United States
Environmental Protection
^^LhI M lk Agency

Office of Water	EPA822P24001

Office of Science and	December 2024

Technology

DRAFT Human Health
Ambient Water Quality Criteria:

Perfluorooctanoic Acid (PFOA) and Related

Salts

R F R F F, F O

-xWV

FFFFFFFF


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Acknowledgements

This document was prepared by the Health and Ecological Criteria Division, Office of Science
and Technology, Office of Water (OW) of the U.S. Environmental Protection Agency (EPA).

The OW scientists and managers who provided valuable contributions and direction in the
development of these recommended water quality criteria are, from OST: Brandi Echols, PhD;
Casey Lindberg, PhD; Czarina Cooper, MPH; Brittany Jacobs, PhD; Carlye Austin, PhD; Kelly
Cunningham, MS (formerly OST); Erica Fleisig; Susan Euling, PhD; and Colleen Flaherty, MS; and,
from the Office of Research and Development (ORD): Jason Lambert, PhD.


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Table of Contents

1	Introduction: Background and Scope	1

2	Problem Formulation	2

2.1	Uses and Sources of PFOA	3

2.2	Environmental Fate and Transport in the Environment	4

2.3	Occurrence and Detection in Sources Relevant to Ambient Water Quality

Criteria	4

2.3.1	Occurrence in Surface Water	4

2.3.2	Occurrence in Freshwater and Estuarine Fish and Shellfish	5

3	Criteria Formulas: Analysis Plan	6

4	AWQC Input Parameters	8

4.1	Exposure Factor Inputs	8

4.1.1	Body Weight	8

4.1.2	Drinking Water Intake Rate	9

4.1.3	Fish Consumption Rate	9

4.2	Bioaccumulation Factor (BAF)	10

4.2.1	Approach	10

4.2.2	Data Selection and Evaluation	12

4.2.3	BAFs for PFOA	13

5	Selection of Toxicity Value	15

5.1	Approach	15

5.2	Toxicity Value for PFOA	17

5.2.1	Reference Dose	17

5.2.2	Cancer Slope Factor	18

6	Relative Source Contribution (RSC) Derivation	19

6.1	Approach	19

6.2	Summary of Potential Exposure Sources of PFOA Other Than Water and
Freshwater and Estuarine Fish/Shellfish	20

6.2.1	Dietary Sources	20

6.2.2	Food Contact Materials	22

6.2.3	Consumer Product Uses	23

6.2.4	Indoor Dust	24

6.2.5	Ambient Air	25

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6.2.6 Summary and Recommended RSC for PFOA	25

7	Criteria Derivation: Analysis	27

7.1	AWQC for Noncarcinogenic Toxicological Effects	28

7.2	AWQC for Carcinogenic Toxicological Effects	28

7.3	AWQC Summary for PFOA	29

8	Consideration of Noncancer Health Risks from PFAS Mixtures	30

9	Chemical Name and Synonyms	31

10	References	32

Appendix A: Bioaccumulation Factor (BAF) Supporting Information	46

Appendix B: Comparative Analysis for Potentially Sensitive Populations for PFOA	51

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1 Introduction: Background and Scope

The U.S. Environmental Protection Agency's national recommended ambient water quality
criteria (AWQC) for human health are scientifically derived numeric values that define ambient
water concentrations that are expected to protect human health from the adverse effects of
individual pollutants in ambient water.

Section 304(a)(1) of the Clean Water Act (CWA) requires the EPA to develop and publish, and
from time-to-time revise, recommended criteria for the protection of water quality that
accurately reflect the latest scientific knowledge. Water quality criteria for human health
developed under section 304(a) are based solely on data and scientific judgments about the
relationship between pollutant concentrations and human health effects. Section 304(a) criteria
do not reflect consideration of economic impacts or the technological feasibility of meeting
pollutant concentrations in ambient water.

The EPA's recommended section 304(a) criteria provide technical information for states and
authorized Tribes3 to consider and use in adopting water quality standards that ultimately
provide the basis for assessing water body health and controlling discharges of pollutants into
waters of the United States. Under the CWA and its implementing regulations, states and
authorized Tribes are required to adopt water quality criteria to protect the designated uses of
waters (e.g., public water supply, aquatic life, recreational use, industrial use). The EPA's
recommended water quality criteria do not substitute for the CWA or regulations, nor are they
regulations themselves. Thus, the EPA's recommended criteria do not establish legal rights or
obligations or impose legally binding requirements and are not final agency actions. States and
authorized Tribes may adopt, where appropriate, other scientifically defensible water quality
criteria that differ from these recommendations. EPA's water quality standards regulation at 40
CFR 131.20(a) requires states and authorized Tribes to consider any new or updated national
section 304(a) recommended criteria as part of their triennial review process, and, if the state
or authorized Tribe does not adopt new or revised criteria for parameters that correspond to
those new or revised 304(a) criteria, to provide an explanation when it submits its triennial
review to EPA. This requirement is to ensure that state or Tribal water quality standards reflect
the current science and protect applicable designated uses.

The water quality criteria that are the subject of this document are draft national AWQC
recommendations for human health issued under CWA section 304(a). Unless expressly
indicated otherwise, all references to "human health criteria," "criteria," "water quality
criteria," "ambient water quality criteria recommendations," or similar variants thereof are
references to draft national AWQC recommendations for human health.

a Throughout this document, the term states means the 50 states, the District of Columbia, the Commonwealth of
Puerto Rico, the Virgin Islands, Guam, American Samoa, and the Commonwealth of the Northern Mariana Islands.
The term authorized Tribe or Tribe means an Indian Tribe authorized for treatment in a manner similar to a state
under CWA section 518 for the purposes of section 303(c) water quality standards.


