The undersigned organizations urge you to consider additional public input regarding underpinning science and associated approaches for developing possible categories to regulate per-and polyfluoroalkyl substances (PFAS). We support EPA’s commitment in the recent PFAS Roadmap to follow the science and are pleased that the agency indicated that it would not regulate PFAS as a class. This aside, the National PFAS Testing Strategy was released in October 2021. These test orders were issued far in advance of the Agency’s PFAS categorization framework that we view as essential to a logical pursuit of test orders to obtain data critical for informing the Agency about PFAS hazards, exposure, and risk. Furthermore, the strategy and test orders were developed and submitted without feedback from the impacted industries and without the scientific assessment and advice of the SAB and BOSC.
To assist with the SAB and BOSC review, the business community provides the following concepts and factors essential for the soundest scientific and technical groupings of PFAS chemistries into categories. These concepts and factors are intended to provide suggestions that will scientifically support a sound framework that regulators can use in evaluating whether and when to group substances for a variety of regulatory purposes. The list identifies questions regulators should address when examining whether and when grouping may be appropriate, even if different answers are reached for different substances or situations. These grouping principles include considerations identified by multiple sources and are consolidated here to provide a broad view of relevant issues when evaluating grouping substances, not just PFAS for regulatory purposes. Source identification appears at the end of the document in Appendix 1.