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      Fluorotechnology Is Critical to Modern Life: The FluoroCouncil Counterpoint to the Madrid Statement

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      Environmental Health Perspectives
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          Abstract

          The Madrid Statement (Blum et al. 2015) is a listing of policy recommendations that its authors would apply to a broad universe of poly- and perfluoroalkyl substances (PFASs). The FluoroCouncil could support many of these policy recommendations if they were limited to long-chain PFASs. However, the application of these recommendations to a broad universe of PFASs simply cannot be supported. The core weakness of the document is the absence of a compelling rationale for the sweeping scope of those recommendations. Specifically, the Madrid Statement fails as a policy statement in the following areas: It does not acknowledge the fact that fluorotechnology is essential technology for many aspects of modern life, a critical consideration for adoption of any social policy on PFASs. It ignores a large body of scientific information demonstrating important differences between the health and environmental impacts of long-chain and short-chain PFASs. The U.S. Environmental Protection Agency (EPA) and other regulators have approved numerous short-chain alternatives to replace long-chain PFASs. Data in non-human primates indicate shorter-chain perfluoroalkyl carboxylic acids (PFCAs) are less toxic than long-chain PFCAs and have substantially shorter half-lives than perfluorooctanoic acid (PFOA) in particular (U.S. EPA 2015a). It does not recognize the substantial and continuing efforts by industry and governments to replace long-chain substances with alternatives that limit environmental impacts while continuing to provide the unique benefits of PFAS chemistry. These efforts continue, but more work is needed by all parties to complete this transition. In our daily life we rely on fluorotechnology, mostly without noticing, because it uniquely enhances the functionality and durability of things we take for granted, such as airplanes, automobiles, and cell phones. PFASs are designed for specific end uses, and therefore all PFAS chemistry is not the same. In fact, the term “PFAS” describes a large class of chemistries. Although FluoroCouncil member companies do not participate in all these chemistries, we have expertise in two types of chemistries that are important to everyday life: fluoropolymers and fluorotelomers. Fluoropolymers have unmatched thermal and chemical stability, providing strength, resilience, and durability for the reliable function of a variety of products and industries. Chemical and pharmaceutical manufacturers rely on this technology in linings for pipes, valves, and tanks to allow safe and clean production of products we use and consume every day. Aircraft, trucks, buses, and cars utilize high-reliability, durable, lightweight tubing and hoses made from fluoropolymers that reduce overall weight and prevent evaporation of fuel vapors, reducing greenhouse gas emissions and increasing fuel efficiency. In addition, fluoropolymers exhibit unique dielectric properties that enable high-speed data transfer for wireless communications in smart phones and other devices. Fluorotelomer-based polymers provide protective surface finishes for textiles such as surgical gowns and drapes that shield against fluid-borne pathogens, protecting patients and health care workers. These products are also used on uniforms to protect chemical workers, military personnel, and firefighters, as well as on outerwear and gear for outdoor enthusiasts, so that all can return home safely. The unique property of water and oil repellency is also utilized in specialized paper and paperboard applications to prevent burns from hot oil in food preparation and to protect food from spoilage. One key use for fluorotelomer-based surfactants is in firefighting foams. These foams extinguish aircraft and oilfield fires faster and provide more protection from reignition than any other medium, saving lives of first responders, military personnel, and others while also protecting property. More information on the uses and benefits of fluorotechnology is available on the FluoroCouncil website (http://www.fluorocouncil.org). Given this range of important societal benefits offered by fluorotechnology, policy measures on PFASs need to be strongly supported by rigorous risk assessment based on all relevant data. In response to public concerns that arose over PFOA and perfluorooctanesulfonic acid (PFOS) more than a decade ago, the FluoroCouncil member companies developed new products, including PFASs based on short chains, which provide comparable properties and benefits to long-chain products, often at similar concentrations, with improved health and environmental profiles. For the past several years, FluoroCouncil member companies have engaged in an ambitious program to develop robust scientific data on these alternative products, the raw materials used to produce them, and their degradation products. Although a broad scientific discussion continues regarding how much science is needed to assess these short-chain products, significant toxicity and environmental