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Perfluorooctanoic acid (PFOA) is a member of the per- and polyfluoroalkyl substances (PFAS)
class. PFAS are a large class of thousands of synthetic chemicals that have been in use in the
United States and around the world since the 1940s (EPA, 2018). The ability for PFAS to
withstand heat and repel water and stains makes them useful in a wide variety of consumer,
commercial, and industrial products, and in the manufacturing of other products and chemicals.
The current scientific evidence has shown the potential for harmful health effects after human
exposure to certain PFAS. The persistence and resistance to hydrolysis, photolysis, metabolism,
and microbial degradation of PFAS raise additional concerns about long-term exposure and
human health effects.

The EPA developed the draft human health criteria (HHC) PFOA to reflect the latest scientific
information for input values, including exposure factors (i.e., body weight [BW], drinking water
intake [DWI] rate, and fish consumption rate [FCR]), bioaccumulation factors (BAFs), human
health toxicity values (i.e., reference dose [RfD] or cancer slope factor [CSF]), and relative
source contribution (RSC). The draft criteria are based on the EPA's current Methodology for
Deriving Ambient Water Quality Criteria for the Protection of Human Health (EPA, 2000a), which
is referred to as the "2000 Methodology" in this document (EPA, 2000a).

2 Problem Formulation

Problem formulation provides a strategic framework for ambient water quality criteria
development to systematically identify the major factors and chemical-specific scientific issues
to be considered in the assessment (EPA, 2014a). The structure of this draft criteria document is
intended to be consistent with general concepts of health assessments as described in the
EPA's Framework for Human Health Risk Assessment to Inform Decision Making (EPA, 2014a).

In developing AWQC, the EPA follows the assessment method outlined in the 2000
Methodology (EPA, 2000a). The 2000 Methodology describes different approaches for
addressing water and nonwater exposure pathways to derive human health AWQC depending
on the toxicological endpoint of concern, the toxicological effect (noncarcinogenic or
carcinogenic), and whether toxicity is considered a linear or threshold effect. Water sources of
human exposure include both consuming drinking water and eating fish or shellfish from inland
and nearshore water bodies that have been contaminated with pollutants. For pollutants that
exhibit a threshold of exposure before deleterious human health effects occur, as is the case for
noncarcinogens and nonlinear carcinogens, the EPA applies an RSC. The RSC is the percentage
of the total exposure to a contaminant that is attributed to the combination of drinking water
and eating freshwater and estuarine fish and shellfish, where the remainder of exposure is
allocated to other sources of oral exposure and other routes of exposure. The RSC is calculated
by examining the data for other sources of exposure (e.g., air, food, soil) and pathways of
exposure following the exposure decision tree for calculation of an RSC described in the 2000
Methodology (EPA, 2000a).

For carcinogenic substances for which the cancer slope factor was quantified using linear low-
dose extrapolation, only the exposures from drinking water and fish ingestion are reflected in
human health AWQC; that is, nonwater sources are not explicitly included, and no RSC is

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applied (EPA, 2000a). This is because in these situations, AWQC are derived with respect to the
incremental lifetime cancer risk posed by the presence of a substance in ambient water, rather
than an individual's total risk from all exposure sources. Therefore, the resulting AWQC
represents the ambient water concentration that is expected to increase an individual's lifetime
risk of cancer from exposure to the pollutant by no more than one chance in one million (10~6)
for the general population (male and female adults, 21 years and older; referred to as "general
population" herein), regardless of the additional lifetime cancer risk due to exposure, if any, to
that substance from other sources. The EPA calculates AWQC at a 10"6 cancer risk level for the
general population (EPA, 2000a). The 2000 Methodology recommends that states set human
health criteria cancer risk levels for the target general population at either 10"5 or 10"6and also
notes that states and authorized Tribes can choose a more stringent risk level, such as 10"7.

For substances that are carcinogenic, the EPA takes an integrated approach by considering both
cancer and noncancer effects when deriving AWQC (EPA, 2000a,b). Where sufficient data are
available, the EPA first derives separate AWQC for both carcinogenic and noncarcinogenic
toxicity endpoints and then selects the lower (more health protective) of the two values for the
recommended AWQC.

PFOA may exist in multiple forms, such as isomers or associated salts and each form may have a
separate Chemical Abstracts Service registry number [CASRN] or no CASRN at all. Additionally,
these compounds have various names under different classification systems. PFOA is a strong
acid that is generally present as the perfluorooctanoate anion at typical environmental pH
values. Therefore, this assessment applies to all isomers of PFOA, as well as nonmetal salts of
PFOA that would be expected to dissociate in aqueous solutions of pH ranging from 4 to 9. For
the purpose of this assessment, "PFOA" will signify the ion, acid or any nonmetal salt of PFOA.

2.1 Uses and Sources of PFOA

PFAS are manufactured chemicals that have been widely used in industrial and consumer
processes and products over the past several decades in the United States due to their
repellant and surfactant properties. PFAS are persistent chemicals based on their
physicochemical properties. Concerns about persistence of PFAS stem from the resistance of
these compounds to hydrolysis, photolysis, metabolism, and microbial degradation.

