EPA Issues Next PFAS Test Order Under National Testing Strategy

Aug. 16, 2023
Chemours, DuPont and 3M must submit testing results on HFPO-DAF, a PFAS used as a reactant in organic chemical manufacturing.

On August 15, 2023, the U.S. Environmental Protection Agency (EPA) issued the third Toxic Substances Control Act (TSCA) test order requiring testing on per- and polyfluoroalkyl substances (PFAS) under the EPA’s National PFAS Testing Strategy, the latest action taken to confront contamination from forever chemicals nationwide.

The action orders Chemours; DuPont de Nemours Inc.; and 3M to conduct and submit testing on 2,3,3,3-Tetrafluoro-2-(heptafluoropropoxy) propanoyl fluoride (HFPO-DAF), a substance used as a reactant in organic chemical manufacturing.

HFPO-DAF is known to be used to make the chemical Hexafluoropropylene Oxide (HFPO) Dimer Acid (CASRN 13252-13-6), also known by the trade name GenX. HFPO-DA is used in the production of nonstick coatings, stain repellent and other consumer and industrial products and was widely used to replace PFOA. More than 1 million lbs of HFPO-DAF are manufactured each year, according to required TSCA chemical data reports.

“We still don’t know enough about the dangers that many PFAS might pose to human health,” said Assistant Administrator for the Office of Chemical Safety and Pollution Prevention Michal Freedhoff in a press release. “We’re using all the tools at our disposal to rapidly gather data about these substances so that we can better understand the potential environmental and human health impacts of PFAS and take any necessary steps to address them.”

After thoroughly examining existing hazard and exposure data, the EPA has concluded that HFPO-DAF may present an unreasonable risk of injury to health or the environment. The potential hazards from exposure to this chemical could include organ damage, including to the eyes and skin, as well as cancer.

The EPA has also concluded that workers may be exposed to HFPO-DAF. Additionally, a recent EPA proposal to regulate six PFAS in drinking water, including HFPO-DA and its salts, isomers and derivatives which includes HFPO-DAF, found there was a meaningful opportunity to reduce health risks to people consuming drinking water contaminated by these PFAS. The test order will help the agency better understand the potential hazards and potential exposures associated with HFPO-DAF.

According to the EPA, the information it receives under this order will not only improve the agency’s understanding of HFPO-DAF’s effects on human health but also the potential effects of dozens of PFAS that are structurally similar to HFPO-DAF and in the same Testing Strategy category of PFAS, improving the agency’s overall PFAS data.

The latest test order falls under the agency’s recently released framework for reviewing PFAS chemicals that could pose persistent, bioaccumulative and toxic risk.

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