DEQ-CFW_00000528

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Comment on "Fluorotechnology
Is Critical to Modern Life: The
FluoroCouncil Counterpoint to
the Madrid Statement"
h ttp: //dx. do i. o rg/ 10.1289/ehp.15102 07
Refers to http://dx.doi.org/10.1289/ehp.1509910
We commend the FluoroCouncil for phasing
out long -chain poly- and perfluoroalkyl sub-
stance (PFAS) chemistry. However, members
of the FluoroCouncil have been producing
long -chain PFASs for decades while in pos-
session of research showing adverse health
effects in humans and animals. This model of
chemical manufacturing needs to change. We
recommend implementing the principles of
green chemistry (Anastas and Warner 1998)
in chemical manufacturing to ensure safer and
sustainable chemical products. The scientific
consensus of the Madrid Statement authors
and signatories is that the use of all PFASs is
unsustainable, and can and should be greatly
reduced and discontinued where feasible.
Short -chain fluorinated alternatives were there-
fore intentionally included in the scope of the
Madrid Statement.
Some of the functionalities provided by
fluorotechnology have become part of mod-
ern life. However, we disagree that PFASs
are critical to modern life. Sustainable and
less hazardous alternatives are available for
many functionalities, and others will be
developed. PFAS-based chemistries are used
in many nonessential applications such as
clothing, sports equipment, food packaging
materials, blooming and dispersion agents,
and stain -repellant treatments. We urge the
FluoroCouncil to provide as much infor-
mation as possible on the PFAS chemis-
tries used in different commercial products
and technologies.
We are aware that short -chain perfluoro-
alkyl acids bioaccumulate less than long -
chain ones. However, some short -chain
PFASs have been linked to adverse biological
effects (Bull et al. 2014), and further sys-
tematic, representative studies on additional
end points are needed. Given the ongoing
release and environmental persistence of
short -chain acids, increasing environmental
and human exposures such as those docu-
mented by Glynn et al. (2012) are expected,
for example, via contaminated drinking water
aquifers (Xiao et al. 2015). Thus, continuous
release of short -chain PFASs can be expected
to lead to poorly reversible internal expo-
sures, regardless of their low bioaccumulation
potential (Scheringer et al. 2014).
A 170
Bowman commented that the Madrid
Statement cannot claim insufficient data on
the hazards and risks of fluorinated alterna-
tives. However, Wang et al. (2015) high-
lighted the specific data gaps that prohibit
conducting hazard and risk assessments for
many fluorinated alternatives. An assess-
ment commissioned by the FluoroCouncil
(ENVIRON International Corporation
2014) also identified many gaps regarding
human health data.
Bowman stated that "decisions on the
societal acceptability of strategic materi-
als such as PFASs cannot be wisely made
on a single attribute such as persistence."
However, persistent chemicals are unsustain-
able in a world with limited resources. We
cannot afford to "lose" portions of resources
(water, soil, or food) because potentially
harmful and persistent chemicals are accu-
mulating over centuries and causing continu-
ous exposure. Because of their persistence,
an enormous inventory of PFASs is being
created: Even if all PFAS production and
uses were to stop immediately, PFASs would
continue to be released for decades during
products' use and disposal life -cycle phases
(Wang et al. 2014a, 2014b). One of the
12 principles of green chemistry is "design
for degradation: chemical products should
be designed so that at the end of their func-
tion they break down into innocuous deg-
radation products and do not persist in the
environment" (Anastas and Warner 1998).
We endorse this principle and urge the
FluoroCouncil to follow it also.
We welcome collaboration with the
FluoroCouncil to establish information -
sharing platforms for PFASs and support
all opportunities for dialogue. We ask the
FluoroCouncil to take leadership and respon-
sibility for the global management of the
PFASs they produce, from manufacturing to
end of life.
The authors declare they have no actual or
potential competing financial interests.
