop alternatives to persistent chemicals so that we can leave them in the past.
And low-hanging fruit can and should be addressed first. EPA could act now to finally regulate these chemicals, but so far its action plan has fallen short. Congress is working on final National Defense Authorization Act (NDAA) language now that would, among other things, compel DOD to phase out PFAS-containing firefighting foam within the next few years and EPA to better monitor PFAS, set an enforceable drinking water standard, require reporting of PFAS releases into the environment, and designate it as a hazardous substance so that companies would have to pay to clean it up. We need a strong NDAA to set the bar, and we’ll need continuous coordinated federal efforts to understand, treat, and prevent PFAS exposure for years to come.