As of late, the daily headlines are filled with stories from the halls of Congress and elsewhere of proposed regulations and the challenges nearly every permitted entity is facing in addressing the chemical family of per- and polyfluoroalkyl substances (PFAS).
Stop us if you’ve heard this one before, but PFAS are a nearly 6,000-strong army of man-made synthetic chemicals used for many decades in hundreds of applications where grease- and water‑resistant surface qualities are required. Teflon®, Gore-Tex®, stain-free carpets, pizza boxes and popcorn bags (and many other food packaging) are among the many consumer products in which PFAS were used. Critically important to note, is the use of aqueous film‑forming foam (AFFF) that has been effectively used in firefighting for decades. Due to the carbon-fluorine bond, one of the strongest in nature, PFAS have gained the nickname, “forever chemicals.” While the toxicity has not been studied for most PFAS, there are some studies suggesting select PFAS may have carcinogenic properties.
Until June 2019, the only published US EPA analytical method was prepared for drinking water and no other non-potable aqueous, solid, tissue or air. Currently, out for comment until July 22nd, US EPA’s Office of Resource Conservation and Recovery is seeking public input on its validated SW-846 Update VII – Method 8327: Per-and Polyfluoroalkyl Substances (PFAS) Using External Standard Calibration and Multiple Reaction Monitoring (MRM) Liquid Chromatography/Tandem Mass Spectrometry (LC/MS/MS). This method includes the analysis of 24 PFAS analytes in aqueous matrices, and is intended to go beyond finished drinking water.
While the US EPA deems the draft method “generally acceptable,” our Chemists at Environmental Standards would take issue. We have identified a number of deficiencies and shortcomings with this draft method. Having thoroughly reviewed the method and the results from US EPA’s round-robin laboratory study, there is compelling evidence that adhering to this method will produce screening-quality data and not the determinative data the anticipated pending regulatory climate expects.
Engaged by various stakeholders and trade associations, Environmental Standards will be submitting comments on behalf of this coalition. Should you wish to have your company’s voice join the coalition, please contact Rock Vitale, rvitale@www.envstd.com or David Blye, dblye@www.envstd.com to learn how to participate. Environmental Standards is not alone in its concerns of US EPA Method 8327. Recently, the Department of Defense released its comments stating, “This analyte exhibits known difficulties with reproducibility, response, recovery, stability, and /or chromatography that may reduce the overall quality or confidence in the results when using this method.”
It is said, “to be informed is to be prepared,” and it could be argued that passively following the PFAS headlines may be a prudent corporate approach. Another proactive approach, should you see the need for current or future sampling and analysis for PFAS, is to engage Environmental Standards to prepare specific PFAS technical specifications (TS) for contracting laboratories for PFAS analytical services. In order to ensure compliance with the TS and assess data quality, Environmental Standards Chemists can perform critical data validation to ensure data are of defensible and of known quality.