Per- and polyfluoroalkyl substances, often referred to as PFAS or Fluorotechnology, are a diverse group of chemistries characterized by the strong bond between fluorine and carbon. Because of this strong bond, PFAS provide products with strength, durability, stability, and resilience. These properties are critical to the reliable and safe function of a broad range of products that are important for industry and consumers, such as the cell phones, tablets and telecommunications systems we use every day to connect with our friends and family; semiconductors that run our modern, high-tech economy; the aircraft that power the U.S. military; solar panels, turbines and batteries critical to alternative energy development; and medical devices and life-saving drugs that help keep us healthy. PFAS are vital to enabling our lives in the 21st century.
“Forever Chemicals” is a pejorative term used widely among the media and advocacy groups as shorthand for PFAS. Activists coined the term by framing PFAS’ primary benefits of strengthened durability and functionality as a liability, claiming that products with even trace amounts of PFAS will not break down over time. However, research by the Environmental Protection Agency (EPA) and the New York Department of Environmental Conservation found that PFAS chemistries can be destroyed through proper waste management practices, which would allow potential end-of-life issues to be managed.
PFAS have been subject to rigorous review by regulators before being introduced into commerce, and federal and state agencies continue ongoing review of products utilizing these chemistries. Furthermore, the use of PFAS in commercial products is supported by a robust body of extensive scientific health and safety data and research.
PFAS have been introduced into the environment through various mediums, such as through the use of firefighting foams containing PFAS and improper disposal of materials. In their efforts to protect human health and the environment, the manufacturers of PFAS chemistries have developed numerous practices and technologies that minimize environmental emissions, demonstrating their commitment to the responsible production, use, and management of PFAS. Our members also support limitations on the use of firefighting foams containing PFAS for training and testing purposes, while protecting their use for high hazard fires where lives and property are on the line.
Multiple major manufacturers voluntarily joined the EPA’s PFOA Stewardship Program, committing to cease the manufacture and use of PFOA-related chemicals by 2015. They invested more than $700 million in research and development and also agreed that new PFAS chemistries would undergo enhanced regulatory review before being permitted on the market. PFOS manufacturing was voluntarily ceased in the United States in 2002.
Alternatives to PFOS and PFOA have been thoroughly reviewed by regulators prior to introduction into commerce, are subject to ongoing review, and are supported by a robust body of health and safety data. PFAS chemistries are being regulated at the state and federal levels, including through the actions described in EPA’s PFAS Strategic Roadmap.
The industry is dedicated to the responsible production, use, and management of PFAS chemistries in a manner that protects public health and our environment. The manufacturers of PFAS chemistries are employing practices and technologies to minimize environmental emissions every day.
A peer-reviewed report by a panel of international experts reviewed hundreds of pages of scientific material and held a series of discussions on regulation and management of PFAS. Key findings from the panel included the following:
- Most experts agreed that all PFAS should not be grouped together for risk assessment purposes.
- Persistence alone is not sufficient for grouping PFAS for the purposes of assessing human health risk.
- Most panelists agreed that it is inappropriate to assume equal toxicity/potency across the diverse class of PFAS.
“It’s clear that for a chemical class as diverse as PFAS, a scientifically rigorous approach to risk assessment is needed. We need to acknowledge that ‘risk assessment’ is not a one-size fits all tool and the context matters, and that effective communication of uncertainties and data limitations is required.” said Dr. Janet Anderson, primary author of the academic report.
All PFAS are not the same, and it is not scientifically accurate or appropriate to consider them all a safety risk. Individual chemistries have their own unique properties and uses, as well as environmental and health profiles. Individual PFAS profiles vary significantly across the broad family of chemistries. Some PFAS are extremely large polymers, while others are small molecules that may move more easily through the environment. Some PFAS are solids (e.g., fluoropolymers), some are liquids (e.g., fluorotelomer alcohols), and some are gases (e.g., hydrofluorocarbon refrigerants). The fundamental physical, chemical, and biological properties of solids, liquids, and gases are clearly different from one another and demonstrate how a simple grouping approach to risk would be inadequate.
Furthermore, there is increased recognition by scientists and policymakers that you cannot group all PFAS chemistries together for the purposes of regulation (Read more here).
The US EPA’s PFAS Strategic Roadmap and National PFAS Testing Strategy recognize distinctions within the broad class of PFAS and describe actions the agency will take to gather information on sub-categories within the broader class.