PFOA is a synthetic, fully fluorinated, organic acid that is used in many types of consumer
products and in the production of fluoropolymers (EPA, 2016a,b). PFOA is also formed by
microbial, metabolic and abiotic degradation of many precursor chemicals. PFOA and its
precursors have been used in flame repellents, cosmetics, paints, polishes, and processing aids
used in the manufacture of nonstick coatings on cookware. It is one of a large group of
perfluoroalkyl substances that are used in consumer and industrial products, etc. to improve
their resistance to stains, grease, and water (Gaines, 2023). In 2006, EPA initiated the
2010/2015 PFOA Stewardship Program, resulting in major PFOA producers committing to a 95%
reduction in PFOA facility emissions and product contents across the globe by 2010. The
2010/2015 PFOA Stewardship Program further aimed to eliminate PFOA emissions and product
content by 2015 (EPA, 2006, 2023a). The EPA has found widespread PFOA contamination in

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water, sediments, and soils. Exposure to PFOA can occur through food including fish and
shellfish, house dust, air, and contact with consumer products.

2.2	Environmental Fate and Transport in the Environment

Under most environmental conditions PFOA in water rapidly dissociates into ionic components.
In aquatic environments, the sorption of PFOA to sediments varies based on the amount of
organic carbon present and other site-specific conditions; the range of log(Kd)b values reported
in the literature for PFOA in sediments is -0.7 to 4.9 (EPA, 2024a). Because of its water
solubility and preferential binding to proteins, once PFOA enters a waterbody it can remain
dissolved in the water column, sorb to organic particulate matter, or be assimilated by
organisms. In the water column, and other environmental compartments, PFOA is stable and
resistant to hydrolysis, photolysis, volatilization, and biodegradation (NCBI, 2024; Lange et al.
2006). The persistence of PFOA has been attributed to the strong carbon-fluorine (C-F) bond.

2.3	Occurrence and Detection in Sources Relevant to Ambient Water Quality Criteria

PFOA has been detected in a variety of environmental matrices. The occurrence and detection
of PFOA in sources relevant to ambient water quality criteria, including ambient water, fish and
shellfish, is described below. Additional occurrence information for sources other than ambient
water (e.g., air, food, soil) is summarized in Section 6.2 as part of the determination of the RSC.

2.3.1 Occurrence in Surface Water

Among the PFAS with established analytical methods for detection, PFOA (along with
perfluorooctane sulfonic acid [PFOS]) is one of the dominant PFAS compounds detected in
ambient water in the United States and worldwide (Ahrens, 2011a; Benskin et al., 2012; Dinglasan-
Panlilio et al., 2014; Nakayama et al., 2007; Remucal, 2019; Zareitalabad et al., 2013). Most of the
current, published PFOA occurrence studies have focused on a handful of broad geographic
regions in the United States, often targeting sites with known manufacturing or industrial uses of
PFAS such as the Great Lakes, the Cape Fear River, and waterbodies near Decatur, Alabama
(Boulanger et al., 2004; Hansen et al., 2002; Konwick et al., 2008; Nakayama et al., 2007; 3M,
2000). PFOA concentrations in global surface waters range over seven orders of magnitude,
generally in picogram per liter (pg/L) to nanogram per liter (ng/L) concentrations, but sometimes
reaching microgram per liter (|_ig/L) levels (Jarvis et al., 2021; Zareitalabad et al., 2013).

PFOA concentrations in surface water tend to increase with increasing levels of urbanization.
Across the Great Lakes region, PFOA was higher in the downstream lakes (Lake Erie and Lake
Ontario), which are more heavily impacted by urbanization, and lower in the upstream lakes
(Lakes Superior, Michigan, and Huron), which are located in relatively rural and forested areas
(Remucal, 2019). Similarly, Zhang et al. (2016) found measured surface water PFOA
concentrations in urban areas (urban average PFOA concentration = 10.17 ng/L; n = 20) to be
more than three times greater than concentrations in rural areas (rural average PFOA
concentration = 2.95 ng/L; n = 17) within New Jersey, New York, and Rhode Island. Seasonal
variations in PFOA levels in U.S. surface waters remain largely unknown due to a lack of data.

b Log(Kd) is the logarithm of the equilibrium dissociation constant.

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2.3.2 Occurrence in Freshwater and Estuarine Fish and Shellfish

PFOA has been detected in freshwater fish fillet samples collected during several national
studies in rivers and the Great Lakes; however, PFOA is reported at a lower frequency and at
lower levels compared to other PFAS, including PFOS (Table 1). The EPA collaborates with
federal agencies, states, Tribes, and other partners to conduct freshwater fish contamination
studies as part of a series of statistically based surveys to produce information on the condition
of U.S. lakes, streams, rivers, and coastal waters. The National Oceanic and Atmospheric
Administration (NOAA) recorded 159 data points available for aquatic organisms in the National
Status and Trends Data Portal for PFOA focusing on dreissenid mussel and other mussels,
oyster, fish fillet, and fish liver samples. There were six detections reported, ranging from
0.33 ng/g wet weight (ww) to 75.1 ng/g ww; 153 were below the method detection limit (MDL)
or not detected (NOAA, 2024).

Table 1. Summary of the EPA national freshwater fish tissue monitoring results for PFOA.

Reference

Most Commonly
Sampled Species

Site Description

Results

2008-2009 National

Smallmouth bass

162 urban river sites

No PFOA detections

Rivers and Streams

Largemouth bass

across the United States

reported.

Assessment (NRSA)

Channel catfish





(Stahl et al., 2014)







2013-2014 NRSA

Channel catfish

349 urban and nonurban

PFOA detected in 4% of

(EPA, 2020, 2023b)

Largemouth bass

river sites across the

fillet samples.



Smallmouth bass

United States

Maximum detected
concentration 0.27 ng/g.

2018-2019 NRSA (EPA,

Channel catfish

290 urban and nonurban

PFOA detected in 2% of

2023c,d)

Smallmouth bass

river sites across the

fillet samples. Maximum



Largemouth bass

United States

detected concentration
0.354 ng/g.

