The Biden Administration recently announced new plans to further regulate polyfluoroalkyl substances, a class of chemicals generically known as PFAS. Such initiatives typically target pollutants that have been found in relatively high concentrations, especially when that pollutant is reactive. That is the case with chemicals like ethylene oxide, benzene, ozone, and a host of others. It's a bit different with PFAS. These are chemicals that are just barely detectable and are basically inert.
So why the fire drill? Are PFAS compounds a clear and present danger to the health and welfare of Americans? What is the best strategy to mitigate the PFAS threat to human health and the environment if they are? As important, how big of a threat are PFAS compounds to either?
It’s unlikely that we’ll ever get honest answers to those questions. The independent, rational, scientific traditions that encouraged critical thinking and informed disagreement is fading away in western civilization. In its place, we are increasingly subject to state-approved science formulated by armies of technocrats and administered by legions of bureaucrats. When the scientific method is eventually dead and buried, I have a suggestion for the epitaph to be engraved on its tombstone: “better safe than sorry.”
Those words concisely express the essence of the Precautionary Principle. The Precautionary Principle, in turn, is a bane of modern existence. It’s a societal plague that breeds cowardice, inhibits progress and encourages insularity in thought and in practice. It was probably inevitable that environmental organizations would eventually target these remarkable fluorinated compounds in another fit of excess caution.
To a chemist, fluorine is one of the most remarkable elements on the periodic table. It forms incredibly strong bonds with other atoms, giving PFAS chemicals their unique characteristics and their resiliency. The last is especially troublesome to the E.P.A. and environmental groups who have dubbed PFAS “forever chemicals.” The implication being that once created they are impossible to get rid of. That’s not entirely accurate, but it must be admitted that getting rid of PFAS compounds does take a bit more work than your run of the mill waste product.
Should we not be concerned about these "forever chemicals"? There's two parts to that question. First, does having a particular chemical in your system for a long time necessarily harm your system? The answer to that depends on the chemical and the dose. It would be fair to call silicon dioxide, what we commonly call sand, a “forever chemical” every bit as much as PFAS. Absent willful and energetic processing, sand is sand and will remain sand. So do we worry if we ingest some sand into our system? If it's not much and it's in our gastrointestinal system the body recognizes it as a waste, something it has no use for, and will pass it through the GI tract and colon to be eliminated.
I am not a biologist. So I do not know if PFAS compounds bioaccumulate in the body in part or in whole. If they do they certainly don't accumulate in substantial amounts. We can say that because when people have conducted studies and found PFAS in the water, in the air, and in the soil they find it in concentrations that are in the parts per trillion or less levels.
A part per trillion is an incredibly small concentration. It is the equivalent of 1 drop of water in enough water to fill 20 Olympic sized swimming pools. Twenty or thirty years ago we didn't even have the technology that would allow us to look at these extremely low concentrations. Are concentrations that low a significant threat to human health and the environment? I cannot answer that question definitively, but I don't think anyone else can do so either.
When the E.P.A. and environmental groups talk about PFAS they inevitably choose verbs that allow them to hedge their bets. Verbs like “may” and “could” and “suggests.” As in: “research suggests that these compounds may be associated with – fill name of your favorite scary disease – and that these effects may be more serious among the elderly and newborn children.”
Definitive verbs are to be avoided at all costs. Verbs like will or does or demonstrates. It takes years of indoctrination by the technocrats and the bureaucrats before they'll move up to definitive verbs. At that point the war is over and the scientists have lost. There was a time when "climate change" was discussed as a potential threat, as a hypothesis worth examining, but not as a proven fact. We are well beyond that point today. Every politician, every journalist, every representative of an environmental NGO talks about "climate change" in terms of certainty. They assure us that the science is settled. The E.P.A.'s PFAS Strategic Road Map puts us well on the way to settling this rather dubious bit of science as well.
I cannot assert that parts per trillion levels of these compounds are not a serious threat to human health and the environment. Nor can I assert they are. I doubt if there's any single scientist who can say one way or the other. I doubt there is anyone who can say pursuing this research is worth the cost compared to other priorities the E.P.A. might be pursuing. But I can predict the E.P.A. will follow its usual playbook: develop a large set of very restrictive rules, very expensive rules, whose cost will be justified by the theoretical reduction in the hospitalizations and death that will be assumed. Not proven. Assumed. That's what inevitably happens. At one point during the Obama administration E.P.A. director Lisa Jackson claimed so much savings from environmental regulations that we could have paid off the national debt had her numbers been accurate.
New rules are coming that will affect regulations covering water, covering land, covering the air, covering waste disposal, covering approval of new and existing chemicals. These rules will largely be developed by the technocrats and bureaucrats alone. Yes, once they're developed there will be comment periods and the various agencies will be flooded with comments. As a result of the comments there'll be a change here and a change there but really no substantive changes in direction. The rules are developed in an echo chamber where only cheerleaders are present. Only then are they presented to the public. No matter. Experience shows that what is finally approved will look much like whatever is first proposed.
It's possible this effort could become another bust like Alar, toxic mold, and endocrine disruptors. All of those crises du jour more or less went away after time. Maybe it will be the same with PFAS. But given the way that fantasies have materialized into so-called realities so quickly over the last few years I fear that massive investments in PFAS regulations, controls and clean-up will be a part of our lives for a long time to come.
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