data have been provided to regulators globally for systematic chemical review processes. Some of these data have been published in the scientific literature. We would welcome the opportunity to collaborate with the broader community to establish a publicly accessible website housing the available scientific literature references on short-chain PFASs. Our efforts in international fora to create a public reference database for this literature have not yet been successful. However, these products have undergone rigorous review in the registration processes of multiple government agencies and are approved for use. Any claim that there are minimal data publicly available on the hazards and risks of these substances is simply incorrect. This robust set of published data as well as data submitted to regulatory authorities support the conclusion that the short-chain PFASs studied to date are not expected to harm human health or the environment. Although the structures of short-chain PFASs may be similar to their long-chain equivalents, data show the short-chain chemistry in general is very different from the long-chain chemistry. For example, short-chain substances are eliminated more rapidly from the body and are less toxic than long-chain substances (Borg et al. 2013; ENVIRON International Corp. 2014; Gannon et al. 2011; Han et al. 2012; Iwai and Hoberman 2014; Martin et al. 2003a, 2003b; Russell et al. 2013). Any assessment of the alternatives to long-chain PFASs must be based on all the relevant factors that have historically guided risk assessment, including the cornerstone considerations of a substance’s hazard and exposure potential. Some critiques of PFASs have relied solely on the fact that these substances are persistent in the environment, a feature that is often closely related to their technological strengths as durable materials. Decisions on the societal acceptability of strategic materials such as PFASs cannot be wisely made on a single attribute such as persistence. If the Madrid Statement had been directed at long-chain PFASs rather than the larger universe of substances it addresses, the FluoroCouncil would have been supportive of many of the policy measures described. Nearly a decade ago, in response to questions about the presence of long-chain PFCAs and their precursors in the environment and in living systems, FluoroCouncil members were among the industry leaders that took action. In 2006 the FluoroCouncil member companies voluntarily committed to a global phaseout of long-chain products and related plant emissions by the end of 2015. This program, known as the U.S. EPA 2010/2015 PFOA Stewardship Program, has resulted in dramatic reductions in environmental emissions from manufacturing and products, concurrent with development and introduction of short-chain alternatives (U.S. EPA 2015b). A similar program was successfully implemented in cooperation with Environment Canada and Health Canada (Environment Canada 2013). Demonstrable success of these programs has been shown in the reduction of measurable levels of long-chain PFCAs in the environment and in living systems (Centers for Disease Control and Prevention 2014; Health Canada 2013). This was achieved well ahead of regulation. The global elimination of long-chain PFASs should be a common goal shared by the FluoroCouncil members, governments, and a wide range of other stakeholders. The FluoroCouncil has strongly advocated for science-based regulation of long-chain PFASs. To truly address these priority chemicals, it is critical that regulatory authorities and other stakeholders focus on eliminating the production and use of products and articles made from or containing long-chain PFASs. Completing that transition should be the centerpiece of policy on PFASs. The members of the FluoroCouncil have engaged in stewardship activities for several years and recognize the value of continually enhancing their chemistries and products while being mindful of the environment, health, and safety. We remain ready to engage with governments and other stakeholders in refining our approach. We believe there may be opportunities for constructive dialogue in the following areas: Strategies to complete the transition away from long-chain PFASs, a clear area of common ground. Identification of areas that warrant further information development and risk assessment. Actions that can foster additional stewardship activities within the supply chain, such as the guidance document on best environmental practices in textile manufacturing recently issued by the FluoroCouncil (FluoroCouncil 2014). Best methods for sharing with all stakeholders, including the scientific community, information on PFASs that is relevant to the health and environmental impact of fluorotechnology. In pursuing these or any other topics of mutual interest, it will be important that all stakeholders recognize that policy on PFASs must necessarily consider the importance of fluorotechnology in many areas of society. Any policy discussion should be based on well-established risk assessment principles that weigh the hazard and exposure potential of specific substances and should include the implementation of best practices to reduce the potential for exposure while preserving the essential societal benefits of fluorotechnology.

