Welcome to Spring 2023! Regardless of the temperature, I know spring is close when the male American Goldfinches start their molt from olive green to vibrant yellow. It is a beautiful sight to see and promises warmer days ahead.
Undoubtedly, many have seen something less beautiful these days, such as headlines focusing on PFAS and “Forever Chemicals.” Headlines everywhere use these terms. PFAS is an emerging and developing topic we will discuss for many decades. Articles on this topic began appearing in profusion in March 2023, resulting from a regulatory determination and proposed rule on drinking water and PFAS released by the United States (US) Environmental Protection Agency (EPA).
Because clean drinking water is of paramount importance, these articles have gained widespread attention. Today our column will provide some background on PFAS, including their definition and historical use, the reason for concern, governmental actions, and possible impacts to our industries.
What are Forever Chemicals?
“Forever Chemicals” or PFAS, also known as per- and polyfluoroalklyl substances, are a class of chemicals uniquely resistant to water, grease/oil, and stains. Within this class, you will see the most commonly discussed chemicals abbreviated as PFOA, PFOS, PFBS, GenX and HFPO. In addition to these, there are actually thousands more chemicals within the PFAS family. They may occur as isomers, acids, organic or metal salts, or derivatives.
Why are Forever Chemicals a concern?
The resistance of PFAS to water and oil allows the chemicals to stay intact and makes them resistant to typical chemical cleanup methods, such as hydrolysis, photolysis, microbial degradation and metabolism. PFAS persist for a long time and are found in groundwater, soil, surface water, outdoor air and biosolids. Due to environmental exposure, PFAS are also found in wild animals, domestic animals, root vegetables, humans and animal products, such as eggs, milk, and other dairy.
How has PFAS been used in the United States?
Teflon was the first PFAS discovered in 1938. By the 1940s, PFAS were used in industrial processes, manufactured goods, and the environment. Examples of historical industrial processes which used PFAS are:
- Chrome plating;
- Electronics manufacturing;
- Textile manufacturing;
- Oil recovery;
- Plating processes, such as a wetting agent/fume suppressant;
- Fluoropolymer production processing aids;
- Photographic coatings; and
- Electrochemical fluorination (ECF) and telomerization.
Examples of historical consumer products which used PFAS are:
- Sandwich wrappers;
- Other paper and paperboard food packaging;
- Stain- and water-repellent fabrics;
- Nonstick cookware products;
- Nonstick food processing equipment;
- Cleaning products;
- Certain firefighting foams;
- Certain types of adhesives;
- Carpet cleaners;
- Auto washes; and
What US governmental activities are addressing PFAS?
In the early 2000s, governmental activities for PFAS started to increase. Today, multiple U.S. federal and state agencies are working to address PFAS. As we focus on US EPA activities, we see that they developed and released a PFAS Strategic Roadmap outlining upcoming U.S. EPA activities. U.S. EPA is using authority under seven statutes to regulate PFAS full circle from “cradle to grave”:
- Clean Water Act (CWA);
- Clean Air Act (CAA);
- Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or Superfund);
- Emergency Planning and Community Right-to-Know Act (EPCRA);
- Resource Conservation and Recovery Act (RCRA);
- Safe Drinking Water Act (SDWA); and
- Toxic Substances Control Act (TSCA).
Governmental sources provide publicly available information on regulated PFAS. Here are a few of my preferred data sites:
- National Emissions Inventory;
- Permit Compliance System (PCS) and Integrated Compliance Information System (ICIS);
- Toxics Release Inventory (TRI); and
- Vulnerable Zone Indicator System.
What future changes could impact the plumbing and mechanical industries?
Conversations about PFAS occur regularly during committee meetings of standards development organizations and code development bodies. Topics discussed are:
- What is the prevalence of the use of PFAS in the manufacturing processes of plumbing and mechanical products?
- Do OEM plumbing and mechanical products contribute to the environmental release of PFAS?
- Should new technologies be incorporated into new construction to address PFAS releases and exposures?
- Can new technologies be incorporated into existing construction through the retrofit of existing systems? and
- What standards exist to assess the performance of new technologies?
What can you do?
Right now, it would be best to stay informed. This topic will continue to develop with new research, technologies, regulations, requirements in standards and codes, and, very likely, third-party certification requirements. While I recommend that you personally monitor this emerging topic, you may choose to request updates through your trade association.
Key organizations to monitor are:
- US EPA activities;
- Standards development organizations;
- Code development bodies; and
- State agencies.
There are existing states resources for:
Or, as always, you can simplify your life and call me at Regulosity!
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