In a robust effort to tackle the extensive contamination from "forever chemicals," the US Environmental Protection Agency (EPA) has launched a pivotal initiative as part of its PFAS Strategic Roadmap. By issuing its fourth Toxic Substances Control Act (TSCA) test order, the EPA demands that the 3M Company and Wacker Chemical Corporation undertake detailed testing on 2-(N-Methylperfluoro-1-octanesulfonamido)ethanol (NMeFOSE). This chemical is extensively utilised in an array of consumer goods, including clothing, carpets, and furniture finishes.
This directive is a critical component of the EPA’s National PFAS Testing Strategy, designed to illuminate the physical-chemical properties and assess the potential health implications stemming from NMeFOSE inhalation. Given the disturbing evidence of NMeFOSE's environmental persistence, including its detection in air, biosolids, indoor dust, and outdoor environments, the urgency for exhaustive testing is more pronounced than ever.
EPA's Commitment to Community Health and Environmental Safety
Michal Freedhoff, Assistant Administrator for the Office of Chemical Safety and Pollution Prevention, underlined the significance of this effort: "Communities across the country are in need of information regarding the presence of PFAS in our air and water, and the health risks these chemicals may pose. This year, we are advancing our use of test orders to collate data on the health effects of PFAS, enabling us to undertake any necessary measures to safeguard public health and the environment.”
The rationale behind this test order stems from an in-depth review of available data, suggesting that NMeFOSE might represent an unreasonable health or environmental hazard, including potential risks to the nervous and immune systems, as well as cancer. The results from this testing will not only provide insights into NMeFOSE's specific dangers but also augment the EPA’s knowledge on over 100 PFAS with structural similarities, thereby broadening the understanding of the risks associated with these chemicals.
Guidance for Compliance and Collaboration
Targeted companies are prompted to either conduct the prescribed tests or present existing pertinent data that fulfils the EPA’s requirements. The EPA is advocating for a collective approach among companies for these tests to reduce redundancy, costs, and the utilisation of animal subjects.
As of 25 March 2024, the companies have a one-year window to submit the initial tier of testing results, which will inform the necessity for subsequent analyses. In a bid to maintain transparency and protect public health, the EPA intends to publicly disclose all data obtained through this order, with due consideration for confidentiality under TSCA section 14.
Towards a Comprehensive Strategy on PFAS
This endeavour is integral to the EPA’s wider strategy to mitigate the PFAS crisis, involving the classification of PFAS based on structural and toxicological traits to streamline testing and regulatory actions. As the agency refines its strategy and incorporates feedback from stakeholders, the focus will increasingly shift towards understanding and mitigating potential exposure risks, ensuring the protection of public health and the environment from these ubiquitous contaminants.
