Inside EPA reports that six North Carolina-based NGOs, represented by a prior EPA Deputy Administrator and Senior Policy Counsel, think EPA should modify its incredibly ambitious PFAS road map to include toxicity testing of 47 PFAS that aren't directly covered by EPA's ambitious plan.

Some of you know my concern that EPA has already bitten off more than it can chew in the time that it has given itself.  See, e.g., (October 18, 2021).

I expect the harsh criticisms of EPA's ambitious PFAS road map by these North Carolina environmental advocates sting the EPA Administrator, a North Carolina native who was previously the Secretary of the North Carolina Department of Environmental Quality.

Based on the Inside EPA report, the NGOs seem to appreciate the daunting task EPA faces -- individually assessing almost 3000 PFAS at the same time with any scientific rigor is, of course, impossible.   

Now the NGOs and their former EPA official lawyer are certainly entitled to their own opinions regarding the most efficient way to get from here to determining how PFAS should be regulated nationally, both in commerce, and after they have entered our environment.

But it has to be up to EPA and its current leadership to determine the best national PFAS strategy consistent with what is actually possible, as opposed to what the advocates might wish was possible.   And, if the people of North Carolina decide that doesn't work for them, I guess they're free to join the growing number of states that have decided they can't or won't wait for EPA and are implementing PFAS plans of their own.

Sussman says it would be “unprecedented” to gather meaningful data on thousands of PFAS from the 24 representative chemicals EPA has named so far. “Remember that, according to the petition response, the 24 substances for which testing will be required are ‘expected to provide data that can be extrapolated to 2,950 PFAS that belong to the same categories’ as the 24 substances,” he says. “This level of extrapolation is unprecedented to my knowledge and the degree of uncertainty is very large given the small database on which it would be based.”