August 24, 2023

EPA Orders Three Companies to Conduct PFAS Testing

EPA has ordered Chemours, DuPont, and 3M to conduct testing on 2,3,3,3-Tetrafluoro-2-(heptafluoropropoxy)propanoyl fluoride (HFPO-DAF), a substance used in chemical manufacturing. The agency’s action is the third “test order” issued under EPA’s national testing strategy for per- and polyfluoroalkyl substances, or PFAS. HFPO-DAF, a replacement for perfluorooctanoic acid (PFOA), is also used in the production of nonstick coatings, stain repellents, and other products. According to EPA, exposure to HFPO-DAF potentially presents hazards for acute toxicity, skin corrosion, serious eye damage, skin sensitization, genetic toxicity, specific target organ toxicity, and carcinogenicity.

“We still don’t know enough about the dangers that many PFAS might pose to human health,” said Michal Freedhoff, EPA’s assistant administrator for the Office of Chemical Safety and Pollution Prevention. “We’re using all the tools at our disposal to rapidly gather data about these substances so that we can better understand the potential environmental and human health impacts of PFAS and take any necessary steps to address them.”

Test orders are issued for substances that EPA determines to present an unreasonable risk of injury to health or the environment; about which too little information exists to predict their effects on health or the environment; or for which testing is necessary to develop this information. For HFPO-DAF, EPA is requiring tests related to the physical and chemical properties of the substance as well as health effects from dermal exposure.

The agency previously ordered testing for two other PFAS: 6:2 fluorotelomer sulfonamide betaine, a component of firefighting foam, and HFPO, which is used in the manufacture of plastics.

Companies subject to test orders must either conduct testing as specified by EPA or submit existing information about the substance that the agency may not have considered.

For more information, see the EPA press release and national PFAS testing strategy. The test order for HFPO-DAF is available for download (PDF), and related documents can be found on The agency’s website provides a full list of EPA test orders.

Related: Read about challenges related to researching and managing exposures to PFAS and how the substances complicate the work of product stewards.