1 2 3 4 5 6 7 8 9 10 Total
Production/Use 0.00% 0 10.00% 1 10.00% 1 20.00% 2 0.00% 0 0.00% 0 0.00% 0 30.00% 3 10.00% 1 20.00% 2 10
Potential exposure route 0.00% 0 10.00% 1 10.00% 1 10.00% 1 10.00% 1 10.00% 1 30.00% 3 10.00% 1 0.00% 0 10.00% 1 10
Biological half-life 0.00% 0 10.00% 1 10.00% 1 10.00% 1 20.00% 2 30.00% 3 0.00% 0 10.00% 1 0.00% 0 10.00% 1 10
Physical-chemical properties 0.00% 0 0.00% 0 0.00% 0 0.00% 0 20.00% 2 20.00% 2 0.00% 0 40.00% 4 10.00% 1 10.00% 1 10
Carbon chain length/chemical structure 0.00% 0 0.00% 0 10.00% 1 0.00% 0 10.00% 1 0.00% 0 0.00% 0 20.00% 2 20.00% 2 40.00% 4 10
Toxicological endpoints 10.00% 1 0.00% 0 40.00% 4 0.00% 0 20.00% 2 20.00% 2 0.00% 0 0.00% 0 0.00% 0 10.00% 1 10
Mode of action 20.00% 2 30.00% 3 10.00% 1 0.00% 0 10.00% 1 10.00% 1 0.00% 0 10.00% 1 0.00% 0 10.00% 1 10
Other (please explain below) 0.00% 0 0.00% 0 0.00% 0 0.00% 0 0.00% 0 0.00% 0 0.00% 0 0.00% 0 50.00% 1 50.00% 1 2

Answer Explanations

  • Expert 10
    Grouped by:12345678910
    Production/Use0010000000
    Potential exposure route0010000000
    Biological half-life0000100000
    Physical-chemical properties0000010000
    Carbon chain length/chemical structure0000000100
    Toxicological endpoints1000000000
    Mode of action1000000000
    Other (please explain below)

    The answers depend on the end purpose of grouping and how many PFAS are grouped. If you would group all PFAS together then all the above categories would score 1 due to lack of information of the thousands of PFAS in use. If you take the PFAAs and perfluoroalkyl ether acids only, we know much more than for all PFAS, but are lacking toxicological data for some PFAAs and perfluoroalkyl ether acids. We also know little about production/use, properties and exposure for some perfluoroalkyl ether acids. Lack of information is often the reason for making precuationary simplifications in grouping approaches.

  • Expert 7
    Grouped by:12345678910
    Production/Use
    Potential exposure route
    Biological half-life
    Physical-chemical properties
    Carbon chain length/chemical structure
    Toxicological endpoints
    Mode of action
    Other (please explain below)0000000001

    They are all relevant but priorization needs to be undertaken and communicated before to proceed. And an organizational principle established for the report.

  • Expert 2
    Grouped by:12345678910
    Production/Use0001000000
    Potential exposure route0000100000
    Biological half-life0000010000
    Physical-chemical properties0000100000
    Carbon chain length/chemical structure0000100000
    Toxicological endpoints0000010000
    Mode of action0000000100
    Other (please explain below)

    Still we do not know much about physicochemical properties and it is not possible to group based on that.

  • Expert 8
    Grouped by:12345678910
    Production/Use0000000001
    Potential exposure route0000000001
    Biological half-life0000000001
    Physical-chemical properties0000000001
    Carbon chain length/chemical structure0000000001
    Toxicological endpoints0000000001
    Mode of action0000000001
    Other (please explain below)

    Again, there is no context to this question, and all are equally feasible depending on the specific scenario.

  • Expert 6
    Grouped by:12345678910
    Production/Use0000000100
    Potential exposure route0000001000
    Biological half-life0001000000
    Physical-chemical properties0000010000
    Carbon chain length/chemical structure0000000010
    Toxicological endpoints0010000000
    Mode of action0100000000
    Other (please explain below)

    See also answer to 1.3; the issue of "feasibility" changes the order of merit; with possibly insufficient information on toxicological profile and/or MoA across the spectrum of PFAS, a more pragmatic approach to grouping may be necessary

  • Expert 3
    Grouped by:12345678910
    Production/Use0000000100
    Potential exposure route0000001000
    Biological half-life0000010000
    Physical-chemical properties0000000100
    Carbon chain length/chemical structure0000000100
    Toxicological endpoints0000100000
    Mode of action0000100000
    Other (please explain below)

    Data are most abundant for those groups I ranked higher. Assuming that risk assessment strategies and research design are outcomes of this exercise, feasibility does not equal current availability of data. One can design (and in some cases require) studies that most contribute value to the information base.

  • Expert 9
    Grouped by:12345678910
    Production/Use0100000000
    Potential exposure route0100000000
    Biological half-life0100000000
    Physical-chemical properties0000000010
    Carbon chain length/chemical structure0010000000
    Toxicological endpoints0010000000
    Mode of action0100000000
    Other (please explain below)0000000010

    Persistence. It is known that the vast majority of PFAS are persistent. Even those that are not, i.e., precursors, degrade to stable PFAS end products.

