When considering the need to regulate PFAS manufacture, use, and import based on human health risks, should lifecycle considerations (risks during production, use and disposal, degradation) be taken into account?

Answer Explanations

• Yes

  Expert 1

  In many cases, PFAS contamination occurred as a result of inadequate disposal. Not accounting for the lifecycle would definitely overlook some potential risks to human health.

• Yes

  Expert 11

  The major sites of contamination are often PFAS manufacturing sites. This suggests that environmental releases during manufacturing should be included in the decision to regulate a compound.

• Yes

  Expert 4

  Risks need to be managed at all stages of the life cycle, so risk assessments should include all stages of the life cycle. The main purpose of most risk assessments is to inform risk management (e.g. setting drinking water criteria or eflluent limits).

• Yes

  Expert 2

  Majority of the PFAS in commerce are precursors that can break down to a persistent metabolite. It is important to understand where and how PFAS are used and life cycle of the product that contains PFAS for effective regulation. Like for many other chemical classes, life cycle assessment is important especially when used in household products (such as carpets).

• Yes

  Expert 3

  Regulations under certain legislative mandates require these consideration. SDWA 96 does not, in that if the contaminant is in the water, it matters not how it got there in terms of the way in which it is regulated. The Clean Water Act, by contrast, can consider parts of life cycle (such as disposal) in setting designated uses for waterbodies. In general it is most effective when the various legislative mandates -- not just those for water as a source -- can be used in concert to reduce exposure to hazardous agents.

• Yes

  Expert 7

  I think life-cycle considerations are commonly applied; the extend to be determined.
  Certain steps are already regulated such as workplace exposure (whereby not necessarily measurements need to be associated)
  Production conditions are also given such as use of closed cycles (to be defined), disposal/destruction technologies (and their parameters; e.g. HF emissions in incineration; not the PFAS)

• Yes

  Expert 10

  Yes! Even if the product (e.g. PTFE-cookware) is inert, large quantities of low molecular weight toxic PFAS may be released during manufacture (e.g. in the case of PTFE manufactured in China, PFOA is released in large quantities still today) or during disposal (e.g. emissions during metal recycling, incineration, etc.).

• Yes

  Expert 8

  Yes. They already are considered.

• Yes

  Expert 6

  I am not saying it will be easy to predict exposures through all of these cycles, or whether exposures will occur to different forms of PFAS during the lifecycle of any one PFAS (e.g. degradation products), but ultimately, a wholistic approach is more likely to identify those aspects of human exposures that could lead to health risks.

• Yes

  Expert 9

  Myriad reasons support lifecycle considerations for PFAS. It is well known that many PFAS used in industrial processes escape the manufacturing "loop" and enter the environment, exposing more than just those who work with PFAS in manufacturing processes. While many facilities within the US have implemented capture devices for air and water emissions, these are not 100% efficient and for certain types of waste, i.e., process water, the generated PFAS still need to be filtered and/or incinerated, typically off-site. Accumulating evidence highlights that PFAS are present in household dust and dusts in facilities, such as firehouses, that have PFAS-containing products. Additional accumulating evidence demonstrates that a variety of PFAS are detectable in leachate water from landfills. Therefore, human exposure potential exists across various stages of the PFAS lifecycle so this needs to be considered.

• Yes

  Expert 5

  During the regulation phase, all potential exposures during the chemical's lifecycle should be assessed for health risk. Through this approach, exposures (and risk and health impact) during specific phases of the lifecycle can be estimated. Individual phases of the life cycle (and perhaps individual uses) can be prioritized for additional scrutiny according to the health impact (not just risk) associated with exposures during specific phases/stages (or even uses) of the lifecycle. The application of a health economic analysis could help refine estimates of health impact.