The U.S. Environmental Protection Agency (EPA) has issued a test order under the Toxic Substances Control Act (TSCA) for 6:2 Fluorotelomer Acrylate (6:2 FTAc), a chemical used in various industrial applications. The order, effective October 8, 2024, requires manufacturers, including prominent companies like Chemours and Daikin America, to conduct rigorous testing to evaluate the health and environmental risks associated with this substance. This move comes amid growing concerns about the potential dangers posed by per- and polyfluoroalkyl substances (PFAS), a class of chemicals to which 6:2 FTAc belongs.
What is 6:2 Fluorotelomer Acrylate?
6:2 Fluorotelomer Acrylate (CASRN 17527-29-6), also known as 3,3,4,4,5,5,6,6,7,7,8,8,8-Tridecafluorooctyl prop-2-enoate, is a PFAS commonly used in manufacturing textiles, resins, and coatings. Like other PFAS, 6:2 FTAc is valued for its ability to repel water, oil, and stains, but concerns have mounted over its persistence in the environment and potential adverse health effects.
The EPA classifies 6:2 FTAc as a chemical that “may present an unreasonable risk of injury to health or the environment” under section 4 of TSCA. This order aims to address significant gaps in knowledge about the chemical's toxicokinetics, bioaccumulation potential, and long-term effects on human health.
Why the EPA Issued the Test Order
The EPA has raised concerns about the environmental persistence and potential toxicity of 6:2 FTAc, particularly its behavior in air, water, and soil, where it could remain for years without breaking down. Testing on other PFAS chemicals has shown they can accumulate in living organisms, potentially leading to harmful effects, including cancer, reproductive issues, and developmental delays.
The test order requires manufacturers and processors of 6:2 FTAc to develop detailed data on its physical-chemical properties, environmental fate, and health impacts. This testing is crucial to assessing how the chemical may affect workers, consumers, and the environment.
What Tests Are Required?
The order breaks down testing requirements into several key categories:
- Physical-Chemical Properties: Tests for melting and boiling points, vapor pressure, and water solubility will determine how the chemical behaves in different environmental conditions.
- Environmental Fate and Behavior: The EPA mandates studies on how 6:2 FTAc interacts with soil and sewage sludge, as well as how it breaks down (or fails to break down) in various environmental media.
- Health Effects: Critical health tests include skin absorption studies, genotoxicity assessments (tests for DNA damage), and toxicokinetic studies through oral and inhalation routes. These tests will evaluate how 6:2 FTAc moves through the human body and whether it poses risks of cancer or other chronic health issues.
Companies Involved and Response Options
The companies subject to this test order include Chemours, Daikin America, DuPont, Sumitomo Corp. of Americas, and Innovative Chemical Technologies. These firms have 30 days to respond to the EPA, identifying whether they are manufacturers, processors, or both. They are then required to either develop the requested information, submit existing relevant data, or seek an exemption if the chemical has not been in their production pipeline in the last five years.
Failure to comply with the order could result in substantial penalties, including fines or legal action. The EPA’s move to enforce these tests reflects the broader push by regulators to address the widespread contamination of PFAS chemicals, often referred to as "forever chemicals," due to their persistence in the environment.
Broader Implications for PFAS Regulation
This test order is part of a larger strategy by the EPA to regulate and understand the full impact of PFAS chemicals, many of which have been linked to serious health and environmental problems. PFAS are used in a wide range of products, from non-stick cookware to firefighting foam, and their widespread use has led to contamination in water supplies across the U.S.
In recent years, federal and state agencies have increased scrutiny on PFAS, implementing stricter guidelines and banning certain high-risk PFAS compounds. The data collected from this test order will contribute to the EPA’s efforts to create a more comprehensive regulatory framework for managing PFAS risks in the future.
The EPA's test order for 6:2 Fluorotelomer Acrylate marks a significant step in the ongoing regulation of PFAS chemicals. By requiring extensive testing on the environmental and health impacts of 6:2 FTAc, the agency aims to fill critical knowledge gaps and ensure better protection for both human health and the environment. As the results of these tests become available, the EPA is likely to adjust its policies on PFAS, potentially leading to more stringent regulations for these persistent and hazardous substances.