Ian T. Cousins,' Simona A. Balan,z
Martin Scheringer,3.4 Roland Weber,5
Zhanyun Wang,3 Arlene BIum,2,6
Miriam Diamond,? Tony Fletcher,8
Gretta Goldenman,9 Christopher Higgins,10
Avery E. Lindeman,2 Graham Peaslee,f'
Xenia Trier,72 and Pim de V0ogt13
'Stockholm University, Stockholm, Sweden; 2Green
Science Policy Institute, Berkeley, California,
USA; 3ETH Zurich, Zurich, Switzerland; 4Leuphana
University, Luneburg, Germany; 5POPs Environmental
Consulting, Schwabisch GmOnd, Germany; 6University
of California at Berkeley, Berkeley, California, USA;
7University of Toronto, Toronto, Ontario, Canada;
a London School of Hygiene & Tropical Medicine,
London, United Kingdom; 9European Centre on
Sustainable Policies for Human and Environmental
Rights, Brussels, Belgium;10Colorado School of
Mines, Golden, Colorado, USA; "Hope College,
Holland, Michigan, USA;12Technical University of
Denmark, Kongens Lyngby, Denmark;13University of
Amsterdam, Amsterdam, the Netherlands
Address correspondence to S.A. Balan, Green Science
Policy Institute, P.O. Box 5455, Berkeley, CA 94705
USA. E-mail:simona®greensdencepolicyorg
REFERENCES
Anastas PT, Warner JC. 1998. Green Chemistry: Theory and
Practice. New York, NY:Oxford University Press.
Bull S, Burnett K, Vassaux K, Ashdown L, Brown T, Rushton L.
2014. Extensive Literature Search and Provision of
Summaries of Studies Related to the Oral Toxicity of
Perfluoroalkylated Substances (PFASs), Their Precursors
and Potential Replacements in Experimental Animals
and Humans. Area 1: Data on Toxicokinetics (Absorption,
Distribution, Metabolism, Excretion) in in Vitro Studies,
Experimental Animals and Humans. Area 2: Data on
Toxicity in Experimental Animals. Area 3: Data on
Observations in Humans. EFSA Supporting Publication
EN-572. Parma, haly:European Food Safety Authority.
ENVIRON International Corporation. 2014. Assessment of POP
Criteria for Specific Short -Chain Perfluorinated Alkyl
Substances (Prepared for FluoroCouncil, Washington,
DC). Arlington, VA:ENVIRON International Corporation.
Glynn A, Berger U, Bignert A, Ullah S, Aune M, Lignell S, at
al. 2012. Perfluorinated alkyl acids in blood serum from
primiparous women in Sweden: serial sampling dur-
ing pregnancy and nursing, and temporal trends 1996-
2010. Environ Sci Technol 46(16):9071-9079; doi:10.1021/
es301168c.
Scheringer M, Trier X, Cousins IT, de Voogt P, Fletcher T,
Wang Z, at al. 2014. Helsingor Statement on poly- &
perfluorinated alkyl substances (PFASs). Chemosphere
114:337-339; doi:10.1016/j.chemosphere.2014.05.044.
Wang Z, Cousins IT, Scheringer M, Buck RC, Hungerbilhler
K. 2014a. Global emission inventories for C4—C14 per-
fluoroalkyl carboxylic acid (PFCA) homologues from
1951 to 2030, part I: production and emissions from
quantifiable sources. Environ Int 70:62-75; doi:10.1016/j.
envint.2014.04.013.
Wang Z, Cousins IT, Scheringer M, Buck RC, Hungerbiihler
K. 2014b. Global emission inventories for C4-C14 perfluo-
roalkyl carboxylic acid (PFCA) homologues from 1951 to
2030, part II: the remaining pieces of the puzzle. Environ
Int 69:166-176; doi:10.1016fl.envint.2014.04.006.
Wang Z, Cousins IT, Scheringer M, Hungerbuehler K. 2015.
Hazard assessment of fluorinated alternatives to long -
chain perfluoroalkyl acids (PFAAsi and their precursors:
status quo, ongoing challenges and possible solutions.
