PFOA and PFOS Designated as Hazardous Substances by EPA

In January of this year, a plan for a PFAS Superfund designation was proposed by the U.S. Environmental Protection Agency (EPA). Submitted to the White House's Office of Management and Budget (OMB), the plan follows the Agency's objective to categorize PFOA (Perfluorooctanoic acid) and PFOS (Perfluorooctanesulfonic acid) as hazardous substances.


Both PFOA and PFOS are part of the larger group of chemicals known as per- and polyfluoroalkyl substances (PFAS). The chemical composition of PFAS makes them highly resistant to degradation and contributes to their environmental persistence.


IUPAC Name2,2,3,3,4,4,5,5,6,6,7,7,8,8,8-pentadecafluorooctanoic acid
Chemical FormulaC8HF15O2
CAS Registry Number335-67-1


IUPAC Name1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,8-heptadecafluorooctane-1-sulfonic acid
Chemical FormulaC8HF17O3S
CAS Registry Number1763-23-1

While research continues to be conducted to understand the full range of hazards posed by PFAS, such chemicals are known to present a variety of human health risks. Among these are hypertension, kidney cancer, low birth weight and immunotoxicity (in children), testicular cancer, thyroid disease, and more.

Hazardous Substances Under CERCLA

The EPA’s plan aligns with the release last year of its PFAS Roadmap. It focuses on the Agency’s intent to classify PFOA and PFOS under the Superfund law (i.e., the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA)). CERCLA enables access to a "superfund" to clean up emergency environmental contaminant releases. It also allows the EPA to obligate responsible parties to clean up contaminated sites (or reimburse the Agency in cases where it conducts the cleanup efforts).

Classification of PFOA and PFOS as hazardous substances under CERCLA will have numerous implications for businesses and industries that use products containing them. The construction industry, for example, is at particularly high risk as these and other PFAS chemicals are found in many building materials and related products (including adhesives, flooring and roofing products, paints and other finishes, window surface materials, and a host of others).

Barring any significant opposition to the EPA's plan, final rule designation is expected by next year.

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