2010 National Coastal

Lake trout

157 nearshore sites

PFOA detected in 12% of

Condition Assessment

Smallmouth bass

along the U.S. shoreline

fillet samples.

(NCCA) Great Lakes

Walleye

of the Great Lakes

Maximum detected

Human Health Fish





concentration 0.97 ng/g.

Tissue Study (Stahl et







al., 2014)







2015 NCCA Great Lakes

Lake whitefish

152 nearshore sites

PFOA detected in 14% of

Human Health Fish

Yellow perch

along the U.S. shoreline

fillet samples.

Tissue Study (EPA,

Lake trout

of the Great Lakes

Maximum detected

2021, 2024c)

Walleye



concentration 1.93 ng/g.

2022 National Lakes

Largemouth Bass

413 sampled lakes within

PFOA was detected in < 1%

Assessment (EPA,

Rainbow Trout

the contiguous U.S.

of samples (0.98%).

2024d)

Bluegill

(excluding The Great

Maximum detected



Yellow Perch

Lakes, Great Salt Lake

concentration: 1.55 ng/g;



Black Crappie

and lakes which are
tidally influenced).

median < MDL
(0.152 ng/g).

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In addition, Penland et al. (2020) measured PFAS concentrations in invertebrates and
vertebrates along the Yadkin-Pee Dee River in North Carolina and South Carolina. PFOA was
detected in whole body tissues of unionid mussels (7.41 ng/g ww) and aquatic insects
(10.68 ng/g ww), but was not detected in Asian clam, snails, or crayfish. PFOA was measured in
muscle tissue of 2 out of 11 sampled fish species: the channel catfish (21.19 ng/g ww) and
notchlip redhorse (45.66 ng/g ww).

3 Criteria Formulas: Analysis Plan

Human health AWQC for toxic pollutants may be necessary to protect designated uses of water
bodies related to ingestion of water (i.e., public water supply or source water protection) and
ingestion of freshwater/estuarine fish and shellfish. See CWA 303(c)(2)(A)-(B). Although the
AWQC are based on chronic health effects data (both cancer and noncancer effects), the
criteria are intended to also be protective against adverse effects that may reasonably be
expected to occur as a result of elevated acute or short-term exposures (EPA, 2000a). Human
health AWQC are expected to provide adequate protection not only for the general population
over a lifetime of exposure, but also for sensitive life stages and subpopulations who, because
of high water- or fish intake rates, or because of biological sensitivities, have an increased risk
of receiving a dose that would elicit adverse effect (EPA, 2000a).

The derivation of human health AWQC requires information about both the toxicological
endpoints of concern from exposure to water pollutants and human exposure pathways for
those pollutants. The EPA only considers the following two primary pathways of human
exposure to pollutants present in a particular water body when deriving human health 304(a)
AWQC: (1) direct ingestion of drinking water obtained from the water body and
(2) consumption offish and shellfish obtained from the water body.

The equations for deriving human health AWQC are presented as Equations (Eqs.) 1 and 2 for
noncancer and nonlinear carcinogenic effects, and Eqs. 3 and 4 for linear carcinogenic effects.
The EPA derives two separate recommended human health AWQC based on 1) the
consumption of both water and aquatic organisms (Eq. 1), called "water + organism"; and 2) the
consumption of freshwater/estuarine fish and shellfish (Eq. 2), called "organism only." The use
of one criterion over the other depends on the designated use of a particular water body or
water bodies (i.e., drinking water source and/or fishable waters). The EPA recommends
applying organism-only AWQC (Eq. 2) to a water body where the designated use includes
supporting fishable uses under section 101(a) of the CWA but the water body is not a drinking
water supply source (e.g., nonpotable estuarine waters that support fish or shellfish for human
consumption) (EPA, 2000a).

The EPA recommends including the drinking water exposure pathway for ambient surface
waters where drinking water is a designated use for the following reasons: (1) drinking water is
a designated use for surface waters under the CWA, and therefore, criteria are needed to
ensure that this designated use can be protected and maintained; (2) although they are rare,
some public water supplies provide drinking water from surface water sources without
treatment; (3) even among the majority of water supplies that do treat surface waters, existing

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treatments might not be effective for reducing levels of particular contaminants; and (4) in
consideration of the agency's goals of pollution prevention, ambient waters should not be
contaminated to a level where the burden of achieving health objectives is shifted away from
those responsible for pollutant discharges and placed on downstream users that must bear the
costs of upgraded or supplemental water treatment (EPA, 2000a).

The equations for deriving the criteria values are as follows (EPA, 2000a):

Equations for Noncancer and Nonlinear Carcinogen HHC:

Consumption of water and organisms:

AWQC = RfD x RSC x BW x l.QQQc
DWI + £f=2 (FCRi x BAFi)

For consumption of organisms only:

AWQC = RfD x RSC x BW x 1.0QQC
Yj\=2 (FCRi x BAFi)

Where:

AWQC = ambient water quality criteria, expressed in micrograms per liter (|-ig/L)
RfD = reference dose, expressed in milligrams per kilogram-day (mg/kg-d)
RSC = relative source contribution, unitless
BW = body weight, expressed in kg
DWI = drinking water intake, expressed in L/d

2j!2 = summation of values for aquatic trophic levels (TLs), where the letter /' stands for the

TLs to be considered, starting with TL 2 and proceeding to TL 4
FCRi = fish consumption rate for aquatic TLs (i) 2, 3, and 4, expressed in kg/d
BAFi = bioaccumulation factor for aquatic TLs (i) 2, 3, and 4, expressed in L/kg

Equations for Linear Carcinogens HHC:

Consumption of water and organisms:

AWQC = RSD x BW x 1,QQQC

DWI +£f=2 (FCRi x BAFi)

For consumption of organisms only:

AWQC = RSD x BW x 1.000c
S?=2 (FCRi x BAFi)

(Eq. 1)

(Eq.2)

(Eq. 3)

(Eq. 4)

c 1,000 ng/mg is used to convert the units of mass from milligrams to micrograms.

