By Sam Lodge

Every five years, US EPA begins a cycle to update the UCMR, [1] the Unregulated Contaminant Monitoring Rule. This process, borne out of the Safe Drinking Water Act (SDWA), determines the list of new chemical contaminants that public water utility systems in the US have to monitor for the next five years—in other words, a list of new things to which water testers, water purifiers and water drinkers, need to be paying attention.Figure 1. US EPA flowchart on the UCMR process.

This process is one of a growing list of federal government initiatives that investigate the health risks of emerging compounds in the American water supply. The chemical group increasingly making up the lion’s share of US EPA’s Contaminant Candidate List (CCL) are a class of so-called forever chemicals—known scientifically as per-and polyfluoroalkyl substances or PFAS— that pose a health risk to humans and has an extremely long half-life in the environment, accumulating in water, air, fish, soil, even in deer and in humans.

The UCMR’s fourth cycle (also known as UCMR 4) wound down at the end of 2020, with announcements this year from US EPA listing the 30 currently unregulated contaminants it plans to monitor and study for the next five years. While UCMR 3[2] included six PFAS chemicals in its CCL of 30 chemicals to monitor, this year’s UCMR 5[3] has listed 29 PFAS compounds—out of the maximum of 30 chemicals that US EPA can list. That all but one chemical—lithium—listed belong to the same class is unprecedented in the history of the UCMR, highlighting the importance of monitoring these increasingly ubiquitous chemicals in our environment.

In recent years, there have been several new methods developed to identify and isolate these compounds at much lower levels than we’ve been able to test before. Meanwhile, new research is emerging about ways to destroy PFAS in the environment, as well as new PFAS alternatives. It’s clear that if we can do more to test, study, mitigate and ultimately eliminate the introduction of new PFAS, while we find ways to remove PFAS from public resources, we may be able to envision a new horizon for safety in water.

Testing: knowing the scope of the problem
Understanding where PFAS is appearing in the environment and its organisms—and tracking how exactly PFAS infects our water supply—are the first steps towards comprehending how big of a problem we have on our hands. Since the UCMR 3 ended almost nine years ago, the amount of information about the extent of PFAS contamination in water supplies has increased dramatically. So far, PFAS testing in industrial, military and academic settings has found this group of chemical compounds everywhere—including widespread occurence in rainwater and detectable in all major water supplies in the US.[4] A 2015 report by the Centers for Disease Control and Prevention’s National Health and Nutrition Examination Survey (NHANES) found PFAS in the blood of 97 percent of Americans.[5]

These insights emerged from the rapidly-accelerating field of PFAS analysis, driven by innovations in the methods and consumables we use to monitor and understand these compounds: PFAS testers now have new analytical processes applicable to a growing list of analytes, technology with increased sensitivity to detect PFAS in challenging new environmental matrices, including soil, wastewater and food, as well as significant new workflow improvements, which offer more rapid analysis coupled with higher accuracy and precision, leading to greater laboratory productivity.

US EPA requires labs monitoring PFAS in drinking water to perform solid phase extraction (SPE) to prepare a sample, followed by LC-MS/MS (liquid chromatography/ tandem mass spectrometry) analysis.[6] Recent advances have made SPE more efficient and more versatile. This sample preparation technique allows scientists to effectively clean up and concentrate samples prior to high performance liquid chromatography (HPLC) or gas chromatography (GC) analysis, giving scientists the ability to selectively target analytes of interest, work with a wide range of sample volumes and can be easily automated for high-throughput analysis. In the end, these innovations are giving labs higher-quality, more reliable results on PFAS in the US water supply.

In addition to innovations within the industry, federal agencies have also stepped up to test, measure and study PFAS in the environment. The recently passed bipartisan infrastructure bill additionally delivers more than $10 billion to address contaminants in drinking water, with PFAS occupying a central focus. In October 2021, US EPA announced a National PFAS Testing Strategy[7] that envisions new requirements on PFAS manufacturers, compelling them to provide the agency with toxicity data to better inform future regulatory efforts. According to the agency, the majority of PFAS currently in commerce has limited or no toxicity data, meaning widespread testing of PFAS by manufacturers would provide US EPA and other researchers with a much more comprehensive dataset.

