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. 2025 May;133(5):55002.
doi: 10.1289/EHP15995. Epub 2025 May 16.

Obtaining and Evaluating Information on the Use, Release, and Health Effects of Two Types of Long-Chain PFAS Used as Alternatives for Legacy Long-Chain Perfluoroalkyl Acids: A Case Study

Gloria B Post  1
Affiliations

Obtaining and Evaluating Information on the Use, Release, and Health Effects of Two Types of Long-Chain PFAS Used as Alternatives for Legacy Long-Chain Perfluoroalkyl Acids: A Case Study

Gloria B Post. Environ Health Perspect. 2025 May.

Abstract

Background: Short-chain per- and polyfluoroalkyl substances (PFAS) that are less bioaccumulative have been introduced as replacements for long-chain perfluoroalkyl acids (PFAAs) with the intent of reducing health risks. In contrast, alternative PFAS with longer chain lengths may be at least as bioaccumulative and toxic as phased-out long-chain PFAAs. Such alternative PFAS were used and released unbeknownst to regulatory authorities or the public, causing environmental contamination of public health concern.

Objective: The objective was to examine issues encountered in learning about use, release, and toxicity of alternative PFAS and to demonstrate development of human health benchmarks for alternative PFAS from previously unavailable health effects information.

Discussion: Environmental contamination with chloroperfluoropolyether carboxylates (ClPFPECAs) near a New Jersey fluoropolymer manufacturing facility was revealed through a joint New Jersey Department of Environmental Protection (NJDEP)-United States Environmental Protection Agency (USEPA) Office of Research and Development study. Previously unavailable information on use, release, and toxicity of ClPFPECAs and another alternative PFAS, perfluoropolyether dicarboxylates, was obtained through an NJDEP legal directive requiring submission of information on such PFAS used in the state. It was learned that the facility discharged large amounts of these alternative PFAS to air and water for many years, both before and after use of long-chain PFAAs ended, and that they are at least as bioaccumulative and toxic in rats as long-chain PFAAs. Additionally, information from exposed workers shows that ClPFPECAs have a human half-life of several years and are associated with numerous health end points. Reference doses and water concentrations protective of chronic drinking water exposure for these alternative PFAS are below those developed by NJDEP for long-chain PFAAs. The use and release of alternative PFAS described herein created concerning human health risks, unknown to regulatory authorities and the public. Such situations in other locations must be identified to allow for regulatory intervention and prevented in the future. https://doi.org/10.1289/EHP15995.