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Where:

AWQC = ambient water quality criteria, expressed in micrograms per liter (|ag/L)

RSD = RSD = risk specific dose; the cancer risk level (i.e., a target risk for the population; 1 in
1 million or 10"6) divided by the cancer slope factor (i.e., incidence of cancer relative to
dose in units of [mg/kg/day]"1), expressed in milligrams per kilogram-day (mg/kg-d)
BW = body weight, expressed in kg
DWI = drinking water intake, expressed in L/d

2j!2 = summation of values for aquatic trophic levels (TLs), where the letter /' stands for the

TLs to be considered, starting with TL 2 and proceeding to TL 4
FCRi = fish consumption rate for aquatic TLs (i) 2, 3, and 4, expressed in kg/d
BAFi = bioaccumulation factor for aquatic TLs (i) 2, 3, and 4, expressed in L/kg

The EPA rounds AWQC to the number of significant figures in the least precise parameter as
described in the 2000 Methodology (EPA, 2000a, Section 2.7.3). The EPA used a rounding
procedure that is consistent with the 2000 Methodology (EPA, 2000a) and the 2015 HHC
update (https://www.epa.gov/wqc/human-health-water-quality-criteria-and-methods-toxics).

4 AWQC Input Parameters
4.1 Exposure Factor Inputs

National recommended HHC establish ambient concentrations of pollutants in waters of the
United States which, if not exceeded, will protect the general population from adverse health
impacts from those pollutants due to consumption of aquatic organisms (i.e., freshwater and
estuarine fish and shellfish) and water (EPA, 2000a). It is the EPA's longstanding practice to set
national recommended HHC at a level intended to be adequately protective of a human
exposure over a lifetime (EPA, 2000a). To accomplish this, the EPA uses a combination of
median values, mean values, and percentile estimates for the HHC inputs consistent with the
EPA's 2000 Methodology. The EPA's assumptions afford an overall level of protection targeted
at the high end of the general adult population (i.e., the target population or the criteria-basis
population) (EPA, 2000a). This approach is reasonably conservative and appropriate to meet
the goals of the CWA and the 304(a) criteria program (EPA, 2000a). If the EPA determines that
another population of life stage (e.g., pregnant women and their fetuses, young children) is the
target then exposure parameters for that target population or life stage could be considered in
the derivation of the criteria (EPA, 2000a). Potentially sensitive life stages for PFOA are explored
further in a comparative analysis in Appendix B.

4.1.1 Body Weight

The BW for the general adult population including males and females, ages 21 years and older,
was selected for the PFOA HHC, consistent with the population selected in the agency's most
recent major update to existing 304(a) HHC (EPA, 2015) and the EPA's 2000 Methodology (EPA,
2000a). The EPA used the mean weight for adults ages 21 and older of 80.0 kg, based on
National Health and Nutrition Examination Survey (NHANES) data from 1999 to 2006 as
reported in Table 8.1 of the EPA's Exposure Factors Handbook (EPA, 2011), the EPA's most
recent publication of body weight exposure factors.

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4.1.2	Drinking Water Intake Rate

For adults ages 21 years and older, the EPA used an updated DWI of 2.3 L/d, rounded from
2.345 L/d. This DWI was estimated using the Food Commodity Intake Database consumption
calculator (http://fcid.foodrisk.org) which is based on NHANES 2005-2010 data used to develop
the EPA's Exposure Factors Handbook Update to Chapter 3, Ingestion of Water and Other Select
Liquids (EPA, 2019, Section 3.3.1.1). This rate represents the per capita estimate of combined
direct and indirect community waterd ingestion at the 90th percentile for adults, males and
females, ages 21 and older. The EPA selected the per capita rate for the updated DWI because
it represents the average daily dose estimates; that is, it includes both people who drank water
during the survey period and those who did not, which is appropriate for a national-scale
assessment such as the development of CWA section 304(a) national human health criteria
development (EPA, 2019, Section 3.2.1). The updated DWI of 2.3 L/d reflects the latest scientific
knowledge in accordance with CWA 304(a)(1).

The EPA's selection of the DWI of 2.3 L/d is consistent with the 2000 Methodology's selection of
a default rate based on per capita community water ingestion at the 86th percentile for adults
surveyed in the U.S. Department of Agriculture's 1994-1996 Continuing Survey of Food Intake
by Individuals (CSFII) analysis (EPA, 2000a, Section 4.3.2.1).

4.1.3	Fish Consumption Rate

The FCR used for the general adult population is 22.0 g/d, or 0.0220 kg/d (EPA, 2014b, Table
9a). This FCR represents the 90th percentile per capita consumption rate of fish from inland and
nearshore waters for U.S. adults ages 21 years and older based on NHANES data from 2003-
2010. The 95% confidence interval (CI) of the 90th percentile per capita FCR is 19.1 g/d and
25.4 g/d.

As recommended in the 2000 Methodology, the EPA used TL-specific FCRs to better represent
human dietary consumption offish. An organism's trophic position in the aquatic food web can
have an important effect on the magnitude of bioaccumulation of certain chemicals. The TL-
specific FCRs are numbered 2, 3, and 4, and they account for different categories offish and
shellfish species based on their position in the aquatic food web: TL 2 accounts for benthic filter
feeders; TL 3 accounts for forage fish; and TL 4 accounts for predatory fish (EPA, 2000a).

