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This week the Sierra Club submitted comments on the Environmental Protection Agency's draft toxicity assessments for two perfluorinated chemicals, PFBS and GenX. Both chemicals were introduced about a decade ago as "safer substitutes" to other nonstick chemicals, yet now appear to pose similar hazards to people and the environment.
PFAS are a family of synthetic chemicals used to make stain-resistant textiles, grease-proof food packaging, and non-stick cookware, among other uses. All PFAS are incredibly persistent in the environment.
The Sierra Club and allies called for the EPA to more carefully consider the health risks of PFBS and GenX chemicals individually, and in tandem with other PFAS chemicals. There is relatively little information on toxic effects of each chemical, and the studies EPA reviewed were generally performed by the fluorochemical industry and report effects to the kidney, liver, thyroid, and reproductive system. As is the case with other PFAS, infants and young children may be the most sensitive to exposure.
The Sierra Club joined The Endocrine Disruptor Exchange, NRDC, EWG ,and Center for Environmental Health to comment on the EPA's draft toxicity assessments for two perfluorinated (PFAS) chemicals, PFBS and GenX.
EPA’s assessment confirms what many have feared -- taking PFOA and PFOS off the market and out of products has only led to the industry replacing them with related PFAS chemicals that pose similar risks -- a "regrettable substitution."
GenX and PFBS are both linked to health harms similar to those of the chemicals they have replaced, and the draft potency estimate for GenX is in the same range as the EPA’s health threshold for PFOA.
We called for the EPA to more carefully consider the health risks of PFBS and GenX chemicals individually, and in tandem with other PFAS chemicals. Specifically,
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We are deeply concerned that these draft assessments do not include a sufficient margin of safety given the major gaps in our understanding of their individual and shared chemical properties and health effects.
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Not only is the toxicity data incomplete for both chemicals but it is also largely based on industry-performed studies.
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We also believe it is inappropriate for the EPA to attempt to estimate the risks posed by these chemicals individually. The people most at risk of exposure to PFBS and GenX chemicals will generally also have greater than typical exposures to legacy PFAS chemicals
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We also urge the EPA to improve and standardize methods of reviewing the evidence of chemical toxicity following the practices used in the systematic review of PFBS.
Finally, we underscore that risks assessments for two individual chemicals are not the appropriate framework for determine whether industry can "safely" emit more PFBS and GenX into the environment. Instead the EPA should limit new emissions as they add to the already excessive exposures PFAS chemicals in the general population.
Read the full letter here. (PDF)
Comments to the EPA were written in partnership with:
