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(11 Answers)

  • Expert 10

    First, one must decide on the "critical effect" that is the basis of the risk assessment for multiple PFAS.
    There is not a consensus between different authorities on which forms of toxicity (development, hepatotoxicity, etc.) should be the basis of the risk assessment. Without the availability of more information on specific toxic effects (e.g. mode of action for immunotoxicity), it's hard to make a judgement regarding which critical effect should form the basis of the risk assessment.

    Second, once the critical effect is decided, it can be that there are missing data for some PFAS in the key studies that form the basis of the risk assessment. Therefore, the number of PFAS than can be grouped will be limited by data availability on effects. There is a severe lack of true mixture toxicity studies (i.e. when a test species is exposed to mixture of multiple PFAS simultaneously).

    Third, it is uncertain how to deal with exposure to precursors (many of which are not routinely monitored or are unknown) to perfluoroalkyl acids (PFAAs) (e.g. can we assume that they will be absorbed and rapidly metabolized to PFAAs in vivo and thus adding to exposure?). Also, intermediates between the precursors and the PFAAs can also be long-lived and toxic. The detailed information on kinetics of complex transformation processes between precursors and terminal transformation products (usually PFAAs), as well as the toxicities of intermediates, are data gaps that are unlikely to be filled.

  • Expert 2

    Role of precursor PFAS and their biotransformation
    Toxicity of several subgroups and mode of toxicity of each subgroups
    Additive nature of mixture toxicity
    Extrapolation of toxicity from animal model to humans

  • Expert 6

    As outlined in Round 1, the most pressing data gaps relate to toxicological mechanisms for PFAS, so that sub-groups can be constructed with the commonality that is implicit in grouping methodologies proposed in US EPA "Guidelines for health risk assessment of chemical mixtures". The basic assumption, as outlined in this document ("Since the assumption of dose addition is most properly applied to compounds that induce the same effect by similar modes of action, a separate hazard index should be generated for each end point of concern. Dose addition for dissimilar effects does not have strong scientific support, and, if done, should be justified on a case-by-case basis in terms of biological plausibility") implies that a Hazard Index calculated from the exposure/HBGV ratios for individual or grouped PFAS requires data that currently exists for only a few individual PFAS.

  • Expert 1

    In vitro data on PFAS mixtures would allow evaluating the dose additivity assumption, which seems to be central to the derivation of a health-based drinking water guideline.

  • Expert 3

    If the analysis plan and resources are limited to data available in October 2021, then presumably this question is meant to define areas of uncertainty. A different question is rather what information would be most valuable in producing a "better" risk assessment, one that is more precise and accurate. I think the data gap answers from the experts in Round 1 were largely directed at this latter question.

  • Expert 8

    Data exist to conduct a risk assessment of the PFAS that have been measured in the UCMR3. If one wishes to expand this list, simply considering pchem properties is insufficient. This would be a rudimentary first step, and analyses would also have to include factors such as use, pathway to drinking water, and actual measurements in drinking water.

  • Expert 5

    Again, grouping and potency (does response) rise to the top of the priority list. As a matter of potency, toxicokinetics should be considered, at least in rudimentary form.

  • Expert 9

    Currently, data gaps exist for all of the available resources (toxicity, exposure, physical-chemical properties) for many individual PFAS. Additionally, new approach methodologies and other rapid/high-throughput methods for evaluating large numbers of PFAS are still in their infancy for PFAS. It may be possible to conduct a risk assessment on some of the well-studied PFAS (i.e., "long-chain" perfluoroalkyl acids (PFAAs) that include the perfluorocarboxylic acids (PFCAs) and perfluorosulfonic acids (PFSAs), but assumptions will still have to be made for individual PFAS within this "subgroup" that are still lacking either toxicological, exposure, or physical-chemical property data.

  • Expert 11

    Strictly speaking, there are no data gaps in the problem formulation that need to be filled since as point 5 of the problem formulation states the groupings will only rely on available data. Now given the state of available data on the toxicity of PFAS it is safe to say that the decisions on groupings generated will be very uncertain and are likely to need to be revised when additional data become available. Since I am not familiar with all of the data available PFAS, I am unable to identify specific data gaps.

  • Expert 4

    It will be important to know how important the drinking water pathway is relative to other routes of exposure (Required for apportionment of exposure to drinking water in setting the MCL).

