The U.S. Environmental Protection Agency held a webinar on August 17, on the “EPA PFAS Strategic Roadmap: Research Tools and Resources.”
Lynn BergesonThe webinar provided a brief overview of EPA’s PFAS Strategic Roadmap and ongoing efforts by EPA’s Office of Research and Development (ORD) to address key per- and polyfluoroalkyl substances (PFAS) research needs for environmental decision-making.
During the webinar, ORD scientists highlighted two recently released data sources: EPA’s Systematic Evidence Map (SEM) for PFAS, which summarizes available toxicity evidence for approximately 150 different PFAS, and EPA’s PFAS Thermal Treatment Database (PFASTT), which contains information on the treatability of PFAS via various thermal processes. EPA will post a recording of the webinar within two weeks.
ORD is conducting research to:
- Develop methods and approaches for measuring PFAS in the environment;
- Advance the science to assess human health and environmental risks from PFAS; and
- Evaluate and develop technologies for reducing PFAS in the environment.
Avanti Shirke, MPH, ORD Center for Public Health and Environmental Assessment (CPHEA), reviewed the SEMs developed by ORD. According to Shirke, ORD uses SEMs for:
- Prioritization and Scoping: Determine the extent to which the evidence supports an assessment and of what type;
- Problem Formulation: Characterize the extent and nature of the evidence and reveal knowledge gaps/research needs; and
- Updating: Rapidly characterize new evidence to update an assessment or decide whether an update is warranted.
Shirke described ORD’s initial effort in 2019, identifying 150 PFAS (PFAS 150) for in vitro toxicity and toxicokinetic assay evaluation, testing a range of PFAS structures, chemistries, and with environmental relevance. The PFAS 150 data are available for download in EPA’s Health Assessment Workspace Collaborative (HAWC). Laura Carlson, Ph.D., CPHEA, demonstrated how to access the PFAS 150 through HAWC.
Phillip Potter, Ph.D., ORD Center for Environmental Solutions and Emergency Response (CESER), reviewed PFASTT. In this case, thermal treatment is defined as any transformative technique in which elevated temperature is the primary reaction driver. Examples include incineration and pyrolysis. According to Potter, PFASTT can be used:
- As a searchable resource to view state of the science;
- To reveal data gaps;
- To inform best practices for full-scale thermal treatment; and
- For state decision-making on regulation.
Potter noted that PFASTT went down on August 16, 2022, and is not yet back online.
ORD’s slides include links to a number of PFAS tools and resources in addition to PFAS 150 and PFASTT. During the question and answer session, ORD declined to answer regulatory questions concerning PFAS.
Alice Gilliland, Ph.D., Acting Director, EPA ORD Center for Environmental Measurement and Modeling, began the webinar by describing EPA’s PFAS Strategic Roadmap, stating that it is focused on three goals: research; restrict; and remediate. While not addressed by Gilliland during the webinar, EPA is working to restrict and remediate PFAS. Most recently, on August 15, 2022, EPA submitted a proposed rule to the Office of Management and Budget (OMB) that would subject PFAS to reporting under Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA) and Section 6607 of the Pollution Prevention Act (PPA) to the list of Lower Thresholds for Chemicals of Special Concern (Chemicals of Special Concern).
Adding PFAS to the Chemicals of Special Concern list would eliminate the use of the de minimis exemption, eliminate the option to use Form A, and will limit the use of range reporting. As reported in our August 16, 2022, blog item, on August 12, 2022, OMB completed its review of a proposed rule that would designate perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS) as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). Such designations would require facilities to report on PFOA and PFOS releases that meet or exceed the reportable quantity.
Commentary
There are many moving parts to the PFAS debate -- evolving science, new detection methodologies, emerging research strategies, regulatory developments, and a growing number of lawsuits. Stakeholders are urged to monitor these developments and understand how these moving parts intersect with each other. The business and commercial imperative is clear -- few industry sectors are untouched by the PFAS debate, and the need to be mindful of where the debate is headed is undeniable.
This report was prepared by Bergeson & Campbell, P.C. (B&C®) is a Washington D.C. law firm providing decades of experience in the manufacture, handling, and transport of conventional, biobased, and nanoscale industrial, agricultural, and specialty chemicals, including product approval and regulation, product defense, and associated business issues. www.lawbc.com