The EPA used the following TL-specific FCRs to derive the AWQC: TL 2 = 7.6 g/d (0.0076 kg/d)
(95% CI [6.4, 9.1] g/d); TL 3 = 8.6 g/d (0.0086 kg/d) (95% CI [7.2, 10.2] g/d); and TL 4 = 5.1 g/d
(0.0051 kg/d) (95% CI [4.0, 6.4] g/d). Each TL-specific FCR represents the 90th percentile per
capita consumption rate of fish and shellfish from inland and nearshore waters from that
particular TL for U.S. adults ages 21 years and older (EPA, 2014b, Tables 16a, 17a, and 18a). The
sum of these three TL-specific FCRs is 21.3 g/d, which is within the 95% CI of the overall FCR of

d Community water includes direct and indirect use of tap water for household uses and excludes bottled water
and other sources (EPA, 2019, Section 3.3.1.1). Direct ingestion is defined as direct consumption of water as a
beverage, while indirect ingestion includes water added during food preparation (e.g., cooking, rehydration of
beverages) but not water intrinsic to purchased foods (EPA, 2019, Section 3.1).

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22.0 g/d. The EPA recommends using the TL-specific FCRs when deriving AWQC; however, the
overall FCR (22.0 g/d) may be used if a simplified approach is preferred.

4.2 Bioaccumulation Factor (BAF)

4.2.1 Approach

Several attributes of the bioaccumulation process are important to understand when deriving
national BAFs for use in developing national recommended section 304(a) AWQC. First, the
term bioaccumulation refers to the uptake and retention of a chemical by an aquatic organism
from all surrounding media, such as water, food, and sediment. The term bioconcentration
refers to the uptake and retention of a chemical by an aquatic organism from water only. In
some cases, experiments conducted in a lab that measure bioconcentration can be used to
estimate the degree of bioaccumulation expected in natural conditions. However, for many
chemicals, particularly those that are highly persistent and hydrophobic, the magnitude of
bioaccumulation by aquatic organisms can be substantially greater than the magnitude of
bioconcentration. In these cases, an assessment of bioconcentration alone underestimates the
extent of accumulation in aquatic biota. Accordingly, the EPA guidelines presented in the 2000
Methodology (EPA, 2000a) emphasize using, when possible, measures of bioaccumulation as
opposed to measures of bioconcentration (EPA, 2000a).

The EPA estimated BAFs for the draft PFOA AWQC using the 2000 Methodology (EPA, 2000a)
and the associated Technical Support Document Volume 2: Development of National
Bioaccumulation Factors (Technical Support Document, Volume 2) (EPA, 2003). Specifically,
these documents provide a framework for identifying alternative procedures to derive national
TL-specific BAFs for a chemical based on the chemical's properties (e.g., ionization and
hydrophobicity), metabolism, and biomagnification potential (EPA, 2000a, 2003). As described
in the 2000 Methodology, the purpose of the EPA's national BAF is to represent the long-term,
average bioaccumulation potential of a chemical in aquatic organisms that are commonly
consumed by humans throughout the United States (EPA, 2000a). The EPA evaluated results
from field BAF and laboratory bioconcentration factor (BCF) studies on aquatic organisms
commonly consumed by humans in the United States for use in developing national trophic-
level BAFs. National BAFs are not intended to reflect fluctuations in bioaccumulation over short
periods (e.g., a few days) because human health AWQC are generally designed to protect
humans from long-term (lifetime) exposures to waterborne chemicals (EPA, 2003).

The EPA followed the approach described in Figure 3-1 of the Technical Support Document,
Volume 2 (EPA, 2003). The EPA used the best available data to classify each chemical according
to this framework, and to derive the most appropriate BAFs following the 2000 Methodology
(EPA, 2000a) and Technical Support Document, Volume 2 (EPA, 2003). Best available data
consisted of peer-reviewed literature sources, government reports, and professional society
proceedings, when sufficient information was provided to indicate the quality and usability of
the data.

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The framework provides six procedures to calculate a national BAF based on the pollutant's
physical and chemical properties. Each procedure contains a hierarchy of the BAF derivation
methods (listed below); however, this hierarchy should not be considered inflexible (EPA,
2000). The four methods are:

1.	BAF Method. This method calculates national TL-specific BAFs using water and fish and
shellfish tissue concentration data obtained from field studies. Field-measured BAFs are
calculated by dividing the concentration of a contaminant in an organism by the
concentration of that contaminant in the surrounding water.

For nonionic organic chemicals, BAFs are normalized to allow a common basis for
averaging BAFs from several studies by adjusting for the water-dissolved portions of the
chemical.

In order to calculate representative TL-specific national BAFs used to calculate national
recommended 304(a) criteria, the EPA averaged multiple field BAFs using a geometric mean
of the normalized BAFs, first by species and then by TL, to calculate the TL baseline BAFs.

2.	BSAF Method. This method uses biota-sediment accumulation factors (BSAFs) to estimate
bioaccumulation. While BAFs are calculated by dividing the concentration of a
contaminant in an organism by the concentration of the contaminant in water, BSAFs
divide the concentration in the organism by the concentration in surrounding sediments.
BSAFs are useful when calculating site-specific criteria for compounds that are highly
hydrophobic—these compounds have potential to cause bioaccumulation in aquatic
organisms even when concentrations in the water column are below detection limits.