  • Expert 7

    Careful and sound wording is necessary to define the problem/objective and apply throughout. Limitations need to be addressed as well otherwise the different disciplines struggle with themselves and between each other.
    In my view, risk assessment must be followed by risk management, which should be revisited periodically as to efficiency and be flexible for adaptations.
    it would be a failure to discuss forever, rather take measures. Risk assessment alone (like environmental or biomonitoring) do not change anything

2 votes 2 0 votes
Expert 4
10/20/2021 08:48

Experts 9 and 10 have detailed the most important data gaps, particularly in the dose-response/toxicity portion of the risk assessment process. Expert 8

1 vote 1 0 votes
Expert 4
10/20/2021 08:51

... identifies some of the data gaps on the exposure side. I continue to think it's important to know how drinking water exposures compare to exposures via other media (e.g. food), since this is important for apportionment.

[EDITORIAL NOTE FOR SCIPI: It would be great if we could edit our comments. I accidently hit the return key and could not edit my response. Thank you.]

1 vote 1 0 votes
Expert 2
10/20/2021 09:37

How precursor PFAS are evaluated in risk assessment can be tricky. They (i.e., precurosors) may not be found in human specimens as is, but they form the source for metabolites that accumulate in tissues. Thus, the toxicokinetics of many precursor PFAS needs to be assessed.

0
Expert 3
10/20/2021 13:10

I concur with Expert 11.

2 votes 2 0 votes
Expert 7
10/22/2021 07:58

Whatever problem addressed or approach taken, the process (risk assessment, setting MCL) must be consistent. We cannot state that the PFAS have different characteristics and not agree on grouping and then use one critical effect or one parameter (bioaccumulation, persistence, etc.) for all compounds or other groups or mixtures.
It does not make sense to ask for many groups and then use one approach in the risk assessment, neither the way backwards to have one critical effect and then assign all PFAS to this effect or parameter.
From the answers and the debate, I conclude that there are deficiencies, gaps, uncertainties, etc. at all ends with the chemical identity, the physical chemical parameters, which impact fate and transport, we do not know enough about the sources and the source strength and we lack knowledge about mode of action, endpoints, etc.
We must be more honest to state the facts and the gaps in each step of the risk assessment - then state how to close the gaps and do so and move forward towards the final risk assessment or MCL (or whatever is the target). We cannot accumulate the gaps (and uncertainties until finish line), have to make assumptions, agree on these and move forward. Otherwise, the process of the risk assessment is not understood.

Maybe it is time to develop one (or more) decision trees to elucidate the risk assessment approach.

1 vote 1 0 votes
Expert 5
10/23/2021 19:27

Experts 9, 10 and 6 have pretty much captured what I think are the technical data (information) gaps. The response to these comments from Expert 7 (immediately above) rings true with me. We must develop a process that is clearly described, internally consistent, and - hopefully - workable. There will always be data gaps, unless every "mixture of concern" has adequate human dose response data from a chronic exposure.

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Expert 10
10/24/2021 07:28

Expert 11's answer was clever and I didn't think of that. However, I think the answers of other experts (e.g. 5, 6 and 9) were more in line with what SciPinion wanted. They covered the important data gaps.

1 vote 1 0 votes
Expert 6
10/24/2021 21:13

I agree that Experts 9 & 10 have outlined the key data gaps, and I also like the "decision tree" approach suggested by Expert 7. It would be useful to know how such a decision tree approach could be fleshed out.

{Further editorial note - I found it frustrating that comments typed into the box would disappear if they were not 'saved' before moving to the next question. That prevents any return for later editing if further thoughts occur as a result of reading more comments}

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Expert 8
10/25/2021 07:18

The comments of experts 9 and 10 reflect my comments on the data availability of those PFAS that have been measured in the public drinking water facilities (UCMR3). There are sufficient data for those specific PFAS . It gets more difficult if other PFAS are included as the data will be lacking for the most part.

0
Expert 11
10/26/2021 13:23

Expert 4's comment on apportionment is correct. But in the past apportionment has been been done based on policy in the absence of data. So this might not be a problem.

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Expert 11
10/26/2021 13:28

My response on data gaps was more than a little bit snarky. For this I apologize to the group. But The point I was trying to make is that the wording in the draft problem formulation did not appear to think through the technical issues required in a statement. As a result, it was hard to actually answer the questions.

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