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          Most cited references15

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          The Madrid Statement on Poly- and Perfluoroalkyl Substances (PFASs)

          As scientists and other professionals from a variety of disciplines, we are concerned about the production and release into the environment of an increasing number of poly- and perfluoroalkyl substances (PFASs) for the following reasons: PFASs are man-made and found everywhere. PFASs are highly persistent, as they contain perfluorinated chains that only degrade very slowly, if at all, under environmental conditions. It is documented that some polyfluorinated chemicals break down to form perfluorinated ones (D’Eon and Mabury 2007). PFASs are found in the indoor and outdoor environments, wildlife, and human tissue and bodily fluids all over the globe. They are emitted via industrial processes and military and firefighting operations (Darwin 2011; Fire Fighting Foam Coalition 2014), and they migrate out of consumer products into air (Shoeib et al. 2011), household dust (Björklund et al. 2009), food (Begley et al. 2008; Tittlemier et al. 2007; Trier et al. 2011), soil (Sepulvado et al. 2011; Strynar et al. 2012), ground and surface water, and make their way into drinking water (Eschauzier et al. 2012; Rahman et al. 2014). In animal studies, some long-chain PFASs have been found to cause liver toxicity, disruption of lipid metabolism and the immune and endocrine systems, adverse neurobehavioral effects, neonatal toxicity and death, and tumors in multiple organ systems (Lau et al. 2007; Post et al. 2012). In the growing body of epidemiological evidence, some of these effects are supported by significant or suggestive associations between specific long-chain PFASs and adverse outcomes, including associations with testicular and kidney cancers (Barry et al. 2013; Benbrahim-Tallaa et al. 2014), liver malfunction (Gallo et al. 2012), hypothyroidism (Lopez-Espinosa et al. 2012), high cholesterol (Fitz-Simon et al. 2013; Nelson et al. 2009), ulcerative colitis (Steenland et al. 2013), lower birth weight and size (Fei et al. 2007), obesity (Halldorsson et al. 2012), decreased immune response to vaccines (Grandjean et al. 2012), and reduced hormone levels and delayed puberty (Lopez-Espinosa et al. 2011). Due to their high persistence, global distribution, bioaccumulation potential, and toxicity, some PFASs have been listed under the Stockholm Convention (United Nations Environment Programme 2009) as persistent organic pollutants (POPs). As documented in the Helsingør Statement (Scheringer et al. 2014), Although some of the long-chain PFASs are being regulated or phased out, the most common replacements are short-chain PFASs with similar structures, or compounds with fluorinated segments joined by ether linkages. While some shorter-chain fluorinated alternatives seem to be less bioaccumulative, they are still as environmentally persistent as long-chain substances or have persistent degradation products. Thus, a switch to short-chain and other fluorinated alternatives may not reduce the amounts of PFASs in the environment. In addition, because some of the shorter-chain PFASs are less effective, larger quantities may be needed to provide the same performance. While many fluorinated alternatives are being marketed, little information is publicly available on their chemical structures, properties, uses, and toxicological profiles. Increasing use of fluorinated alternatives will lead to increasing levels of stable perfluorinated degradation products in the environment, and possibly also in biota and humans. This would increase the risks of adverse effects on human health and the environment. Initial efforts to estimate overall emissions of PFASs into the environment have been limited due to uncertainties related to product formulations, quantities of production, production locations, efficiency of emission controls, and long-term trends in production history (Wang et al. 2014). The technical capacity to destroy PFASs is currently insufficient in many parts of the world. Global action through the Montreal Protocol (United Nations Environment Programme 2012) successfully reduced the use of the highly persistent ozone-depleting chlorofluorocarbons (CFCs), thus allowing for the recovery of the ozone layer. However, many of the organofluorine replacements for CFCs are still of concern due to their high global warming potential. It is essential to learn from such past efforts and take measures at the international level to reduce the use of PFASs in products and prevent their replacement with fluorinated alternatives in order to avoid long-term harm to human health and the environment. For these reasons, we call on the international community to cooperate in limiting the production and use of PFASs and in developing safer nonfluorinated alternatives. We therefore urge scientists, governments, chemical and product manufacturers, purchasing organizations, retailers, and consumers to take the following actions: Scientists: Assemble, in collaboration with industry and governments, a global inventory of all PFASs in use or in the environment, including precursors and degradation products, and their functionality, properties, and toxicology. Develop analytical methods for the identification and quantification of additional families of PFASs, including fluorinated alternatives. Continue monitoring for legacy PFASs in different matrices and for environmental reservoirs of PFASs. Continue investigating the mechanisms of toxicity and exposure (e.g., sources, fate, transport, and bioaccumulation of PFASs), and improve methods for testing the safety of alternatives. Bring research results to the attention of policy makers, industry, the media, and the public. Governments: Enact legislation to require only essential uses of PFASs, and enforce labeling to indicate uses. Require manufacturers of PFASs to conduct more extensive toxicological testing, make chemical structures public, provide validated analytical methods for detection of PFASs, and assume extended producer responsibility and implement safe disposal of products and stockpiles containing PFASs. Work with industry to develop public registries of products containing PFASs. Make public annual statistical data on production, imports, and exports of PFASs. Whenever possible, avoid products containing, or manufactured using, PFASs in government procurement. In collaboration with industry, ensure that an infrastructure is in place to safely transport, dispose of, and destroy PFASs and PFAS-containing products, and enforce these measures. Chemical manufacturers: Make data on PFASs publicly available, including chemical structures, properties, and toxicology. Provide scientists with standard samples of PFASs, including precursors and degradation products, to enable environmental monitoring of PFASs. Work with scientists and governments to develop safe disposal methods for PFASs. Provide the supply chain with documentation on PFAS content and safe disposal guidelines. Develop nonfluorinated alternatives that are neither persistent nor toxic. Product manufacturers: Stop using PFASs where they are not essential or when safer alternatives exist. Develop inexpensive and sensitive PFAS quantification methods for compliance testing. Label products containing PFASs, including chemical identity and safe disposal guidelines. Invest in the development and use of nonfluorinated alternatives. Purchasing organizations, retailers, and individual consumers: Whenever possible, avoid products containing, or manufactured using, PFASs. These include many products that are stain-resistant, waterproof, or nonstick. Question the use of such fluorinated “performance” chemicals added to consumer products.
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            Renal elimination of perfluorocarboxylates (PFCAs).

