We’ve Got 99 Problems & PFAS Is One

Will New Efforts To Regulate & Study PFAS Make A Difference?

I wish we could talk less about PFAS (per- and polyfluoroalkyl substances), but these contaminants continue to make headlines and some of the news shows promise, so I want to give you the latest.

Legislative Action

On April 13, Representatives Debbie Dingell and Fred Upton from Michigan introduced a bipartisan bill to the House called the PFAS Action Act of 2021 to help establish a national drinking water standard for PFOA and PFOS and designate these chemicals as hazardous substances.

“Let’s be very clear, PFAS is an urgent public health and environmental threat. And the number of contamination sites nationwide is growing at an alarming rate, including our military bases,” said Rep. Dingell said in statement. “Setting drinking water standards and designating PFAS as hazardous substances under the EPA’s Superfund program will accelerate the clean-up process in communities and at military facilities all across this nation.”

The bill would:

  • Require the U.S. Environmental Protection Agency (EPA) to establish a national drinking water standard for PFOA and PFOS within two years that protects public health, including the health of vulnerable subpopulations.

  • Designate PFOA and PFOS chemicals as hazardous substances within one year and requires EPA to determine whether to list other PFAS within five years.

  • Designate PFOA and PFOS as hazardous air pollutants within 180 days and requires EPA to determine whether to list other PFAS within five years.

  • Require EPA to place discharge limits on industrial releases of PFAS and provides $200 million annually for wastewater treatment.

  • Prohibit unsafe incineration of PFAS wastes and places a moratorium on the introduction of new PFAS into commerce.

  • Require comprehensive PFAS health testing.

  • Create a voluntary label for PFAS in cookware.

Sounds like a good start, but we have been here before, as similar legislation passed in the House in January 2020, but stalled in the Senate. Here’s hoping this new act can make it all the way through Congress.

For a refresher on PFAS chemicals and a chuckle (laughter can be good medicine), check out this clip from The Daily Show last year:

At The Federal Level

The National Center for Environmental Health and the Agency for Toxic Substances and Disease Registry announced plans to further study the link between exposure to PFAS chemicals and susceptibility to viral illnesses, including Covid-19, pneumonia, and the flu.

I’m encouraged to see this work continue, as we need more information about how chemical exposures affect our immune systems and whether they make people more vulnerable to sicknesses, especially as the immune system is on the minds of so many people right now.

The research builds on investigations of PFAS exposure in communities located near U.S. military bases, where elevated levels of these contaminants were detected in the drinking water. The new study will send health questionnaires to people who have already had blood samples drawn for the PFAS exposure assessments.

Starting in 2006, studies showed probable links between PFOA and chronic diseases like high cholesterol, thyroid disease, testicular cancer, and kidney cancer.

Read more about it here.

A Class of PFAS

Meanwhile, a California agency is making plans to regulate PFAS as well. The state’s Department of Toxic Substances Control (DTSC) is looking to regulate PFAS as a class of chemicals rather than individually on the grounds that they exhibit “environmental persistence.”

If this rule goes into effect, DTSC will become the world’s first agency to use persistence to warrant regulation.

“The widespread use, large number, and diverse chemical structures of PFAS pose challenges to any sufficiently protective regulation, emissions reduction, and remediation at contaminated sites,” wrote DTSC scientists in a February 2021 paper. “The approach of regulating only individual PFAS or a limited subset of PFAS has led to the replacement of those PFAS with other members of the class that have less well-characterized hazard profiles. These alternatives may even be worse, in some respects, than the PFAS being replaced, thus constituting a ‘regrettable substitution.’”

You might remember in late March, I testified before Congress at a hearing on Remediation and Impact of PFAS and one of the other witnesses that day was Dr. Jamie DeWitt. I was so impressed with her knowledge and passion about PFAS that I got in touch with her to talk more about her work.

