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Correspondence July 2015 | Volume 123 | Issue 7

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Environ Health Perspect; DOI:10.1289/ehp.1510207

Comment on “Fluorotechnology Is Critical to Modern Life: The FluoroCouncil Counterpoint to the Madrid Statement”

Ian T. Cousins,1 Simona A. Balan,2 Martin Scheringer,3,4 Roland Weber,5 Zhanyun Wang,3 Arlene Blum,2,6 Miriam Diamond,7 Tony Fletcher,8 Gretta Goldenman,9 Christopher Higgins,10 Avery E. Lindeman,2 Graham Peaslee,11 Xenia Trier,12 and Pim de Voogt13

1Stockholm University, Stockholm, Sweden; 2Green Science Policy Institute, Berkeley, California, USA; 3ETH Zürich, Zürich, Switzerland; 4Leuphana University, Lüneburg, Germany; 5POPs Environmental Consulting, Schwäbisch Gmünd, Germany; 6University of California at Berkeley, Berkeley, California, USA; 7University of Toronto, Toronto, Ontario, Canada; 8London School of Hygiene & Tropical Medicine, London, United Kingdom; 9European Centre on Sustainable Policies for Human and Environmental Rights, Brussels, Belgium; 10Colorado School of Mines, Golden, Colorado, USA; 11Hope College, Holland, Michigan, USA; 12Technical University of Denmark, Kongens Lyngby, Denmark; 13University of Amsterdam, Amsterdam, the Netherlands

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Citation: Cousins IT, Balan SA, Scheringer M, Weber R, Wang Z, Blum A, Diamond M, Fletcher T, Goldenman G, Higgins C, Lindeman AE, Peaslee G, Trier X, de Voogt P. 2015. Comment on “Fluorotechnology is Critical to Modern life: The FluoroCouncil Counterpoint to the Madrid Statement.” Environ Health Perspect 123:A170;

Address correspondence to S.A. Balan, Green Science Policy Institute, P.O. Box 5455, Berkeley, CA 94705 USA. E-mail:

The authors declare they have no actual or potential competing financial interests.

Final Publication: 1 July 2015

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Fluorotechnology Is Critical to Modern Life: The FluoroCouncil Counterpoint to the Madrid Statement

Jessica S. Bowman

Response to “Comment on ‘Fluorotechnology Is Critical to Modern Life: The FluoroCouncil Counterpoint to the Madrid Statement’”

Jessica S. Bowman

We commend the FluoroCouncil for phasing out long-chain poly- and perfluoroalkyl substance (PFAS) chemistry. However, members of the FluoroCouncil have been producing long-chain PFASs for decades while in possession of research showing adverse health effects in humans and animals. This model of chemical manufacturing needs to change. We recommend implementing the principles of green chemistry (Anastas and Warner 1998) in chemical manufacturing to ensure safer and sustainable chemical products. The scientific consensus of the Madrid Statement authors and signatories is that the use of all PFASs is unsustainable, and can and should be greatly reduced and discontinued where feasible. Short-chain fluorinated alternatives were therefore intentionally included in the scope of the Madrid Statement.

Some of the functionalities provided by fluorotechnology have become part of modern life. However, we disagree that PFASs are critical to modern life. Sustainable and less hazardous alternatives are available for many functionalities, and others will be developed. PFAS-based chemistries are used in many nonessential applications such as clothing, sports equipment, food packaging materials, blooming and dispersion agents, and stain-repellant treatments. We urge the FluoroCouncil to provide as much information as possible on the PFAS chemistries used in different commercial products and technologies.

We are aware that short-chain perfluoroalkyl acids bioaccumulate less than long-chain ones. However, some short-chain PFASs have been linked to adverse biological effects (Bull et al. 2014), and further systematic, representative studies on additional end points are needed. Given the ongoing release and environmental persistence of short-chain acids, increasing environmental and human exposures such as those documented by Glynn et al. (2012) are expected, for example, via contaminated drinking water aquifers (Xiao et al. 2015). Thus, continuous release of short-chain PFASs can be expected to lead to poorly reversible internal exposures, regardless of their low bioaccumulation potential (Scheringer et al. 2014).