Environ Int 75:172-179; doi:10.1016/j.envint.2014.11.013.
Xiao F, Simcik MF, Halbach TR, Gulliver JS. 2015.
Perfluorooctane sulfonate (PFOS) and perfluoro-
octanoate (PFOA) in soils and groundwater of a
US metropolitan area: migration and implications for
human exposure. Water Res 72:64-74; doi:10.1016/j.
watres.2014.09.052.
Response to "Comment on
'Fluorotechnology Is Critical to
Modern Life: The FluoroCouncil
Counterpoint to the Madrid
Statement"'
http: //dx. doi. o rg/10.1289/ehp.1510295
Refers to http://dx.dai.org/10.1289/ehp.1509910
The FluoroCouncil's voluntary develop-
ment of alternative chemistries is unprece-
dented and a model for the development
and introduction of more sustainable
VOLUME 1231 NUMBER 7 1 July 2015 • Environmental Health Perspectives
DEQ-CFW 00000528

Correspondence 0
chemistry worldwide. More than a decade
ago, the FluoroCouncil member companies
responded to concerns about long -chain
poly- and perfluoroalkyl substances (PFASs)
by working with regulators to voluntarily
phase out those substances and develop alter-
natives with improved health and environ-
mental profiles. The FluoroCouncil also
works with regulators and other stakehold-
ers to support a global transition away from
long -chain PFASs. This effort stands as a
historic collaboration by government and
industry to foster sustainable development.
The claim that all PFASs are problematic
is simply not supported by the wealth
of data available on both long- and short -
chain PFASs. Because of the concerns raised
in regard to long -chain PFASs, the U.S.
Environmental Protection Agency (EPA) has
held the fluorotechnology industry to high
standards and increased data requirements
to ensure the alternatives are well studied
and safer than the substances being replaced.
Consequently, short -chain PFASs are some
of the most robustly studied new chemicals
introduced to the market, having undergone
years of toxicity and environmental testing
at the request of regulators. Industry con-
tinues this collaboration with regulators,
developing additional data on the alternatives
and working to make those data publicly
available, including on the FluoroCouncil
website (http://www.fluorocouncii.org/
Resources/Research). Based on this robust
body of data, regulators globally have deter-
mined the alternatives are safe for their
intended use. The "sustainable and less haz-
ardous alternatives" sought by the Madrid
Statement authors already exist in the form of
short -chain PFASs.
We continue to be perplexed by asser-
tions from the authors of the Madrid
Statement that short -chain PFASs present
hazards comparable to those of long -chain
PFASs, citing publications such as Bull et al.
(2014) and Wang et al. (2015). These publi-
cations suffer from important data gaps, such
as the failure to cite key published articles
on the toxicity of short -chain PFASs (e.g.,
Klaunig et al. [20151, which presents ani-
mal data indicating perfluorohexanoic acid is
not carcinogenic). Furthermore, these pub-
lications actually acknowledge or demon-
strate that many of the leading short -chain
PFASs are less bioaccumulative and less toxic
than the long -chain PFASs with which they
have been compared, based on the avail-
able data taken as a whole. This conclusion,
which is well accepted by regulatory agencies
such as the EPA, compels a different policy
outcome than the Madrid Statement sug-
gests. The first priority for risk management
should be phase -out of the long -chain PFASs.
Attempting to broaden that phase -out to
effective alternatives that are less hazardous
can only create a technological impasse that
supports the retention of long -chain PFASs
in the marketplace.