  • Expert 11
    Grouped by:12345678910
    Production/Use0000000100
    Potential exposure route0000000100
    Biological half-life0000000100
    Physical-chemical properties0000000100
    Carbon chain length/chemical structure0000000001
    Toxicological endpoints0010000000
    Mode of action1000000000
    Other (please explain below)

    The above numbers reflect my limited understanding of the availability of data for PFAS compounds that could be used for a grouping strategy and not the effectiveness of such a strategy.

  • Expert 4
    Grouped by:12345678910
    Production/Use0000000001
    Potential exposure route0000010000
    Biological half-life0010000000
    Physical-chemical properties0000100000
    Carbon chain length/chemical structure0000000001
    Toxicological endpoints0010000000
    Mode of action0010000000
    Other (please explain below)

    For most PFAS, there is scant information that would allow grouping by most of these criteria. That is why I gave low feasibility scores to half-life, toxicological endpoints and mode of action. There is a little more data on phys/chem properties. Potential exposure routes could be inferred based on production and use. Grouping by production and use or carbon chain length is the most feasible, since this information is most available.

  • Expert 1
    Grouped by:12345678910
    Production/Use0001000000
    Potential exposure route0001000000
    Biological half-life0000100000
    Physical-chemical properties0000000100
    Carbon chain length/chemical structure0000000010
    Toxicological endpoints0000010000
    Mode of action0000010000
    Other (please explain below)

    Given the number of past- and current-use PFAS and the lack of toxicological data on most of them, it seems like using chemical descriptors is the most realistic approach. However, as stated in other sections, grouping all the PFAS together would simplify and accelerate the process.

  • Expert 5
    Grouped by:12345678910
    Production/Use0000000010
    Potential exposure route0000001000
    Biological half-life0000010000
    Physical-chemical properties0000000100
    Carbon chain length/chemical structure0000000001
    Toxicological endpoints0000100000
    Mode of action0100000000
    Other (please explain below)

    Feasibility might be interpreted to mean the development of confidence in the determination, or it may mean strictly the ability to apply the specified data/characteristics to successfully group chemicals. Feasibility is here considered to represent “Can we group by “X”?”

    The data most certain to be available might be chemical structure data; these data will be largely independent of chemical production, use, or biological endpoints. Next most available data might be production and use data. The numerical ratings applied here reflect this reviewer’s estimate of the likelihood of having or developing reliable data for each characteristic sufficient to serve as the basis for a credible grouping strategy. So, the toxicological endpoints and mode of action data may be the most reliable basis for chemical grouping to conduct a mixtures risk assessment for PFAS chemicals, but those data sets may also be the least likely to be available (for more than a few PFAS chemicals at present).

1 vote 1 0 votes
Expert 3
09/15/2021 13:47

I did not agree with reviewer 1's comment that grouping all the PFAS together is the way to proceed. But when I got to discussion of screening approaches -- maybe that is the way to go. In my original comments on screening I suggested considering all PFAS to be equitoxic, assume additivity, and compare estimated exposure to a health benchmark.

0
Expert 3
09/15/2021 13:49

Agree that production and use data are likely to be most available. Appreciate comments by reviewers that for screening could use these data with default assumptions for conservative estimate.

1 vote 1 0 votes
Expert 8
09/16/2021 13:43

I think that the feasibility of each of these depends on the purpose and scope of the assessment. Risk assessment is an iterative process and some mey be initially feasible and others may become feasible over time. What is lacking, however, from this list as well as from all the questions, is exposure. Production is often used as a surrogate, but for some PFAS compounds there are actual measures of human exposure.

1 vote 1 0 votes
Expert 5
09/16/2021 14:30

I relate best to answers provided by experts 1,4 and 6 - in that the data most likely to be available and undisputed may be chemical properties. Grouping to discriminate among chemicals might be best accomplished on the basis of factors that differ among groups, and so the use of persistence, as common to many, may induce complications, especially if potencies differ among chemicals with similar half-life values. Production and use data might be used to prioritize (but not necessarily group) chemicals for risk evaluation

0
Expert 7
09/20/2021 01:32

I agree on Reviewer 1 first statement that "Given the number of past- and current-use PFAS and the lack of toxicological data on most of them, it seems like using chemical descriptors is the most realistic approach". However, I believe that in the view of the discussions before as to "PFAS" grouping together will only confuse and dilute the process. I prefer concrete examples.
I do not agree that production and use data are easy to access. There are historic data available but they do not match and newer "inventories" use past production numbers and processes. Further, amounts may only be available for regulated chemicals.
Finally, PFAS precursors are blamed for most of the occurrence (in monitoring exercises) and they cannot be covered by production/use amounts.
For any grouping, the source of information needs to be defined and accessible for verification.

0
Expert 10
09/22/2021 03:47

Properties may be the most likely data available, but we be careful that we collect relevant properties given the unusual behaviour of PFAS, e.g. the octanol-water partition coefficient (Kow) is not relevant for fluorinated surfactant soprtion and bioaccumulation behavior. Also because of the unusual behaviour of PFAS, property estimation software often performs poorly.

0
Expert 4
09/23/2021 07:08

I appreciated Expert 8's comment that feasibility of a particular approach can change over time, for example as new data becomes available. I also agreed with several experts that feasibility of any approach depends on the context of the risk assessment. In my mind feasibility is not just about whether the data is available. It is also about whether a useful result can be produced within an appropriate time frame and budget, and can inform risk management strategies if necessary.

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