No chemical compound has presented the scale of exposure and potential industry-wide liability risk as per- and polyfluoroalkyl substances (PFAS). PFAS have been ubiquitous since the 1940s, and nearly all major industries have PFAS concerns in one way or another. The sheer scale of the issue is yet to be quantified; an increase in state and federal regulatory requirements and enforcement, as well as lawsuits concerning PFAS, are a near certainty.

Federal agency actions concerning PFAS have been relatively slow to develop in comparison to the actions already taken by some states. This is understandable, because there are thousands of compounds that meet the definition of PFAS¹ and no consensus on whether and how to make individualized determinations on which of these substances present a risk to health and safety. In evaluating at what level these compounds present a risk to the health of humans and animals, the federal Food and Drug Administration (FDA), U.S. Department of Agriculture (USDA), Consumer Product Safety Commission (CPSC), and Environmental Protection Agency (EPA) are focusing on three issues: bioaccumulation, persistence, and toxicity.