Approaches to addressing PFAS ▸ Class-based approaches • With 9,000 PFAS, we can never assess or regulate 1 at a time • When is it appropriate to treat PFAS as a single class or subgroups? ▸ ”Essentiality” (Cousins et al. 2019) • What uses of PFAS are truly essential? • Which uses can be phased out that are not essential ? ▸ Extreme persistence and mobility as basis for concern • EU considering “very persistent very mobile” under REACH criteria • Together, these alone form basis for concern
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