New regulatory landscape
Scientific studies have indicated a number of worrying human health effects linked to the exposure to PFAS. They have been shown to increase the risk of cancer,[8] disrupt the development of a healthy fetus[9] and reduce the effectiveness of vaccines.[10] Biomonitoring studies by the Centers for Disease Control and Prevention (CDC) show that the blood of nearly all Americans is contaminated with PFAS.[11] Meanwhile, more than 600 PFAS compounds are still in industrial use,[12] involved in everything from coating textiles, paper products and cookware to formulating some firefighting foams and being used in aerospace, aviation, photographic imaging, semiconductor, electronics, automotive and construction companies.

Testing for PFAS has occupied the lion’s share of regulatory requirements for water utility systems, though the regulatory landscape is quickly evolving. Five years ago, US EPA issued a non-enforceable lifetime health advisory for PFOA and PFOS in drinking water of 70 ppt, though independent scientists have recommended a safe level for PFAS in drinking water of 1 ppt. Recent federal actions related to PFAS expand the scope and introduce stricter standards for PFAS regulation – for water, US EPA has announced plans for a national primary drinking water standard for PFOA and PFOS by fall of 2022 with the aim to finalize enforceable limits by the fall of 2023.[13]

In October 2021, US EPA Administrator Regan launched the PFAS Strategic Roadmap,[14] a commitment on actions to, “Control PFAS at its sources, hold polluters accountable, ensure science-based decision making, and address the impacts on disadvantaged communities.”[15]. In early October, the agency announced an upcoming petition[16] that would allow the agency to designate PFAS compounds as ‘hazardous constituents’ under the Resource Conservation and Recovery Act (RCRA), allowing for RCRA corrective action against heavily contaminated treatment, storage and disposal facilities, an onerous process with a stringent timeline and inflexible performance standards. It also is a necessary first step in PFAS compounds being considered hazardous waste and being handled as such.

In advance of federal regulations, states have stepped in to set legal limits or guidelines for PFAS in drinking water, including New Jersey, New York, Connecticut, California, Massachusetts, Michigan, Minnesota, New Hampshire, North Carolina and Vermont. In late November, Pennsylvania[17] became the latest state to pass maximum contaminant levels for PFAS contamination and pollution at 14 ppt for PFOA and 18 ppt for PFOS, much more strict than US EPA’s current Health Advisory Level (HAL) for PFAS at 70 ppt.

Envisioning a path forward
Experts doubt we can realistically eliminate all PFAS use in the short-term, simply because of the compound’s utility in resisting oil, heat and water. Firefighting foam known as aqueous film forming foams (AFFF) used to put out jet fuel fires at airports, for instance, requires PFAS to serve as surfactants, effectively distributing the foam across a highly flammable liquid fire, cooling and suppressing it. Despite its utility, AFFF is one of the most prolific contributors to PFAS in California’s water supply.
Figure 2. Scientist collecting samples.

In charting a path forward that retains some of the modern comforts we’ve grown used to (like non-stick pans, water-repellent hiking gear and stain-resistant fabrics and carpets), we must find a way to limit the introduction of new PFAS into the environment while simultaneously embarking on three key directives: searching for safer PFAS alternatives, studying new ways to break down PFAS in the environment and moving to restrict the use of PFAS when we have no other option. In the case of firefighting foam, the Federal Aviation Authority (FAA) has announced a new research effort to find a PFAS-free alternative, while also exploring technologies that can limit the PFAS discharges in the testing of firefighting equipment, both of which could bring about crucial innovations that could greatly contain our PFAS problem.

Even more promising, scientists are finding that PFAS can achieve near-complete destruction when oxidized in extremely pressurized, heated water–a state referred to as supercritical.[18] For now, however, the process has only been tested with a small number of PFAS compounds at small sites. Heating up and pressurizing water to supercritical levels, after all, requires inordinate amounts of energy at a large scale–but it offers new clues for researchers and a potential future lifeline for small water utility systems.

Conclusion
There was a moment wherein PFAS contamination seemed like a trade-off to modern life. The non-stick pans made for easy clean up, the airplanes ferried us wherever we’d like to go. But increasingly, the industry and its regulators are pouring money and attention towards a future without PFAS contamination, a future in which our tests return fewer and fewer PFAS parts per trillion. We can only hope for their success.