3.	BCF Method. This method estimates BAFs from laboratory-measured BCFs. Experiments
designed to calculate BCFs aim to measure bioconcentration resulting from an organism's
exposure to contaminated water. Unlike BAFs measured in the field, BCF experiments do
not capture bioaccumulation from other routes of exposure or biomagnification (the
increase in bioaccumulation at higher levels of the food chain). However, BCFs may be
used to estimate bioaccumulation if a contaminant's chemical and physical properties
indicate that the compound is likely to primarily accumulate in the organism via the water
exposure route, and there is no evidence that the contaminant biomagnifies in the food
chain. If insufficient field-collected data are available to calculate a national BAF, the EPA
may also estimate bioaccumulation using laboratory measured BCFs and a food chain
multiplier term, which accounts for biomagnification.

A similar process to the one described in the BAF method description (above) for
normalizing of water-dissolved portions of the chemical and particulate organic carbon
content is used for calculating national BAFs from laboratory-measured BCF data. Ionic
organic chemicals are normalized, then multiplied by the food chain multiplier if
biomagnification is expected to occur. All available BCFs are averaged using a geometric
mean across species and then across TL to compute baseline BAFs.

4.	KowMethod. This method predicts BAFs based on a chemical's octanol-water partition
coefficient (Kow), with or without adjustment using a food chain multiplier, as described
in Section 5.4 of the Technical Support Document, Volume 2 (EPA, 2003).

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4.2.2 Data Selection and Evaluation

The EPA conducted a systematic literature search in October 2022 of publicly available
literature sources to determine whether they contained information relevant to calculating
national BAFs for human health AWQC, using the 2000 Methodology and Technical Support
Document, Volume 2 (EPA, 2000a, 2003). The literature search for reporting the
bioaccumulation of PFOA was implemented by developing a series of chemical-based search
terms, consistent with the process for derivation of BAFs used in the development of the EPA's
Final Aquatic Life Criteria for PFOA (EPA, 2024e) and PFOS (EPA, 2024f) and published in
Burkhard (2021). These terms included chemical names and Chemical Abstracts Service Registry
Number (CASRN or CAS), synonyms, tradenames, and other relevant chemical forms (i.e.,
related compounds). Databases searched were Current Contents, ProQuest CSA, Dissertation
Abstracts, Science Direct, Agricola, TOXNET, and UNIFY (database internal to the EPA's ECOTOX
database). The literature search (including literature published through the first two quarters of
2020) yielded > 37,000 citations that were further refined by excluding citations on analytical
methods, human health, terrestrial organisms, bacteria, and where PFOA was not a chemical of
study (Burkhard, 2021). The citations meeting the search criteria were reviewed for reported
BAFs and/or reported concentrations in which BAFs could be calculated. Data from papers that
met the inclusion and data quality screening criteria described below were extracted into the
chemical dataset for PFOA.

Specifically, studies were evaluated for inclusion in the dataset used for calculating national
BAFs for PFOA using the following evaluation criteria:

•	Only BAF studies that included units for tissue, water, and/or BAFs were included.

•	Mesocosm, microcosm, and model ecosystem studies were not selected for use in
calculating BAFs.

•	BAF studies in which concentrations in tissue and/or water were below the minimum
level of detection were excluded.

•	Only studies performed using freshwater or brackish water were included; high salinity
values were excluded.

•	Studies of organisms (e.g., damselfly, goby) and tissues (e.g., fish bladder) not
commonly consumed by humans or not used as surrogate species for those commonly
consumed by humans were excluded.

•	Studies in which the BAFs were not found to be at steady state were excluded.

•	Initially, for pooled samples, averaging BAF data from multiple locations was only
considered acceptable if corresponding tissue and water concentrations were available
from matching locations (e.g., a BAF would not have been calculated using water and
tissue samples collected from eight separate locations with tissue concentrations
collected from only six of these corresponding locations). After further review, for
pooled samples, averaging data from multiple locations was considered acceptable if
corresponding tissue and water concentrations were available from the overall spatial
area of the study.

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In addition to the evaluation criteria listed above, PFOA bioaccumulation data were also
subsequently evaluated using the following study evaluation criteria outlined in Burkhard
(2021) (Table 2).

As noted in Burkhard (2021), study quality determinations based on temporal and spatial
coordination were subjective and based on best professional judgement. In the absence of
adequate quantifiable information regarding sample location (site coordinates for both water
and tissue collection locations) or temporal coordination (specific dates of sample collection),
BAF data were given a score of 2 or 3 for these categories.

Table 2. Bioaccumulation factor (BAF) study quality criteria based on suggested criteria in
Burkhard (2021).	

Criteria

1

2

3

Number of water
samples collected

> 3 samples

2-3 samples

1 sample

Number of organism
samples collected

> 3 samples

2-3 samples

1 sample

Temporal coordination
of water and biota
samples

Concurrent collection
of samples

Collected within a 1-
year time frame

Collected > 1 year time
frame

Spatial coordination of
water and biota
samples

Collected from same
locations

Collected from
reasonably close
locations (1 kilometer
(km)-2 km)

Significantly different
sampling locations

General experimental
design

Assigned a default
value of zero for
studies in which tissues
from individual species
were identified and
analyzed



Assigned a value of 3 for
studies in which tissues
were from mixed
species or reported as a
taxonomic group.

Notes: The scores for each BAF were totaled and used to determine the overall confidence ranking for each
individual BAF. The sum of quality values for the five criteria listed in Table 2 were classified as high quality (total
score of 4 or 5), medium quality (total score of 5 or 6) or low quality (total score > 7). Only high and medium
quality data were included in final national BAFs calculations.

4.2.3 BAFs for PFOA

Following the decision framework presented in Figure 1, the EPA selected one of the four
methods to develop a national-level BAF for this chemical. Because PFOA is an organic chemical
that predominantly exists in an anionic form in water (EPA, 2024g,h; NCBI, 2024), the BSAF and
Kow methods would not be applicable. The EPA selected the BAF estimate using the BAF method
(i.e., based on a field-measured BAF) because sufficient field-measured BAF data were available
for PFOA.

