On June 30, 2020, a group of international scientists from academia, regulatory agencies, and civil society organizations published an article in the peer-reviewed journal Environmental Science and Technology Letters presenting a scientific basis for managing all per- and polyfluoroalkyl substances (PFAS) as a single chemical class. The approach the authors present is centered on the “high persistence, accumulation potential, and/or hazards (known and potential) of PFAS studied to date [that] warrant treating all PFAS as a single class.” The article discusses in depth the major PFAS subclasses of perfluoroalkyl acids and perfluoroalkylether acids (termed PFAAs) and their precursors, fluoropolymers and perfluoropolyethers, and other PFAS that are primarily less reactive. Referencing published literature, the article provides background on the wide variety of uses for PFAS, their studied health and environmental hazards, and environmental exposure examined in the light of their persistent, accumulative, and mobile properties.

PFAS manufacturers have recently argued that fluoropolymers should be separated from other PFASs for hazard assessment and regulatory purposes. However, the authors make a point to note that the production of fluoropolymers and perfluoropolyethers has been identified as a significant and sometimes primary source of wider PFAS contamination in the environment and provide further arguments for the inclusion of fluoropolymers in the single class.

The article goes on to review existing frameworks and potential options to manage the risks associated with PFAS, including regulatory and marketplace approaches. Up until now, regulatory approaches have focused on reviewing one PFAS chemical at a time or in some instances subgroups of PFAS. The authors write that while a subgroup-focused approach “allows for extrapolation from well-studied chemicals to those less studied,” this still “systematically ignores the majority of PFAS and underestimates the overall risk, particularly when many of the chemicals are unknown.” Marketplace action is reported to be increasing, with many large retailers and downstream users voluntarily shifting away from using PFAS in their products.

Overall, the authors write that managing the entire PFAS group as a class “reduces the likelihood of replacing well-studied hazardous chemicals with poorly studied but structurally similar PFAS that have the potential to be similarly hazardous.” Compared to being regulated individually, a class-based approach can also “be simpler and less expensive to implement.”

In conclusion and looking towards next steps, the article reiterates that “managing PFAS one by one is neither feasible nor cost-efficient” and that “more comprehensive solutions are needed, given that traditional approaches have failed to control widespread exposures to PFAS and resulted in inadequate public health protection.” Some of the authors’ main recommendations include (i) adopting and further developing the concept of permitting PFAS to only be used when identified as essential according to agreed-upon criteria, (ii) taking a class-based approach to clean-up efforts of contaminated sites so as to remove all PFAS from all media and not just some, and (iii) implementing class-based strategies at the regulatory level to reduce and limit combined exposure to all PFASs and not just to individual chemicals.

Read More

Jim Spencer (June 30, 2020). “Panel of scientists recommends stronger guidelines on PFAS.” Star Tribune

American Chemistry Council (June 30, 2020). “ACC Responds to Misleading PFAS Report.”

Andrew Turley (July 2, 2020). “Precise decision criteria needed for ‘essential’ PFAS use, scientists say.” Chemical Watch


Kwiatkowski, C. et al. (June 30, 2020). “Scientific Basis for Managing PFAS as a Chemical Class.” Environmental Science and Technology Letters