The Challenges of Regulating an Evolving Industry

 The Challenges of Regulating an Evolving Industry

by Michelle Taylor, Editor-in-Chief, Labcompare

In the last few years, PFAS has moved from an emerging contaminant to a regulated contaminant. With a 25 to 30% growth year over year, the next challenge is keeping up with PFAS testing needs and demands.

“In the future, commercial labs need to be able to answer questions in minutes—not days,” said Bharat Chandramouli, Product Director of North America at SGS. “Labs will need the ability to measure in the field at very low levels so answers can be found in real-time.”

SGS is the world’s leading testing, inspection and certification company. They operate a network of over 2,500 laboratories and business facilities across 115 countries, supported by a team of 99,500 dedicated professionals. As a recognized global leader in PFAS testing, SGS was chosen by the U.S. Environmental Protection Agency to develop and validate the benchmark reference method for PFAS testing, known as EPA 1633. In Europe, SGS has developed PFASafe, which is becoming the basis for forthcoming EU legislation.

As PFAS regulations and R&D continue to evolve on a seemingly everyday basis, Labcompare spoke to Chandramouli about what he experiences at the frontlines of PFAS analysis in SGS’s high-volume laboratories.

Labcompare: What are the biggest challenges right now in the detection and analysis of PFAS?
Chandramouli: We've come a long way in standardization on many of these methods. We now have standard methods available for 40-50 PFAS, depending on where you’re looking. The other good part is that we've all had more experience as an environmental community running PFAS so we have more people who are able to do routine testing

From a challenges perspective, we have coverage and standard methods available for maybe 60 compounds but that's still a very small percentage of what's actually out there that needs studying and measurement. Speed is another challenge. Labs are now getting to a point where we can provide information in 2 or 3 days, sometimes even less. But when you're in the field, you need almost immediate information—and that part is still a big challenge for everyone in the community. A third challenge is, even though we have a lot of capabilities across the community from a measurement perspective, PFAS measurement is still complex. For labs, being able to hire enough qualified people, being able to keep that training current, and being able to keep those systems going is quite challenging.

Labcompare: What are the challenges associated with trying to detect PFAS and legislate that detection when we're still learning how these compounds affect human health?
Chandramouli: We've looked at PFAS in a different paradigm compared with how we've looked at other contaminants. With a lot of other contaminants, we are regulating them as single contaminants, or groups of contaminants that are very closely linked. For example, if we look at its mercury, then it's mercury, but it's PCBs, they're all polychlorinated biphenys that share a structure and similar enough properties and toxicity concerns.

PFAS, meanwhile, are thousands of chemicals that all share a common carbon fluorine structure, so they can weigh anything from very short chain to long chains. Can you regulate PFAS as a class? That’s the big question. There's a lot of disagreement on that. In the absence of that, how do you regulate PFAS individually? In the U.S. the route we have taken is to regulate specific PFAS that we have more information and toxicity data on, like perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS). While there's still uncertainty, there's a lot more data on this subset of PFAS right now than anything else.

Meanwhile, Canada just came out with a federal guideline that said all small molecule PFAS meet a general definition of toxicity so they will all be regulated as a class. They made a class first approach. They have regulations for specific PFAS coming as well, but they made that additional distinction on class—that's not happening in the U.S.

Labcompare: Are there any other matrices that you think we'll see PFAS regulations in the future?
Chandramouli: We’re seeing increased attention on PFAS in air, primarily coming from the remediation end of things where you're trying to destroy or remediate PFAS in one way or the other. It’s not just generating solid or aqueous waste, we’re also looking at what's coming out of the stack. There’s guidance from the U.S. Department of Defense, for example, that says you have to measure this and that to understand PFAS levels. On a federal level, I don’t think PFAS in the air have gotten to that point of regulation yet. There are some state-level regulations, though. The indoor and industrial hygiene side of PFAS has not gotten involved either, so OSHA is not looking at PFAS yet. Thus far, the big movement has been on consumer products and source reduction.

Labcompare: I’ve heard you speak about the need for real-time PFAS detection in the field. How can we move toward that kind of a detection and analysis model?
Chandramouli: That’s a difficult question, but there's a lot of people working on it. The first question you need to answer is, “are you looking at specific PFAS or the entire universe?” If you're looking at specific PFAS, you can focus sensor technology on just those. If you're looking at all PFAS, that's a different approach. Both of these are being studied right now—which is exciting—but it's a wide variety of structures and properties. PFAS diversity is what makes this process very challenging.

Labcompare: Are there any research trends developing that you see as particularly exciting and innovative?
Chandramouli: Going from just looking at specific target PFAS into broader spectrum analysis, like high resolution mass spectrometry for non-targeted PFAS where you can measure not just these 40 PFAS, but here are the other hundreds of PFAS we detected in the sample and these are the structures. Non-targeted analysis has always been around but what has changed in the last 5 to 10 years is the instruments to enable non-targeted and forensic-level PFAS identification and reporting have gotten a lot better and more sensitive so we're able to do that at a lower level than we've been able to in the past. Importantly, those instruments have also gotten easier to use and more robust, meaning they work for longer periods of time without extensive maintenance.

The other big advancement is that software is getting better, and researchers are pulling more actionable information from the gigabyte of raw data that can be generated during analysis. All of this is without any AI or the other mega-trends that are developing, so it'll be interesting to see what we can do very soon when you combine these large data sets with high-quality instrumentation at a higher level—whether it's AI-enhanced or not, the intelligence is there to start mining that data for what it's worth because we might just be scratching the surface.

Labcompare: What advice would you give someone looking to start a PFAS laboratory?
Chandramouli: The most important thing you need to do is hire good people because everything flows from there—hire scientists who know what they're doing, who have a high attention to detail and are good at troubleshooting because PFAS analysis is complex.

Ten years ago, the instrumentation, automation and support were not there. Now, you have all of this—it’s easy to start a PFAS lab. You can even have an AI tell you exactly what you need to get started.

But from my experience of working with both internal and external labs, the greatest differentiator for good data quality is people. PFAS is one of those areas where a lot of your knowledge comes from experience. The more experience you get, the more you retain your staff, the better it's going to be. So get good people and let them stay and figure it out. The instrumentation and equipment part is a lot more standard. It’s people that are the biggest differentiator—the X factor.

About the interviewee: Bharat Chandramouli is a senior scientist with 20+ years of experience in the occurrence, fate, and transport of persistent organic pollutants and contaminants of emerging concern (CEC). He is a published author on several peer-review articles and book chapters on atmospheric chemistry, PFAS measurement, Pharmaceutical and Personal Care Product (PPCP) occurrence, semivolatiles fate and transport, and more. At SGS, Bharat manages the development of new products and services in North America, provides technical leadership on analytical methods, and coordinates between product development, sales, management, and clients to ensure that SGS services meets everyone’s needs.

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