Jake Auchincloss on PFAS Testing Investment and Regulation

Challenges in PFAS Testing

• 🧪 PFAS testing at parts per trillion levels can yield results with significant variability, depending on the lab, time of day, and even the gloves used.
• 🎯 The current drinking water standard of four parts per trillion is based on reliable testing capabilities, not necessarily risk-based standards, which are much lower (0.01-0.03 parts per trillion).
• ⚠️ This variability can create a false sense of precision and undermine confidence in test results, impacting public health communications.

Need for Federal Investment in Testing

• 💡 There is a call for federal investment in R&D for inline, 24/7 high-integrity testing of PFAS content within drinking water facilities.
• ⚡ Such real-time, consistent testing is needed to provide understandable results, moving beyond lab-by-lab analysis.

Shifting Focus to Upstream Regulation

• 🎯 Debating contamination levels at the point of consumption (municipal water) is chasing the problem late in the bioaccumulation cycle.
• 🚀 It is crucial to address PFAS at the point of production by going upstream.
• ⚖️ Support for using the Resource Conservation and Recovery Act (RCRA) to designate PFAS as a hazardous substance for remediation is mentioned.
• 📈 There is also a call to strengthen the Toxic Substances Control Act (TSCA) to proactively regulate PFAS production and expedite unreasonable risk determinations.

Avoiding Regrettable Substitutes and Industry Influence

• ⚠️ It is essential to be cautious about shields where bad actors can hide, preventing polluters from co-opting local utilities and delaying mitigation.
• 🚫 The focus should be on phasing out non-essential uses of PFAS at the point of production, similar to how ozone-depleting chemicals were handled under the Montreal Protocol.
• ♻️ A concern is the repeated use of regrettable substitutes (like PFAS replacing ozone-depleting chemicals) and the need for green chemistry solutions.
• 🗣️ Industry should not be allowed to dictate regulations, as they have historically shown a failure to self-regulate or hold themselves accountable.