EPA Issues Final Lifetime Health Advisories for PFOA and PFOS

On May 25, 2016 the U.S. Environmental Protection Agency (EPA) issued its final Lifetime Health Advisories (HAs) for the compounds perflourooctanoic acid, otherwise known as PFOA, and perflourooctane sulfonate, or PFOS, lowering the health advisory concentrations for these chemicals to the part per trillion level – a move that may be related to the intense litigation scrutiny that these chemicals are currently undergoing.


PFOA and PFOS are part of a large group of chemicals known as perflourinated chemicals (PFCs). PFCs are used in the manufacture of common household products such as carpeting, clothing, furniture fabrics, food packaging, and cookware. PFCs are employed in these products because of their resistance to water, grease, and stains. They are also used in firefighting chemicals at airfields.


PFCs are extremely persistent and very resistant to typical environmental degradation processes due to their carbon–fluorine bonds, among the strongest found in organic chemistry. They are found in environmental media worldwide, including finished drinking water, surface water, groundwater, air, sludge, soils, sediments, outdoor and indoor dust, biota, and polar ice caps.


PFOA cannot be removed from drinking water by standard treatment processes such as coagulation, sand filtration, sedimentation, ozonation, or chlorination, but can be removed by activated carbon.


Sources of exposure to PFOA and/or its precursors include drinking water, food, migration from food packaging into food, treated fabrics (carpets, upholstery, and clothing), house dust, use of protective sprays sold as consumer products, ski waxes, and inhalation of indoor and outdoor air. Migration into food from nonstick (Teflon-coated) cookware is not considered to be a significant exposure source. Occupational exposure is believed to occur primarily through inhalation.


PFOA differs in several important ways from other well-studied drinking water contaminants. For example, it is very resistant to degradation in the environment and thus persists long periods of time. Unlike other persistent, bioaccumulative, and toxic organic compounds that are fat soluble and for which human exposure primarily occurs through dietary sources such as fish, meat, or dairy products, PFOA is water soluble and contaminates drinking water sources when discharged to the environment.


Even though PFOA is water soluble it has a half-life of several years in humans and ongoing exposure to relatively low levels in drinking water substantially increases total exposure in humans.


EPA has set the Health Advisory for both PFOA and PFOS at 0.07 parts per billion (ppb) within drinking water, which is relatively more restrictive than other common organic compounds regulated by the Safe Drinking Water Act. For example, trichloroethylene and benzene – known carcinogens – have a Maximum Contaminant Level (MCL) of 5 ppb; vinyl chloride has an MCL of 2 ppb; and PCBs have a MCL of 0.5 ppb.


EPA’s Health Advisories for PFOA and PFOS are not regulatory standards; rather, they exist to assist federal, state, and local officials as well as water managers to protect public health by providing information on the chemical and physical properties of the chemicals as well as other information on the toxicity, exposure, and occurrence of the chemical in the environment. The Health Advisories issued in May 2016 supersede the draft versions EPA released in February 2014.


First Environment Point of Contact:

Tod Delaney, PhD, PE, President


[email protected]





ATSDR., 2009. Agency for Toxics Substances and Disease Registry. Toxicological Profile for Perfluoroalkyls. Draft for Public Comment. May 2009. /http://www.atsdr.cdc.gov/toxprofiles/tp200.pdfS Accessed 1/17/12.


Bartell, S.M., Calafat, A.M., Lyu, C., Kato, K., Ryan, P.B., Steenland, K., 2010. Rate of decline in serum PFOA concentrations after granular activated carbon filtration at two public water systems in Ohio and West Virginia. Environ. Health Perspect. 118, 222–228.


Eschauzier, C., Beerendonk, E., Scholte-Veenendaal, P., De Voogt, P. Impact of treatment processes on the removal of perfluoroalkyl acids from the drinking water production chain. Environ. Sci.Technol., in press.


Fraser, A.J., Webster, T.F., Watkins, D.J., Nelson, J.W., Stapleton, H.M., Calafat, A.M., Kato, K., Shoeib, M., Vieira, V.M., McClean, M.D., 2011. Perfluorinated compounds in serum linked to indoor air in office environments. Environ. Sci. Technol. 46, 1209–1215.