Bowman commented that the Madrid Statement cannot claim insufficient data on the hazards and risks of fluorinated alternatives. However, Wang et al. (2015) highlighted the specific data gaps that prohibit conducting hazard and risk assessments for many fluorinated alternatives. An assessment commissioned by the FluoroCouncil (ENVIRON International Corporation 2014) also identified many gaps regarding human health data.

Bowman stated that “decisions on the societal acceptability of strategic materials such as PFASs cannot be wisely made on a single attribute such as persistence.” However, persistent chemicals are unsustainable in a world with limited resources. We cannot afford to “lose” portions of resources (water, soil, or food) because potentially harmful and persistent chemicals are accumulating over centuries and causing continuous exposure. Because of their persistence, an enormous inventory of PFASs is being created: Even if all PFAS production and uses were to stop immediately, PFASs would continue to be released for decades during products’ use and disposal life-cycle phases (Wang et al. 2014a, 2014b). One of the 12 principles of green chemistry is “design for degradation: chemical products should be designed so that at the end of their function they break down into innocuous degradation products and do not persist in the environment” (Anastas and Warner 1998). We endorse this principle and urge the FluoroCouncil to follow it also.

We welcome collaboration with the FluoroCouncil to establish information-sharing platforms for PFASs and support all opportunities for dialogue. We ask the FluoroCouncil to take leadership and responsibility for the global management of the PFASs they produce, from manufacturing to end of life.


Anastas PT, Warner JC. 1998. Green Chemistry: Theory and Practice. New York, NY:Oxford University Press.

Bull S, Burnett K, Vassaux K, Ashdown L, Brown T, Rushton L. 2014. Extensive Literature Search and Provision of Summaries of Studies Related to the Oral Toxicity of Perfluoroalkylated Substances (PFASs), Their Precursors and Potential Replacements in Experimental Animals and Humans. Area 1: Data on Toxicokinetics (Absorption, Distribution, Metabolism, Excretion) in in Vitro Studies, Experimental Animals and Humans. Area 2: Data on Toxicity in Experimental Animals. Area 3: Data on Observations in Humans. EFSA Supporting Publication EN-572. Parma, Italy:European Food Safety Authority.

ENVIRON International Corporation. 2014. Assessment of POP Criteria for Specific Short-Chain Perfluorinated Alkyl Substances (Prepared for FluoroCouncil, Washington, DC). Arlington, VA:ENVIRON International Corporation.

Glynn A, Berger U, Bignert A, Ullah S, Aune M, Lignell S, et al. 2012. Perfluorinated alkyl acids in blood serum from primiparous women in Sweden: serial sampling during pregnancy and nursing, and temporal trends 1996–2010. Environ Sci Technol 46(16):9071–9079; doi: 10.1021/es301168c.

Scheringer M, Trier X, Cousins IT, de Voogt P, Fletcher T, Wang Z, et al. 2014. Helsingør Statement on poly- & perfluorinated alkyl substances (PFASs). Chemosphere 114:337–339; doi: 10.1016/j.chemosphere.2014.05.044.

Wang Z, Cousins IT, Scheringer M, Buck RC, Hungerbühler K. 2014a. Global emission inventories for C4–C14 perfluoroalkyl carboxylic acid (PFCA) homologues from 1951 to 2030, part I: production and emissions from quantifiable sources. Environ Int 70:62–75; doi: 10.1016/j.envint.2014.04.013.

Wang Z, Cousins IT, Scheringer M, Buck RC, Hungerbühler K. 2014b. Global emission inventories for C4-C14 perfluoroalkyl carboxylic acid (PFCA) homologues from 1951 to 2030, part II: the remaining pieces of the puzzle. Environ Int 69:166–176; doi: 10.1016/j.envint.2014.04.006.

Wang Z, Cousins IT, Scheringer M, Hungerbuehler K. 2015. Hazard assessment of fluorinated alternatives to long-chain perfluoroalkyl acids (PFAAs) and their precursors: status quo, ongoing challenges and possible solutions. Environ Int 75:172–179; doi: 10.1016/j.envint.2014.11.013.

Xiao F, Simcik MF, Halbach TR, Gulliver JS. 2015. Perfluorooctane sulfonate (PFOS) and perfluorooctanoate (PFOA) in soils and groundwater of a US metropolitan area: migration and implications for human exposure. Water Res 72:64–74; doi: 10.1016/j.watres.2014.09.052.

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