PFAS reduction claims & efforts to expand the scope to other PFAS compounds
Prior to 2002, perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic (PFOS) acid, or PFAS chemicals, were being released into the environment, including water systems, as a byproduct of the manufacturing process of paper, cardboard food packaging, insecticides, electronics, stain repellants, paints, plumbing tape, firefighting foam and non-stick cooking surfaces. The widespread release of these chemicals contaminated the water supply near current and former manufacturing locations, oil refineries, airfields and other locations at which PFAS was manufactured or released. This poses a significant risk for local residents, as exposure to PFAS chemicals via drinking water can result in a myriad of negative health outcomes, including developmental effects to fetuses during pregnancy, cancer, increased cholesterol, and liver, immune and thyroid effects.
This, as well as international media attention in recent years related to issues of water quality and safety, caused local, state, federal and international organizations to begin to establish regulations on PFAS levels in water. This also created an immediate need for residential water treatment professional education on the ability to treat and test PFAS chemicals, as well as revised testing protocols and standards to ensure treatment technologies are effective at the levels necessary based on these new regulations.
Setting the Stage
PFOA and PFOS are part of a group of man-made chemicals commonly referred to as PFAS chemicals. In 2002, PFAS chemicals were voluntarily phased out of production in the U.S. by their primary manufacturer, and in 2006, eight major companies voluntarily decided to cease their global production of PFAS chemicals. Despite their discontinuation, substantial PFAS chemicals had already been released, causing water contamination in impacted areas.
In 2016, the U.S. EPA created a lifetime of exposure health advisory at 70 parts per trillion (ppt) for PFOA and PFOS in drinking water. Creating this advisory provided a margin of protection to those who are immunocompromised or in special populations, such as pregnant women, children and older adults.
At the bequest of regulatory agencies and manufacturers that wanted to restore public confidence and trust in the quality and safety of drinking water in contaminated areas, NSF International developed the PFOA and PFOS reduction test protocol to enable water treatment and filtration devices to be tested on their ability to reduce these chemicals. Following on the success of this protocol, the NSF Joint Committee on Drinking Water Treatment Units, consisting of stakeholders from industry, regulatory and user groups, adopted this protocol as an addition to the existing NSF/ANSI 53 and NSF/ANSI 58 standards.
The committee’s initial PFAS performance requirements were outlined in a protocol named NSF P473: Drinking Water Treatment Units – PFOS & PFOA, published in 2016. This protocol required devices to reduce PFAS concentrations in water to below the 70 ppt health advisory level set by the EPA. The protocol also required devices to comply with material and physical requirements of to achieve NSF International certification.
To earn NSF International certification to P473, water treatment systems, including water filters, were required to undergo extensive testing to confirm they meet the strict material safety and structural requirements of NSF/ANSI 53, an American National Standard for drinking water treatment units. Reverse osmosis systems must also meet all requirements of NSF/ANSI 58. With P473 now merged into NSF/ANSI 53 and NSF/ANSI 58, devices that are certified for PFOA and PFOS reduction have been tested to assure that:
- The contaminant reduction claims for PFOA and PFOS shown on the label are true.
- The system does not add anything harmful to the water.
- The system is structurally sound.
- The product labeling, advertising and literature are not misleading.
To make a PFAS reduction claim, a water filter must be able to reduce these chemicals to below the EPA healthy advisory limit of 70 ppt. NSF International-certified products must be retested periodically, and manufacturing facilities must be inspected every year, to monitor whether the products continue to meet all requirements.
How to Develop a Protocol
To establish a contaminant reduction protocol, the following elements are essential:
- Participation From Regulatory Agencies. Without regulatory levels set by appropriate authorities, the requirements of a contaminant reduction protocol could be viewed as arbitrary. It is the regulatory levels set by an appropriate authority that create legitimacy. Most often, these regulations are set by a federal regulatory agency such as the U.S. EPA or Health Canada. In some cases, the rapid pace of detection of contaminants has meant that state and local water departments have been issuing their own regulations and conducting their own tests.
- Commercially Available Contaminant Challenges. Testing facilities must be able to access and obtain the chemicals in sufficient quantity and purity at an affordable price.
- Occurrence Data. Testing facilities need to know how much PFAS is in water on average. This allows them to create tests that are reflective of what would occur in the real world. Without occurrence data, the challenge levels could be viewed as arbitrary.
- Proven Ability to Accurately and Reproducibly Test at Regulatory Levels. The test must be able to be conducted in the lab without error or issue. Stability of challenge water and the ability to analyze the results at low levels are often two hindrances to testing successfully.
Current Efforts to Expand the Scope to Other PFAS Compounds
State and local water departments have been developing and issuing new regulatory levels for other PFAS chemicals and sharing them with the international water community. As a result, this has created an opportunity for the NSF Drinking Water Treatment Unit Joint Committee to expand the scope of the NSF/ANSI 53: Drinking Water Treatment Units – Health Effects PFAS testing protocol to include additional PFAS contaminants, potentially including PFNA, PFHxS, HFPO-DA (Genex) and PFHpA. There is also discussion regarding the possibility of developing a total PFAS reduction claim. A task group working under the joint committee has been formed and began work on developing a combined contaminant challenge.
In order to be successful, the new testing protocol must be able to analyze compounds both individually and accurately. A validation study is currently underway. If successful, this would allow NSF/ANSI 53 to be expanded to include the ability to test for multiple PFAS compounds at the same time, as well as allowing certified water treatment and filtration products to use a “PFAS reduction” claim.
Doing so would allow manufacturers to verify the performance of their devices, which would in turn equip residential water treatment and filter professionals with the educational resources needed to educate consumers on this important issue when installing and repairing these devices in their homes. It also ensures that the water industry is united in its effort to continuously evolve as new safe regulatory levels are developed for contaminants in water and to be able to test and treat them in an accurate and timely manner.