As a part of the US Environmental Protection Agency (EPA)’s PFAS Strategic Roadmap, the agency has issued the first in a series of Toxic Substances Control Act (TSCA) test orders to require companies to conduct and submit testing on per- and polyfluoroalkyl substances (PFAS). 

EPA selected 6:2 fluorotelomer sulfonamide betaine (CASRN 34455-29-3) as the first order issued under the National PFAS Testing Strategy. The foam has been manufactured (defined to include importing) in significant quantities (more than 25,000 pounds in a given year) according to TSCA Chemical Data Reporting (CDR) rule reports.

This chemical substance is a surface-active agent used to make commercial fire-fighting foams and may be found in certain floor finishes. CDR data also indicate that at least 500 workers in a given year could be potentially exposed to this chemical. Although there is some hazard and exposure information about this PFAS, EPA said it found insufficient data to determine the effects on human health associated with the inhalation route of exposure. This test order will address this data need.

The Chemours Company, DuPont De Nemours Inc., National Foam Inc., and Johnson Controls Inc. are the recipients of this first test order. The companies subject to the test order have been instructed to conduct the tests as described in the order, including testing of physical-chemical properties and health effects following inhalation, or provide EPA with existing information that they believe EPA did not identify in its search for existing information. EPA said it encourages companies to jointly conduct testing to avoid unnecessary duplication of tests. 

Based on available information and predictive models, testing on 6:2 fluorotelomer sulfonamide betaine will also inform the agency’s understanding of the human health effects of 503 additional PFAS with similar structures as detailed in the Testing Strategy.

“For far too long, families across America, especially those in underserved communities, have suffered from PFAS. High-quality, robust data on PFAS helps EPA to better understand and ultimately reduce the potential risks caused by these chemicals,” said EPA Administrator Michael S. Regan. 

“Our communities deserve transparency from the companies that use or produce these substances about their potential environmental and human health impacts.”