The authors of the Madrid Statement also
contend that PFASs are not critical to mod-
ern life. The importance of PFAS chemis-
try, however, was long ago determined by the
market. Industries relying on PFASs evaluated
fluorinated and nonfluorinated alternatives,
as well as alternative technology, and decided
on the products that met their specifications
and performance needs. Some decisions
involved continuing to use PFASs because
they meet performance needs that nonflu-
orinated alternatives cannot. For example,
first -responder protective gear is treated with
fluorinated products to help maintain per-
formance in fires; firefighting foam produced
with fluorinated surfactants provides shorter
extinguishment times and critical burnback
resistance when fighting flammable liquid
fires; and hospital gowns, drapes, and divider
curtains rely on fluorinated polymers to pro-
vide protective barriers against transmission
of diseases. Because the short -chain PFASs
have been reviewed and approved by regula-
tory authorities globally, all applications rely-
ing on these substances can be used without
presenting a significant risk.
The largest use of short -chain PFASs is
for polymeric products. These products —
like other polymers —are quite stable under
environmental conditions. The resilience
of short -chain PFASs is directly connected
to its performance, providing long-lasting,
durable properties. First responders, medical
personnel, and patients would certainly not
want the properties in safety gear or medi-
cal garments to quickly become ineffective.
Even when the short -chain PFASs, which
do not present a significant risk, are used
in what some people may characterize as
"nonessential applications," such as clothing
and furniture, these substances significantly
extend the effective lifetime of those prod-
ucts, meaning less waste, infrequent wash-
ings, and economic savings. These benefits of
Environmental Health Perspectives • VOLUME 123 I NUMBER 7 I July 2015
short -chain PFASs can be further enhanced
by reducing emissions through the adoption
of best environmental practices, which the
FluoroCouncil has identified and is encour-
aging in the supply chain.
The FluoroCouncil members remain
committed to science -based stewardship
activities, including continually enhancing
the sustainability of their chemistries and
products by improving their environmen-
tal, health, safety, and performance profiles.
We are open to working collaboratively and
constructively with stakeholders on 1) strate-
gies to complete the global transition away
from long -chain PFASs, 2) identification of
issues that warrant further data development
and risk assessment, 3) actions that can foster
additional stewardship activities within the
supply chain, and 4) best methods for trans-
parently sharing information relevant to the
health and environmental impact of PFASs.
The author is employed by the American
Chemistry Council and manages the
FluoroCouncil, a global organization represent-
ing the world' leading fluorotechnology com-
panies. The members of the FluoroCouncil are
Arehroma Management LLC, Arkema France,
Asahi Glass Co., Ltd., Daikin Industries, Ltd.,
Solvay Specialty Polymers, and The Chemours
Company LLC.
Jessica S. Bowman
FluoroCouncil
Address correspondence to J..5. Bowman, FluoroCouncil,
7002ndSt., NE, Washington, DC20002 USA. E-mail'
jessica�[e-mail]
REFERENCES
Bull S, Burnett K, Vassaux K, Ashdown L, Brown T, Rushton L
2014. Extensive Literature Search and Provision of
Summaries of Studies Related to the Oral Toxicity of
Perfluoroalkylated Substances (PFASs), Their Precursors
and Potential Replacements in Experimental Animals
and Humans. Area 1: Data on Toxicokinetics (Absorption,
Distribution, Metabolism, Excretion) in in Vitro Studies,
Experimental Animals and Humans. Area 2: Data on
Toxicity in Experimental Animals. Area 3: Data on
Observations in Humans. EFSA Supporting Publication
EN-572. Parma, Italy:European Food Safety Authority.
Klaunig JE, Shinohara M, Iwai H, Chengelis CP, Kirkpatrick JB,
Wang Z, et al. 2015. Evaluation of the chronic toxicity and
carcinogenicity of perfluorohexanoic acid (PFHxA) in
Sprague-Dawley rats. Toxicol Pathol 43(2):209-220; doi:
10.1177/0192623314530532.
Wang Z, Cousins IT, Scheringer M, Hungerbuehler K. 2015.
Hazard assessment of fluorinated alternatives to long -
chain perfluoroalkyl acids (PFAAs) and their precursors:
status quo, ongoing challenges and possible solutions.
Environ Int 75:172-179; doi:10.1016/j.envint.2014.11.013.
A 171
DEQ-CFW 00000529