Trifluoroacetic acid (TFA) is a breakdown product of several hydrochlorofluorocarbons (HCFC). It is regulated under the Montreal Protocol (MP), and hydrofluorocarbons (HFC) are used mainly as refrigerants.
TFA is (1) produced naturally and synthetically, (2) used in the chemical industry, and (3) a potential environmental breakdown product of a large number (>1 million) chemicals, including pharmaceuticals, pesticides, and polymers.
In 2016, the Environmental Protection Agency (EPA) stated that the “formation of TFA derived from degradation of HCFC and HFC warrants continued attention, in part because of a long environmental lifetime and due many other potential but highly uncertain sources.”
TFA has a smaller molecular structure than PFAS and is also mobile and water soluble. Currently, however, it appears that EPA does not define TFA as a PFAS and there is disagreement over whether it should be so classified, with some in industry saying that it is not a PFAS because in part it is “naturally occurring.”
It is not a chemical that is monitored in drinking water, and studies have tested and found TFA presence to be common in various environmental media, including surface water. Some say that the most effective filtration method for smaller chemicals like TFA is reverse osmosis, which is more expensive than other traditional treatment methods. If at some point this is a chemical that must be filtered out of drinking water, presently installed treatment methods for PFAS may not be sufficient.
A study published recently suggested governmental action “as soon as possible.”
“Rapidly increasing TFA concentrations, coupled with TFA’s extreme persistence, mobility, and the possibility of irreversible impacts, should prompt action to reduce emissions of TFA and its precursors,” the study said.
Some findings and statements from this study are worth noting:
- TFA is by far the most abundant PFAS in the environment.
- In recent years, interest in TFA has been reestablished due to rapidly increasing concentrations observed in remote locations, as well as its ubiquity in drinking water sources and human blood.
- Since the 1990s, it has been suggested that hazard-related concerns of TFA and other short-chain PFAAs are much lower than those of PFAAs with longer perfluoroalkyl chains, which are more bioaccumulative and generally more toxic. However, these early reports did not consider TFA’s ubiquitous accumulation in the environment, in particular its observed accumulation in water resources and bioaccumulation in various plants, including crops.
- Although there are fewer toxicological data compared to long-chain PFAAs, we maintain that there are more than sufficient data to conclude that TFA poses a risk to humans and the environment and meets the criteria of a planetary boundary threat for novel entities.
- The study states that it presents risk evidence based on TFA’s (1) increasing planetary exposure, which is (2) irreversible and increasing due to emissions from many sources and could thereby cause (3) long-lasting disruptive effects on human health and vital earth system processes.
The study’s conclusion finds that “policy, industry initiatives, and innovation actions should be enacted globally to reduce TFA emissions as soon as possible to protect future generations from potential irreversible effects of TFA accumulation.”
This article originally appeared on Goldberg Segalla LLP. https://www.goldbergsegalla.com/
About the Author:
Oliver E. Twaddell is a partner at Goldberg Segalla LLP.