A PFAS Hydra - The Crux of Regulating 10,000 Chemicals
I finally had the chance to sit down and watch Dark Waters recently—the movie about perfluorinated or polyfluorinated alkyl substances (PFASs). If you haven’t watched it, you definitely should, even if just to be impressed by Mark Ruffalo. I might be slightly biased when it comes to films with Mark Ruffalo.
It is a great film to watch if you are looking for context on the history of this group of chemicals, and why it was such a significant step for the EPA to set PFAS standards for drinking water. The EPA estimates the rule will reduce PFAS exposure for 100 million people in the U.S. The importance of this cannot be overstated, as any exposure reduction is crucial. Exposure to PFAS chemicals is a serious health concern, linked to conditions such as kidney and testicular cancer, weight gain, raised blood pressure, and low birth weight in babies.
PFAS chemicals are not just a distant concern; they are found nearly everywhere. Studies have found low levels of PFAS in just about everyone’s blood worldwide. These chemicals are not confined to industrial settings; they are also found in products, our homes, our food supply, and our environment. This pervasive presence should serve as a wake-up call, highlighting the urgent need for action.
PFASs are not only everywhere but also hard to remove. This is because their chemical makeup contains a string of fluorine and carbon bonds. The “F-C” bond is how they got their nickname, “forever chemicals.” The F-C bond is the strongest in all organic chemistry, which is useful for developing products that nothing else can get through (e.g., oils, stains, water). However, the F-C bond is so strong that PFAS chemicals never fully break down.
Regulating PFAS will be a chore
Scientists estimate that there are likely over 10,000 PFAS chemicals. Dr. Joseph G. Allen, the professor responsible for coining the term “forever chemicals,” opined yesterday in the Washington Post that this large number of chemicals presents a huge problem to federal science and regulation. “That’s particularly alarming because once scientists and regulators start zeroing in on a toxic chemical, it takes years to develop a rule for it. In the meantime, the industry can swap in a replacement that’s just different enough to escape regulation,” wrote Dr. Allen.
The EPA rule that I mentioned earlier targets only 6 PFAS chemicals. The EPA rule is still a huge triumph and will make people’s lives safer and healthier. But given that industry can turn to another PFAS chemical among the thousands not regulated…, it seems like we could find a more effective way to regulate these toxins. Industry has acknowledged that PFAS chemicals are still used in their products, but which ones are they using and are they dangerous? We don’t know.
This strategy, whereby agencies and their scientists take years to study and then regulate a chemical, only for industry to use a similar chemical that is also toxic, is often referred to as “chemical whack-a-mole.” However, whack-a-mole doesn’t seem quite right to me since that game eventually ends. Dr. Allen’s analogy to the mythical Lernaean Hydra monster seems more accurate - an endless supply of heads no matter how many you nix (even if you’re Hercules).
This strategy has been used for other chemicals aside from PFAS. For example, DDT (the pesticide used in the 1970s was replaced with organophosphate pesticides - both interfere with child brain development. Flame-retardant chemicals known as PBBs, which interfere with embryo development, were replaced with PBDEs, which decrease sperm production and disrupt hormone levels, among other health effects. PBDEs were banned in 2003 and replaced with a chemical known as tris, which causes certain types of cancer.
The hydra isn’t the only problem
The EPA's Office of Chemical Safety and Pollution Prevention (OCSPP) evaluates new and existing chemicals to determine their risks. However, the office is heavily captured by the same industries it regulates and has experienced several scientific integrity issues—many of which were made public by Sharon Lerner's reporting at The Intercept but revealed by several whistleblowers.
The stories describe scientists being asked to sign off on chemical assessments showing that a chemical was safe when the science didn’t show that. Supervisors used incorrect methods to alter results, showing that chemicals were safe when they really weren’t safe. Information about the hazards certain chemicals posed in assessments was deleted without the sign-off from scientists. One whistleblower described a case in which her assessment of a PFAS chemical was altered to downplay the chemical’s risk.
After the whistleblower complaints and reporting, the EPA created two internal science policy advisory councils to oversee OCSPP’s work. One of the new advisory committees reviews scientific and science policy issues related to chemical submissions. The EPA was confident that the two committees would make a difference, but this was not true of everyone. In fact, around this time in 2022, when these committees were formed, I spoke with an anonymous former OCSPP scientist who was not confident in EPA’s ability to overhaul its chemicals division. I distinctly remember them saying that the only solution to making OCSPP function as it should was to burn the program to the ground and rebuild it.
We wait and see if things get better?
Maybe EPA’s newly formed advisory committees and overhaul of its chemical division have helped strengthen scientific integrity within OCSPP. Time will tell.
While we wait for that issue to be properly addressed, we need more folks working on the chemical hydra. Regulating one chemical, or even six of 10,000, isn’t working. Sound off in the comments if you know of good work or ideas on solving this issue. It’s an incredibly important issue that has disproportionate impacts on underserved communities—we really need to figure out a better way to regulate these toxins.
I will end this post by saying that while changes must be made, the EPA’s rule regulating PFAS in drinking water is amazing progress. It will reduce millions of people’s exposure to the chemical and give millions of dollars to states, territories, and local communities to deal with polluted waters. It’s good news that was a long time coming.