She’s an associate professor of pharmacology and toxicology at the Brody School of Medicine at East Carolina University in Greenville, North Carolina. Her laboratory’s research program explores the toxicological effects of PFAS and how they affect the immune system. She explores the immune system in model systems.

“Here in my laboratory, we do ask questions about the immune system and we really focus on the part of the immune system that we call the adaptive immune system, so that’s the immune system that's really important when you get exposed to pathogens that your body has never seen like Covid-19 or when you get vaccinated and you get exposed to an antigen that your body has never seen so that you can make a memory response,” she said.

One of the ways she investigates how that part of the immune system functions is by challenging it and measuring its response to that challenge.

“Just how epidemiologist might ask people to come in for a vaccination in a particular contaminated community and then measure their response to a vaccination,” she said, “we do the same thing in experimental systems, but we also ask general questions about other parts of the immune system as well.”

At her lab, they examine different types of cells and different types of signals and really try to get a handle on why the immune system isn't functioning the way they would expect.

“For example, we have some funding from the NIEHS through their superfund research program to really dig into why the immune system doesn't appear to make a good number of antibodies when PFAS are present,” Dr. Jamie explained. “What's been reported in people is that there's a suppressed response to vaccinations. We've really focused in on cells called B cells, which are the cells that eventually transform into cells that makes antibodies. We're trying to figure out the molecular reasons that B cells don't make the antibodies at the level that they're supposed to make.”

A lot of her work is done in a tube looking at cells and measuring them, trying to figure out if they're using energy in the ways that they're supposed to use energy, performing some basic immunology along with immunotoxicology.

She also works on “descriptive immunotoxicology,” studying certain PFAS that we know almost nothing about. In the publicly-available literature, there’s almost no data on some PFAS compounds that have been discovered in North Carolina when it comes to their potential to induce toxicity.

“We're  trying to figure out if they have the potential to cause immunotoxicity,” she said. “We're working on those very first studies to ask about the potential of these new PFAS to disturb the immune system.”

She shared that so far, some of the understudied PFAS in North Carolina did not produce suppression of this particular immune response, but that doesn't mean they’re not toxic or immunotoxic. It just means that at the doses they administered, they didn't produce less of this particular response.

“We've looked at another compound and it produced very robust suppression of this response,” she said.

She and her team have published several times that PFOA, also known as C8, suppresses the antibody response in experimental models and she’s reported that Gen X (a replacement compound for PFOA) can suppress this response as well.

The Science Says…

One of the most pertinent parts of what Dr. Jamie shared with me is that we already have quite a bit of evidence on the PFAS that has been studied.

“We're pretty confident that PFAS as a class exhibit a whole bunch of undesirable characteristics—that the vast majority of PFAS are persistent,” she said. “In some countries that alone is sufficient to classify them as “chemicals of concern” that should be regulated and phased out. Persistent means they don't break down. They don't go away and many of the ones that we studied have toxicity; many of the ones that we studied can bioaccumulate; and we're also learning that many PFAS are really mobile so they can move from state to state and country to country. We really should be coming up with guidelines to manage PFAS as a class and to phase their non-essential uses out of production.”

When I asked her why regulations are lagging when the science is in, she echoed something I’ve written many times.

“I think regulations always lag behind the science,” she said. “I, as a toxicologist, lag behind the environmental chemists, who are measuring PFAS in the environment.”

First, scientists have to identify that PFAS are in the environment and are getting into people, and then they have to ask whether the PFAS from the environment that are getting into people are causing a problem in people. After that, someone at an agency has to say that they have enough information to make a decision.

“I don't know what level of information is necessary for regulatory decision-making,” she said. “I don't know if it's a number of studies, if it's how many people are exposed, how many calls legislators are getting from constituents. I don't know what drives those decisions. Does anybody know what drives those decisions?”

Let’s hope regulators in California and elsewhere can catch up with the science and we can get some commonsense regulations for PFAS. The time is now.