PFAS in commerce today have been subject to review by regulators prior to introduction into commerce, and they are subject to ongoing review. In addition, many products that include fluoropolymers, like medical devices and food contact materials, have been approved (and are the subject of ongoing safety review) by the U.S. Food and Drug Administration. PFAS in commerce are supported by a robust body of rigorous scientific health and safety data. Furthermore, research by the Environmental Protection Agency and by the New York Department of Environmental Conservation also found that PFAS chemistries can be destroyed through proper waste management practices, so potential end of life issues can also be managed.
ACC has worked with regulators and lawmakers at the federal and state levels on a host of initiatives to address key issues of concern while continuing to allow for the important uses and benefits of PFAS chemistries.
PFOA and PFOS – the two chemistries the EPA has proposed to designate as hazardous chemicals - have been voluntarily phased out of production and use by leading manufacturers in the chemical industry.
ACC member companies are dedicated to the responsible production, use, and management of PFAS chemistries in a manner that protects public health and our environment. The manufacturers of PFAS chemistries are employing practices and technologies to minimize environmental emissions every day.
Multiple major manufacturers voluntarily joined the EPA’s PFOA Stewardship Program, committing to cease the manufacture and use of PFOA-related chemicals by 2015. They invested more than $700 million in research and development and also agreed that new PFAS chemistries would undergo enhanced regulatory review before being permitted on the market. PFOS manufacturing was voluntarily ceased in the United States in 2002.
Alternatives to PFOS and PFOA have been thoroughly reviewed by regulators prior to introduction into commerce, are subject to ongoing review, and are supported by a robust body of health and safety data. PFAS chemistries are being regulated at the state and federal levels, including through the actions described in EPA’s PFAS Strategic Roadmap.
Industry has also conducted and published several peer-reviewed research initiatives around PFAS chemistries, including two published in Integrated Environmental Assessment and Management, one of which demonstrates that 96 percent of commercially available fluoropolymers meet internationally accepted criteria for designation as Polymers of Low Concern, and another providing categorization of PFAS using fundamental classification criteria based on composition and structure that can be used to identify appropriate groups of PFAS substances for risk assessment.
PFAS are vital to enabling our lives in the 21st century and are critical to the reliable and safe function of a broad range of products that are important for industry and consumers, such as cell phones, semiconductors, aircraft, solar panels, electric batteries, medical devices, and life-saving drugs.
All PFAS are not the same, and it is not scientifically accurate or appropriate to consider them all a safety risk. Individual chemistries have their own unique properties and uses, as well as environmental and health profiles.
PFAS are important to our economy and are critical to our nation’s supply chain resiliency. Essential U.S. industries such as transportation, healthcare technology, telecommunications, semiconductors, aerospace, construction, renewable energy, and many more rely on PFAS to create and innovate new products. Thus, overly broad regulation of ALL PFAS will likely cost jobs and harm economic growth, in addition to hampering the ability of businesses and consumers to access the products they need.
Although the grouping of some substances within the class based on similar physical, chemical, and biological properties may be possible – a proposal to regulate all PFAS as a single class is neither scientifically accurate nor appropriate. Given the widespread usage of PFAS in industries like automotive, aerospace, healthcare, pharmaceuticals, and clean energy to name a few, overreaching regulation has the potential to negatively impact the lives of all Americans.
PFAS plays a critical role in enabling technologies critical to America’s economy, growth, and national defense. For example, PFAS products play an important role in the manufacturing of semiconductors. It enables the ultra-pure environment necessary for microchip manufacturing, corrosion resistance for production safety, plasma machinery, cleaning fluids, and wetting surfactants for chemical etchants.
Beyond semiconductors, high-dielectric fluoropolymers enable the transmission of high-frequency signals on which most modern electronics are based. They improve insulation, weatherability, transparency, and water resistance for many key electronic products. It also helps make touch screens smooth and smudge resistant. Electronic products and applications that use PFAS include:
- Hard Disk Drives
- Cell Phones
- Wireless Devices and Base Stations
- Printed Circuit Boards
- Data Centers for Cloud Computing
- Optical Fiber
- Wireless Communication Networks
- Wifi Antennae
Given how important PFAS is in enabling technology, overly broad regulation of all PFAS will slow technical innovation for products consumers and businesses need and will likely harm American competitiveness.
