Is trifluoroacetic acid another "forever chemical" on the rise?
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:
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. otwaddell@goldbergsegalla.com
Medicare conditional payment fundamentals and ensuring compliance
Oliver E. Twaddell is a partner in Goldberg Segalla’s Toxic Tort/Environmental and Commercial Litigation practice groups. otwaddell@goldbergsegalla.com
CLM’s Environmental and Toxic Tort Committee focuses on existing and emerging issues in the environmental, pollution, and mass tort context. This encompasses long-tail claims as well as claims submitted on currently issued policies.
