The Evolution of PFAS, Phasing Out Legacy Compounds
3M and other manufactures voluntarily began to phase out PFOS in 2002 after the EPA expressed concerns associates with this legacy compound and adverse environmental and health effects in humans. In 2006, the EPA launched the PFOA Stewardship Program and encouraged manufactures to stop production of other long-chained PFAS compounds. By 2015, eight manufactures pleaded to discontinue production and importing of PFAO and related chemicals1.
As information continued to present itself and awareness of the harmful effect of PFAS compounds emerge, PFOS, its salts, and PFOSF were added in the Annex B of the Stockholm Convention on Persistent Organic Pollutants (POPs). By May of 2019, more than 180 countries also agreed to ban production and use of PFOA in fire fighting foams and have instituted tight restrictions of the use of PFOS2.
There are still many more PFAS compounds available without adequate regulatory oversight. Regulations will continue to be enforced as the EPA and other governing bodies continue to understand these compounds and their harmful effects.
Governmental initiatives to understand PFAS exposure
Toxics Release Inventory (TRI)
The TRI is requiring manufactures, processors, and users of PFAS compounds to report release and other waste management information to the EPA. 176 PFAS compounds have been added to the TRI under section 7321 of the National Defense Authorization Act (NDAA) covered by section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA) in 20224.
PFAS Strategic Road Map3
The EPA has committed to an action plan from 2021 – 2024 where they have set timelines by which they plan to take specific action. These plans will:
- Consider the lifecycle of PFAS
- Work to get upstream of the problem
- Ensure science-based decision making
- Implementing bolder polices to safeguard public health
- Protection of the environment and prioritize protection of disadvantaged communities
- Hold polluters accountable
Toxic Substance Control Act (TSCA)
Under the TSCA section 8 rule, manufactures must identify any PFAS used since January 1, 2011, and are prohibited from manufacturing, processing, or importing products containing long-chain PFAS moving forward5,6. They must report on the following:
- Byproducts from the manufacturing process
- Category of use for these compounds
- Production volumes
- Disposal information
- Reports of any worker's exposure
- Any information concerning environmental and human health effects
National PFAS Testing Strategy7
Industries who have used or manufactured PFAS compounds are required to perform testing using its TSCA toxics section 4 authority. Information gathered will help the EPA to evaluate toxicity and risk associated with future regulations, monitoring, and research of this large class of chemicals.
 SBAR Panel: TSCA Section 8(a)(7) Rule: Reporting and Recordkeeping Requirements for Perfluoroalkyl and Polyfluoroalkyl Substances: What is the Implication of the Proposed Rulemaking on Small Entities?
Link to important government websites
- PFAS Clinical Guidelines
- How Can I be Exposed?
- Per- and Polyfluoroalkyl Substances (PFSA) and Your Health
- Per- and Polyfluorinated Substances (PFAS) Factsheet
- National Report on Human Exposure to Environmental Chemicals