Freberg, B.I., Haug, L.S., Olsen, R., Daae, H.L., Hersson, M., Thomsen, C., Thorud, S., Becher, G., Molander, P., Ellingsen, D.G., 2011. Occupational exposure to airborne perfluorinated compounds during professional ski waxing. Environ. Sci. Technol. 44, 7723–7728.


Gewurtz, S.B., Bhavsar, S.P., Crozier, P.W., Diamond, M.L., Helm, P.A., Marvin, C.H., Reiner, E.J., 2009. Perfluoroalkyl contaminants in window film: indoor/outdoor, urban/rural, and winter/summer contamination and assessment of carpet as a possible source. Environ. Sci. Technol. 43, 7317–7323.


Gloria B. Post, PhD, DABT, Comments on “Health Effects Document for Perfluorooctanoic Acid (PFOA),” New Jersey Department of Environmental Protection, May 2014


Guo, Z., Lin, X., Krebs, K.A., Roache, N., 2009. Perfluorocarboxylic acid content in 116 articles of commerce. ORD, USEPA, RTP, NC. EPA/600/R-09/033. March 2009. /http://www.oecd.org/dataoecd/47/50/48125746.pdfS Accessed 1/17/12.


Lau, C., Anitole, K., Hodes, C., Lai, D., Pfahles-Hutchens, A., Seed, J., 2007. Perfluoroalkyl acids: a review of monitoring and toxicological findings. Toxicol. Sci. 99, 366–394.


Nilsson, H., K¨arrman, A.,Westberg, H., Rotander, A., van Bavel, B., Lindstr¨om, G., 2010. A time trend study of significantly elevated perfluorocarboxylate levels in humans after using fluorinated ski wax. Environ. Sci. Technol. 44, 2150–2155.


Rumsby, P.C., McLaughlin, C.L., Hall, T., 2009. Perfluorooctane sulphonate and perfluorooctanoic acid in drinking and environmental waters. Philos. Transact. A Math. Phys. Eng. Sci. 367, 4119–4136.


Takagi, S., Adachi, F., Miyano, K., Koizumi, Y., Tanaka, H., Watanabe, I., Tanabe, S., Kannan, K., 2011. Fate of perfluorooctanesulfonate and perfluorooctanoate in drinking water treatment processes. Water Res. 45, 3925–3932.


Trudel, D., Horowitz, L.,Wormuth, M., Scheringer, M., Cousins, I.T., Hungerbuheler, K.,2008. Estimating consumer exposure to PFOS and PFOA. Risk Anal. 28, 251–269.


Vaalgamaa, S., V¨ah¨atalo, A.V., Perkola, N., Huhtala, S., 2011. Photochemical reactivity of perfluorooctanoic acid (PFOA) in conditions representing surface water. Sci. Total Environ. 409, 3043–3048.


Vestergren, R., Cousins, I.T., 2009. Tracking the pathways of human exposure to perfluorocarboxylates. Environ, Sci. Technol. 43, 5565–5575.

Arthur Clarke, JD

Market Area Director – Litigation and Regulatory Compliance

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Art has more than 30 years of experience as an environmental chemist, regulatory manager, and environmental attorney. He specializes in litigation support, transactional support, due diligence, and regulatory compliance matters and has extensive technical experience as both a project manager and analytical chemist. Art regularly oversees facility compliance auditing and pre-acquisition investigations. He also provides regulatory counseling and consulting to clients appearing before state and federal administrative agencies, administrative law proceedings, and plenary courts. Art assists with negotiations regarding permitting and regulatory compliance matters, and also supports regulatory enforcement defense. He has designed and implemented regulatory compliance and auditing programs for a number of clients, and has created subject matter newsletters and alerts to private and public sector clients. In addition, Art has led international and domestic due diligence teams in the investigation and assessment of pre-acquisition liabilities. He also counsels clients on sustainability matters, renewable energy, and green leases. As First Environment’s corporate quality assurance manager since 2010, he develops and manages the firm’s quality programs; authors standard operating procedures; and oversees execution of program and project plans, audits, and corrective actions