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Regulating PFAS as a Chemical Class under the California Safer Consumer Products Program
Summary
California's Department of Toxic Substances Control proposes regulating PFAS as a single chemical class in consumer products, because all PFAS share at least one hazard trait — environmental persistence — and key PFAS degradation products display additional toxicity. The study suggests this class-based regulatory approach is necessary to comprehensively address these widespread and persistent chemicals.
We at the California DTSC propose regulating certain consumer products if they contain any member of the class of PFAS because: a) all PFAS, or their degradation, reaction, or metabolism products, display at least one common hazard trait according to the California Code of Regulations, namely environmental persistence; and b) certain key PFAS that are the degradation, reaction or metabolism products, or impurities of nearly all other PFAS display additional hazard traits, including toxicity; are widespread in the environment, humans, and biota; and will continue to cause adverse impacts for as long as any PFAS continue to be used. Regulating PFAS as a class is thus logical, necessary, and forward-thinking. This technical position may be helpful to other regulatory agencies in comprehensively addressing this large class of chemicals with common hazard traits. https://doi.org/10.1289/EHP7431.