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Agrochemical toxicologist urges targeted action on clearly harmful PFAS, warns broad definitions would sweep in medicines and pesticides
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Summary
Dr. Pam Bridal, agrochemical toxicologist with the Agency of Agriculture, Food Markets, told lawmakers that pesticide regulation evaluates chemicals individually and urged focusing regulation on a small set of clearly harmful PFAS rather than broad structural definitions that could include medicines and benign compounds.
Dr. Pam Bridal, agrochemical toxicologist with the Agency of Agriculture, Food Markets, told a legislative panel that regulators should target a small number of PFAS with clear evidence of harm rather than adopt broad, structure-based definitions that would sweep in millions of substances.
Bridal said the pesticide regulatory system evaluates chemicals one by one and that ‘‘the harmful PFAS are not allowed in pesticides,’’ a point she tied to pesticide registration and reporting obligations under federal law. She urged lawmakers to prioritize rapid action on a limited set of PFAS with well-documented effects instead of spending time debating an expansive structural definition.
Why it matters: States and federal agencies are using different PFAS definitions — the OECD 'fully fluorinated carbon' formulation, EPA/TSCA definitions and several state approaches vary in wording and scope. Those differences produce large disparities in lists of chemicals described as PFAS: Dr. Bridal cited figures discussed in the panel ranging from roughly 1,200 commonly used PFAS to millions of possible structures under the broadest structural definitions. The practical effect, she said, is that overly broad language could classify everyday medicines and veterinary products as PFAS, complicating regulation and trade.
What Dr. Bridal said: She described three definitional approaches in play — the OECD formulation used in some state laws, the EPA/TSCA steps embedded in federal practice, and state-specific interpretations — and showed how small wording changes (for example, ‘‘a fully fluorinated carbon’’ versus ‘‘at least one fully fluorinated carbon atom’’) can change whether a chemical is captured.
Regulatory context: Bridal walked through pesticide registration requirements enforced under FIFRA, noting that pesticide manufacturers must list active and inert ingredients with EPA at registration and must report impurities of toxicological significance. She described required ecological and mammalian tests that accompany pesticide approvals — avian acute and dietary tests, aquatic invertebrate and fish early-life-stage studies, and multiple bee tests — and said that pesticide reviews use detailed data that many other industrial chemicals do not undergo under TSCA.
Examples and implications: Using examples discussed in the presentation, Bridal contrasted older long-chain PFAS such as PFOA and PFOS (linked in published studies to cardiovascular, liver and immune effects) with replacement chemistries such as GenX, which remain persistent and raise concern. She told the panel that different jurisdictions classify certain pesticide active ingredients differently (EPA lists six PFAS active ingredients, Maine listed 56 in its review, and Minnesota listed 93 under its broader approach), and she urged lawmakers to adopt ‘‘precise language’’ in statute to avoid unintended consequences.
On surfactants and inerts: Bridal said surfactants (ingredients that help pesticides spread) are sometimes raised as a concern but that current inert-ingredient databases and the EPA inert-list searches do not show evidence of long-chain PFAS surfactants widely used in approved pesticide products today. She also explained that while inert ingredients may be protected as trade secrets for public disclosure, EPA and state toxicologists can view confidential formulation details through secure processes.
Reporting and the fluorinated-container episode: The witness discussed a past problem involving fluorinated containers (the transcript cited a pesticide product 'Anvil 10' as the origin of a 'fluorinated container' issue) and asked whether EPA had received manufacturer reports about impurities related to that episode. She noted that, under FIFRA, registrants must notify EPA within 30 days if a distributed product differs from its registered composition or contains new impurities of toxicological significance.
Next steps: The panel paused the hearing for scheduled testimony and agreed to arrange a follow-up session so Bridal could continue a technical briefing, including material she said she had removed for time.
Quotes: "The harmful PFAS are not allowed in pesticides," Bridal said. She added that while broad structural definitions may list millions of possible PFAS, a focused approach aimed at the small number of PFAS with known risks would permit quicker regulatory action.
Ending: Lawmakers accepted Bridal's offer to return for further briefing and paused for a scheduled 10-minute break; the committee planned to check staff calendars to schedule the follow-up session.
