Recently, as part of the Joint Subcommittee on Environment, Innovation, and Public Health, the PFAS Strategy Team of the National Science and Technology Council released a report titled the “Per- and Polyfluoroalkyl Substances (PFAS) Federal Research and Development Strategic Plan.”
The National Science and Technology Council (NSTC) is the principal means by which the executive branch coordinates science and technology policy across the diverse entities that make up the federal research and development (R&D) enterprise. Through the National Defense Authorization Act (NDAA) for Fiscal Year 2021, Congress directed an Interagency Working Group (IWG) to coordinate federal research on Per- and Polyfluoroalkyl Substances (PFAS).
In response, the Office of Science and Technology Policy (OSTP) developed the PFAS Strategy Team (PFAS ST) under the Joint Subcommittee on Environment, Innovation, and Public Health (JEEP) in late 2021. The PFAS ST coordinates interagency PFAS research and development activities and supports the development and implementation of the PFAS strategic research plan. The PFAS ST is co-chaired by OSTP, Department of Energy, and Department of Defense.
The Strategic Plan lays out five strategies, all of which have multiple “objectives” that focus on developing further data and science on exposure pathways, PFAS measuring and analytical capabilities, toxicological background, removal/disposal/destruction technologies, and PFAS alternatives.
“Strategy 1: Understand PFAS exposure pathways to individuals and communities PFAS are ubiquitous in outdoor and indoor environments due to their extensive uses, persistence in the environment, and limited prior control of PFAS releases due to a lack of data and technology.” According to the plan, to understand the prevalence of PFAS in our environment and how humans and biota can be exposed to PFAS, researchers need a more complete characterization of the presence, identity, and concentration of individual PFAS in the environment, including background (e.g., atmospheric deposition) levels. The authors note that studies are necessary for supporting a data-driven understanding of risks posed by PFAS exposure, and there is also a need to develop models that accurately predict the fate and behavior of PFAS where there are limited model training data.
“Strategy 2: Address current PFAS measurement challenges through the development of standards, advanced sampling and analytical methodologies.” The authors state that the analysis of PFAS in the environment, biological samples, and consumer products has driven the understanding of the fate and transport of PFAS contamination and sources of human exposure. There have been increasing numbers of PFAS that have been identified, often due to novel detection in samples or because of emerging toxicological information. The plan notes that these factors “create[] a moving target for PFAS analytical methods.” In addition, the plan states that advanced analytical techniques, like non-targeted analysis (NTA), require a different approach to the identification and quantification of PFAS in environmental and biological samples. “Occurrence and prevalence of novel PFAS identified through NTA coupled with expanded toxicological data can focus resources on the expansion of targeted analytical methods and availability of analytical-grade standards and certified reference materials. This approach would address the most critical needs for evaluating human and ecological exposures, modeling fate and transport, and contaminated site assessment and cleanup.”
The authors state that to achieve this, reference methods and materials are needed to standardize the use of NTA for PFAS identification. Further, the report notes that there is a significant need for analytical methodologies that are capable of precise and accurate measurement of PFAS at very low levels. “Novel analytical methods must be developed, or existing methods may require modifications, to accommodate additional analytes as the list of targeted PFAS expands, technology advances, and insight into toxicological effects of PFAS emerges.”
“Strategy 3: Understand the toxicological mechanisms, human and environmental health effects, and risks of PFAS exposure.” The authors state that the prior 2023 PFAS Report indicates that it is “impractical to assess the human and environmental hazards posed by each of the numerous PFAS that may exist in the environment using an individual, chemical by-chemical approach.” Other challenges to traditional experimental approaches include limited availability of appropriate analytical tests and standards, background levels, intrinsic physicochemical properties, and the lack of access to confidential business information. The plan states that “A holistic systems approach to understanding the risk of PFAS was proposed in the 2023 PFAS Report, leveraging new approach methodologies (NAMs), high-throughput technologies, and different data streams (i.e., human health studies, ecotoxicology, in silico models, and epidemiology studies).” The objectives laid out in the plan here are to (1) further characterize the toxicological mechanisms of action regarding PFAS exposure in humans, wildlife, and domestic animals, (2) understand the occurrence of adverse human health outcomes from PFAS exposure, and (3) support hazard identification and risk assessment for PFAS exposure to humans and ecosystems.
“Strategy 4: Develop, evaluate, and demonstrate technologies for the removal, destruction, and disposal of PFAS.” The authors write that the safe and environmentally friendly removal, destruction, and disposal of PFAS can be challenging because of the large number of PFAS, the stability of the carbon-fluorine bond, and the goal of reducing the PFAS contamination levels to those that are protective of human and environmental health. The report notes that “new research is needed to advance these technologies to field-ready technologies. In addition, removal, destruction, and disposal technology developers should consider tailored treatments for specific exposure pathways (e.g., air, water, soil, or biosolids) to find solutions for specific exposure pathways identified in the previous goals and objectives.” The report goes on to explain that media-specific technologies should consider effectiveness (e.g., soil cleanup thresholds to allow for agricultural production) and be implementable (e.g., cost effective) for the targeted media. This research can include in situ immobilization strategies that reduce the impact of PFAS contamination. The strategy team states that this goal aims to support the “1) continued development of novel, more efficient and effective technologies, and 2) implementation of technologies for field scale removal, destruction, and/or disposal of PFAS-contaminated materials.”
“Strategy 5: Identify PFAS alternatives and evaluate their human health and environmental effects.” According to the authors, PFAS alternatives largely fall into two categories: functional alternatives, which involve technical or engineering solutions to reduce the need for PFAS-containing materials, and chemical alternatives, which involve the replacement of PFAS with alternatives with lower toxicity and lesser persistence that impart a similar function in the manufacturing process or finished product. “To identify potential alternatives, the federal government should better understand the uses of PFAS in products and in the supply chain, the criticality of the uses, and physical and chemical properties required for those uses.” The authors state that R&D efforts to identify and reduce the use of PFAS have been conducted by a variety of government, industry, and academic institutions using literature, database, and quantitative structure-activity relationship models (QSARs); toxicological evaluations of PFAS alternatives; and transition to new products that have reduced adverse effects on human health and the environment.
In conclusion, the strategy team explains that the “successful implementation of this strategic plan will help strengthen and advance the state of the science to successfully address regulatory, scientific, and mitigation gaps and disproportionate exposure, contamination, and toxicity regarding PFAS.” The PFAS ST also recognizes that there are additional research needs that should be further explored, including the “socio-economic effect of PFAS contamination and remediation on specific populations, such as communities with environmental justice concerns, firefighters, and farmers, and medical interventions to prevent or reduce the severity of adverse health outcomes related to PFAS exposure” — (although these are outside the scope of this particular report).
The NDAA requires this strategic plan to be updated every three years; therefore, these areas could be considered in future updates of this plan.