            Sex-, species-, and chain length-dependent renal elimination is the hallmark of mammalian elimination of perfluorocarboxylates (PFCAs) and has been extensively studied for almost 30 years. In this review, toxicokinetic data of PFCAs (chain lengths ranging from 4 to 10) in different species are compared with an emphasis on their relevance to renal elimination. PFCAs vary in their affinities to bind to serum albumins in plasma, which is an important factor in determining the renal clearance of PFCAs. PFCA-albumin binding has been well characterized and is summarized in this review. The mechanism of the sex-, species-, and chain length-dependent renal PFCA elimination is a research area that has gained continuous interest since the beginning of toxicological studies of PFCAs. It is now recognized that organic anion transport proteins play a key role in PFCA renal tubular reabsorption, a process that is sex-, species-, and chain length-dependent. Recent studies on the identification of PFCA renal transport proteins and characterization of their transport kinetics have greatly improved our understanding of the PFCA renal transport mechanism at the molecular level. A mathematical representation of this renal tubular reabsorption mechanism has been incorporated in physiologically based pharmacokinetic (PBPK) modeling of perfluorooctanoate (PFOA). Improvement of PBPK models in the future will require more accurate and quantitative characterization of renal transport pathways of PFCAs. To that end, a basolateral membrane efflux pathway for the reabsorption of PFCAs in the kidney is discussed in this review, which could provide a future research direction toward a better understanding of the mechanisms of PFCA renal elimination.
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              Cumulative health risk assessment of 17 perfluoroalkylated and polyfluoroalkylated substances (PFASs) in the Swedish population.

              Humans are simultaneously exposed to a multitude of chemicals. Human health risk assessment of chemicals is, however, normally performed on single substances, which may underestimate the total risk, thus bringing a need for reliable methods to assess the risk of combined exposure to multiple chemicals. Per- and polyfluoroalkylated substances (PFASs) is a large group of chemicals that has emerged as global environmental contaminants. In the Swedish population, 17 PFASs have been measured, of which the vast majority lacks human health risk assessment information. The objective of this study was to for the first time perform a cumulative health risk assessment of the 17 PFASs measured in the Swedish population, individually and in combination, using the Hazard Index (HI) approach. Swedish biomonitoring data (blood/serum concentrations of PFASs) were used and two study populations identified: 1) the general population exposed indirectly via the environment and 2) occupationally exposed professional ski waxers. Hazard data used were publicly available toxicity data for hepatotoxicity and reproductive toxicity as well as other more sensitive toxic effects. The results showed that PFASs concentrations were in the low ng/ml serum range in the general population, reaching high ng/ml and low μg/ml serum concentrations in the occupationally exposed. For those congeners lacking toxicity data with regard to hepatotoxicity and reproductive toxicity read-across extrapolations was performed. Other effects at lower dose levels were observed for some well-studied congeners. The risk characterization showed no concern for hepatotoxicity or reproductive toxicity in the general population except in a subpopulation eating PFOS-contaminated fish, illustrating that high local exposure may be of concern. For the occupationally exposed there was concern for hepatotoxicity by PFOA and all congeners in combination as well as for reproductive toxicity by all congeners in combination, thus a need for reduced exposure was identified. Concern for immunotoxicity by PFOS and for disrupted mammary gland development by PFOA was identified in both study populations as well as a need of additional toxicological data for many PFAS congeners with respect to all assessed endpoints.
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                Author and article information

                Journal
                Environ Health Perspect
                Environ. Health Perspect
                EHP
                Environmental Health Perspectives
                NLM-Export
                0091-6765
                1552-9924
                01 May 2015
                May 2015
                : 123
                : 5
                : A112-A113
                Affiliations
                [1]FluoroCouncil, Washington, DC, USA
                Author notes
                Article
                ehp.1509910
                10.1289/ehp.1509910
                4421776
                25933200
                f2371367-52fa-4efc-8b00-f95df8196e20
                Copyright @ 2015
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                Public health
                Public health

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