References
1. US EPA. Learn About the Unregulated Contaminant Monitoring Rule. https://www.epa.gov/dwucmr/learn-about-unregulated-contaminant-monitoring-rule
2. US EPA. The Third Unregulated Contaminant Monitoring Rule (UCMR 3): Data Summary, January 2017. https://www.epa.gov/sites/default/files/2017- 02/documents/ucmr3-data-summary-january-2017.pdf
3. US EPA. Revisions to the Unregulated Contaminant Monitoring Rule (UCMR 5) for Public Water Systems. https://www.epa.gov/sites/default/files/2021-01/documents/ucmr5-proposal-factsheet-draft.pdf
4. Environmental Working Group. PFAS Contamination of Drinking Water Far More Prevalent Than Previously Reported. https://www.ewg.org/research/national-pfas-testing/
5. Lewis, R., Johns, L. and Meeker, J., 2015. “Serum Biomarkers of Exposure to Perfluoroalkyl Substances in Relation to Serum Testosterone and Measures of Thyroid Function among Adults and Adolescents from NHANES 2011–2012.” International Journal of Environmental Research and Public Health, 12(6), pp.6098-6114.
6. US EPA. EPA PFAS Drinking Water Laboratory Methods. https://www.epa.gov/pfas/epa-pfas-drinking-water-laboratorymethods
7. US EPA. National PFAS Testing Strategy. https://www.epa.gov/assessing-and-managing-chemicalsunder-tsca/national-pfas-testing-strategy
8. Lerner, S., 2019. “Top U.S. toxicologist was barred from saying PFAS cause disease in humans. She’s saying it now.” The Intercept. https://theintercept.com/2019/10/24/pfas-toxicologist/
9. Environmental Working Group. PFAS and Developmental and Reproductive Toxicity: An EWG Fact Sheet. https://www.ewg.org/news-insights/news/pfas-and-developmental-and-reproductive-toxicity-ewg-fact-sheet
10. Environmental Working Group. PFAS Chemicals Harm the Immune System, Decrease Response to Vaccines, New EWG Review Finds. https://www.ewg.org/news-insights/news/pfaschemicals-harm-immune-system-decrease-response-vaccines-new-ewg-review
11. Centers for Disease Control and Prevention. Per-and Polyfluorinated Substances (PFAS) Factsheet. https://www.cdc.gov/biomonitoring/PFAS_FactSheet.html
12. Andrews, D. (2019, May 20). “INSIGHT: The Case for Regulating All PFAS Chemicals as a Class.” Bloomberg Law. https://news.bloomberglaw.com/environment-and-energy/insight-the-case-for-regulating-all-pfas-chemicals-as-a-class
13. Romero, J. (2021, November 9). “EPA Releases PFAS Strategic Roadmap.” JD Supra. https://www.jdsupra.com/legalnews/epa-releases-pfas-strategic-roadmap-8274164/
14. US EPA. PFAS Strategic Roadmap: EPA’s Commitments to Action 2021-2024. https://www.epa.gov/pfas/pfas-strategicroadmap-epas-commitments-action-2021-2024
15. US White House. FACT SHEET: Biden-Harris Administration Launches Plan to Combat PFAS Pollution. https://www.whitehouse.gov/briefing-room/statements-releases/2021/10/18/factsheet-biden-harris-administration-launches-plan-to-combat-pfas-pollution/
16. Acevedo, A., Fowler, S., Zarghamee, R. (2021, December 13). “Beyond the Roadmap: Additional PFAS Developments.” JD Supra. https://www.jdsupra.com/legalnews/beyond-the-roadmap-additional-pfas-5105652/
17. PennWatch. DEP Proposal to Set Stricter PFAS Limits Approved by Environmental Quality Board.
https://pennwatch.org/dep-%E2%80%8Bproposal-to-setstricter-pfas-limits-%E2%80%8Bapproved-by-environmentalquality-board/
18. Rosansky, S. (2021). “Applying Supercritical Water Oxidation to Destroy PFAS.” The Military Engineer, 113(731), 48–49. https://www.jstor.org/stable/27012886

About the author
Sam Lodge is the Phenomenex Senior Business Development Manager for the Environmental industry. He has served in many roles over his 28 years at Phenomenex, with the last four focused extensively on work with commercial and government labs that are developing and improving PFAS analytical methods. Lodge was instrumental in the collaborations that led to the development of several new SPE formats for PFAS, including stacked tubes and pass through GCB cartridges that can help commercial labs to increase productivity and reduce costs.

About the company
Phenomenex is a global technology leader committed to developing novel analytical chemistry solutions that solve the separation and purification challenges of researchers in industrial, clinical research, government and academic laboratories. From drug discovery and pharmaceutical development to food safety and environmental analysis, Phenomenex chromatography solutions accelerate science and help researchers improve global health and well-being. For more information please visit www.phenomenex.com and follow the company’s blog at www.scienceunfiltered.com.

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