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Figures

Figure 1 depicts the chemical structures of chloroperfluoropolyether carboxylates (ClPFPECAs) and perfluoropolyether dicarboxylates (PFPE-DCAs), alternative PFAS used at the Solvay facility in West Deptford, New Jersey. According to information provided by Solvay, Solvay's chloroperfluoropolyether carboxylate products contain six congeners with 8 to 17 carbon atoms, 0 or 1 ethyl (e), and 2 to 4 propyl (p) groups. Information provided by Solvay indicates that their perfluoropolyether dicarboxylate products contain nine congeners with 9 to 12 carbon atoms, 0 to 4 “A” units and 1 to 4 “B” units.
Figure 1.
General structures of alternative PFAS used at Solvay facility in West Deptford, New Jersey. Six ClPFPECA congeners with 8–17 carbon atoms and containing 0 or 1 ethyl (e) and 2–4 propyl (p) groups and nine PFPE-DCA congeners with 9–12 carbon atoms and containing 0–4 (A) units and 1–4 (B) units are acknowledged by Solvay to be present in their products (Table S6). See Table S6 for additional information on the individual congeners. Note: ClPFPECA, chloroperfluoropolyether carboxylates; PFAS, per- and polyfluoroalkyl substances; PFPE-DCA, perfluoropolyether dicarboxylates.
Figure 2 is a timeline of events related to use of PFAS at the Solvay facility in West Deptford, NJ. Three events relate to the timeframe for use of PFAS at the facility: Event 1: In 1991 to 2010, Surflon S-111 (perfluorononanoic acid and other long chain perfluoroalkyl acids) was utilized as a processing aid in the manufacturing of fluoropolymer (polyvinylidene fluoride) and released into the environment at the Solvay facility. Event 2: In 1996 to 2021, alternative per- and polyfluoroalkyl compounds were utilized as processing aids in the synthesis of a fluoropolymer (polyvinylidene fluoride) and emitted into the environment at the Solvay site. Event 3: In 2021, use of PFAS as processing aids at the Solvay facility ended, and a “PFAS-free” process for fluoropolymer production began. Four events relate to health effects studies of the alternative PFAS. Event 1: In 1996, an industry-sponsored study determining that the lethal dose to 50 percent of animals for chloroperfluoropolyether carboxylates in rats is significantly lower than the previously reported rat lethal dose to 50 percent of animals for perfluorooctanoic acid. Event 2: In 2005, an industry-sponsored repeated dose study showed that perfluoropolyether dicarboxylates cause low dose toxicity in rats. Event 3: In 2006, an industry-sponsored repeated dose study showed that chloroperfluoropolyether carboxylates cause low dose toxicity in rats. Event 4: In 2011, a study of workers exposed to chloroperfluoropolyether carboxylates began. The results of this study, which showed that chloroperfluoropolyether carboxylates have a half-life of several years and reassociated with several health endpoints, were submitted to the United States Environmental Protection Agency in 2019. Four events relate to information on environmental occurrence of PFAS used at the facility from studies conducted by the New Jersey Department of Environmental Protection and the United States Environmental Protection Agency Office of Research and Development. Event 1: In 2009, a study performed by the New Jersey Department of Environmental Protection detected perfluorononanoic acid in public drinking water wells near the Solvay site at the highest level reported in drinking water worldwide. Event 2: In 2013, the New Jersey Department of Environmental Protection discovered that the Solvay facility was the source of perfluorononanoic acid in the local drinking water wells. Event 3: In 2017, the New Jersey Department of Environmental Protection and the United States Environmental Protection Agency Office of Research and Development began a study that detected chloroperfluoropolyether carboxylates in soil, water, and plants near Solvay with non-target analysis. Event 4: In 2021, the US Environmental Protection Agency’s Office of Research and Development identified per- and polyfluoroalkyl chemicals believed to be generated from monomer (vinylidene fluoride) in wastewater from a “per- and polyfluoroalkyl substances-free” process. Three events relate to information provided by Solvay to the New Jersey Department of Environmental Protection or the United States Environmental Protection Agency. Event 1: In 2019, Solvay provided annual use and release data, as well as toxicity studies for chloroperfluoropolyether carboxylates and perfluoropolyether dicarboxylates, to the New Jersey Department of Environmental Protection as confidential business information, in accordance with the Department’s legal directive. Solvay also provided the United States Environmental Protection Agency with the results of a worker study on chloroperfluoropolyether carboxylates, which began in 2011. Event 2: In 2022, Solvay reports to the New Jersey Department of Environmental Protection that it has detected chloroperfluoropolyether carboxylates and perfluoropolyether dicarboxylates in soil and groundwater near the site. Event 3: In 2024, Solvay provides analytical standards for chloroperfluoropolyether carboxylates and perfluoropolyether dicarboxylates to the United States Environmental Protection Agency’s Office of Research and Development, commercializes chloroperfluoropolyether carboxylates standards, and makes previously confidential information on alternative PFAS available to the public. Five events relate to NJDEP regulations, guidance, and legal actions regarding PFAS used at facility. Event 1: In 2015, the New Jersey Department of Environmental Protection established an interim specific groundwater quality standard of 10 nanograms per liter for perfluorononanoic acid. Event 2: In 2018, the New Jersey Department of Environmental Protection adopted a Maximum Contaminant Level (enforceable drinking water standard) of 13 nanograms per liter for perfluorononanoic acid, the first MCL for any per- and polyfluoroalkyl chemical in the United States. Event 3: In 2020, the state of New Jersey filed a lawsuit against Solvay to compel the company to remedy per- and polyfluoroalkyl substances pollution at its facility. Event 4: In 2021, the New Jersey Department of Environmental Protection creates an interim specific groundwater quality standard of 2 nanograms per liter for chloroperfluoropolyether carboxylates. Event 5: In 2024, the settlement of the State of New Jersey’s 2020 lawsuit requires Solvay to remediate per- and polyfluoroalkyl compound contamination from its facility in a timely manner and compensate the public for natural resource damages. A concentration of perfluoropolyether dicarboxylates of 2 nanograms per liter is defined as the benchmark for contaminated groundwater.
Figure 2.
Timeline of events related to use of PFAS at Solvay facility in West Deptford, NJ. Event are color-coded as follows: Pink, timeframe for use of PFAS at facility; yellow, health effects studies of alternative PFAS; green, information on environmental occurrence of PFAS used at facility from NJDEP and USEPA ORD studies and evaluations; orange, information on alternative PFAS provided to NJDEP or USEPA by Solvay; blue, NJDEP regulations, guidance, and legal actions related to PFAS used at facility. Note: Surflon S-111 was used at the facility by the previous owner (Arkema) from 1985 to 1990 (see https://www.syensqo.com/sites/g/files/alwlxe161/files/2025-02/20250122_Meeting-Boards.pdf). However, information on the amounts used and released are not available for years prior to 1991 (see Table S1). CBI, confidential business information; ClPFPECAs, chloroperfluoropolyether carboxylates; LD50, lethal dose to 50% of animals; MCL, maximum contaminant level (enforceable drinking water standard); NJDEP, New Jersey Department of Environmental Protection; PFAA, perfluoroalkyl acid; PFAS, per- and polyfluoroalkyl substances; PFNA, perfluorononanoic acid; PFPE-DCAs, perfluoropolyether dicarboxylates; PVDF, polyvinylidene fluoride; USEPA ORD, United States Environmental Protection Agency Office of Research and Development; VDF, vinylidene fluoride.
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