The EPA has confirmed plans to address the proliferation of PFAS substances, a crucial component of its broader PFAS strategic roadmap. The plan seeks to increase protections and limit the use of PFAS in packing, clothing and myriad other consumer and industrial applications. 

Any product that exhibits an inherent environmental exposure risk will require upfront testing before entering the market. The EPA expects that clear requirements and testing will serve as an important starting point to mitigate the expansion of PFAS substances. 

What’s In The PFAS Framework?

A key component of the framework is a new requirement for substance review. Before any PFAS-related substance enters the market, it must be evaluated by the EPA. The framework includes a 5-point risk assessment and any concerns will require the EPA to address risks before the substance is used. 

Manufacturers are constantly formulating new substances of PFAS to avoid local and state regulations on the substances and to own a degree of deniability to the general public. Advocacy groups at the local, state and federal levels have voiced concerns over the use and proliferation of PFAS, pushing manufacturers to circumvent regulations and public outrage with new products. 

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A Focus on PBT Chemicals

Most PFAS are considered “persistent, bioaccumulative and toxic chemicals, or PBT. The framework does allow for exceptional approvals on some PBT PFAS. These compounds are often used in the production of semiconductors and other tech products. In these conditions, exposure to the compound is negligible and the chemicals do not impact consumers. 

Many other consumer-facing and industrial processes will trigger further review by the EPA. Manufacturers will need to supply additional testing and chemical property data. The EPA will require additional testing and analysis of the compound fails to satisfy any of the 5-point risk assessments. 

What Are the Goals of the EPA’s PFAS Framework?

The review process isn’t perfect, but it’s an important step in what has been a long and arduous march toward improved consumer and environmental protections. It’s a key element within the EPA’s approach toward PFAS, which is structured around three core directives. 

  • Research. Invest in research, development, and innovation to increase understanding of PFAS exposures and toxicities, human health and ecological effects, and effective interventions that incorporate the best available science. 
  • Restrict. Pursue a comprehensive approach to proactively prevent PFAS from entering air, land, and water at levels that can adversely impact human health and the environment.
  • Remediate. Broaden and accelerate the cleanup of PFAS contamination to protect human health and ecological systems.

It’s worth noting that the roadmap itself, announced in 2021, is nearing the end of its three-year project timeline. The actions of the EPA right now could indicate an expanded and more active approach to PFAS regulations. The future of this effort is largely dependent on the outcome of the 2024 presidential election, along with the various Congressional races.