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Moderate-High



~

Low

(Log Kow >4)



(Log Kow < 4)

Nonionic Organic

Hydrophobic?

Inorganic &
Organometallic

V

C Biomognification?y

(^etabolism?) (Metabolism?)

/ j 	 _k_

Low/
Unknown

I

High

Low/
Unknown

High

Procedure #1

1.	Field BAF

2.	BSAF

3.	Lab BCF*FCM

4.	Kow*FCM

Procedure #3

1.	Field BAF

2.	Kow

Procedure #2

1.	Field BAF

2.	BSAF

3.	Lab BCF

Procedure #4

1. Field BAF
or Lab
BCF

Procedure #5

Procedure #6

1. Field BAF or

1. Field BAF

Lab BCF

2. Lab BCF*FCM

Figure 1, Application of the BAF framework for PFOA; gray boxes indicate steps followed
based on available information for PFOA (EPA, 2000a).

The national-level BAF equation adjusts the TL baseline BAFs for nonionic organic chemicals by
national default values for lipid content, as well as dissolved and particulate organic carbon
content. The partitioning of PFOA is related to protein binding properties (ATSDR, 2021);
therefore, the EPA did not normalize measured BAF values for PFOA using lipid content when
calculating baseline and national BAFs. The EPA selected the recommended 50th percentile
dissolved and particulate organic carbon content for the national-level default values which is
consistent with the goal of national BAFs (i.e., as central tendency estimates), as described in
Section 6.3 of the Technical Support Document, Volume 2 (EPA, 2003). Adjustments for water-
dissolved portions of PFOA is applied to TL baseline BAFs (EPA, 2000a) (see Appendix A).

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The EPA followed the framework described in the Technical Support Document, Volume 2 (EPA,
2003), also presented in Figure 1, to select a procedure for estimating national BAFs for PFOA.
Based on the characteristics of this chemical, the EPA selected Procedure 5 for deriving a
national BAF value. PFOA has the following characteristics:

•	Ionic organic chemicals, with ionization not negligible (NCBI, 2024).

•	Biomagnification unlikely (Houde et al., 2011; Du et al., 2021; Munoz et al., 2022).

The EPA was able to locate peer-reviewed, field-measured BAFS for TLs 2, 3, and 4 from the
sources evaluated for which sufficient information was provided to indicate the quality and
usability of the data; therefore, the EPA included only field BAF studies. The EPA used the BAF
method to derive the national BAF values for PFOA:

•	TL 2 = 22 L/kg

•	TL 3 = 49 L/kg

•	TL 4 = 31 L/kg

5 Selection of Toxicity Value
5.1 Approach

The EPA considered all available final toxicity values for both noncarcinogenic and carcinogenic
toxicological effects after oral exposure to develop AWQC for PFOA. As described in the 2000
Methodology (EPA, 2000a), where data are available, the EPA derives AWQC for both
noncarcinogenic and carcinogenic effects and selects the more protective value for the
recommended AWQC. (See Section 7, Criteria Derivation: Analysis.)

For noncarcinogenic toxicological effects, the EPA uses a chronic-duration oral reference values
(RfVs; RfDs or equivalent) to derive human health AWQC. An RfV is an estimate (with uncertainty
spanning perhaps an order of magnitude) of a daily oral exposure of the human population to a
substance that is likely to be without an appreciable risk of deleterious effects during a lifetime
(EPA, 2002). An RfV may be derived from a toxicological study or a human epidemiological study,
from which a point of departure (POD; i.e., a no-observed-adverse-effect level [NOAEL], lowest-
observed-adverse-effect level [LOAEL], or benchmark dose [BMD]) can be derived. To derive the
RfV, uncertainty factors are applied to the POD to reflect the limitations of the data in accordance
with the EPA human health risk assessment methodology (EPA, 2002, 2014a, 2022a).

For carcinogenic toxicological effects, the EPA uses an oral CSF to derive human health AWQC.
The oral CSF is an upper bound, approximating a 95% confidence limit, on the increased cancer
risk from a lifetime oral exposure to a stressor. This value may also be derived from animal
toxicological studies or human epidemiological studies.

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In developing AWQC, the EPA conducts a systematic search of peer-reviewed, publicly available
final toxicity assessments to obtain the toxicity value(s) (RfV and/or CSF) for use in developing
AWQC. The EPA identified toxicological assessments by systematically searching websites of the
following EPA program offices, other national and international programs, and state programs
in April 2024:

•	EPA, Office of Research and Development

o Integrated Risk Information System (IRIS) program (EPA, 2024i)
o Provisional Peer-Reviewed Toxicity Values (PPRTV) (EPA, 2024j)
o ORD Human Health Toxicity Values (EPA, 2024k)

•	EPA, Office of Pesticide Programs (EPA, 20241)

•	EPA, Office of Pollution Prevention and Toxics (EPA, 2024m)

•	EPA, Office of Water Drinking Water Health Effects Support Documents (EPA, 2024n)

•	U.S. Department of Health and Human Services, Agency for Toxic Substances and
Disease Registry (ATSDR, 2024)

•	Health Canada (HC, 2023)

•	California Environmental Protection Agency, Office of Environmental Health Hazard
Assessment (CalEPA, 2024)

After identifying and documenting all available final toxicity values, the EPA followed a
systematic process to consider the identified toxicity values and select the toxicity value(s)to
derive the AWQC for noncarcinogenic and carcinogenic effects. The EPA selected IRIS toxicity
values to derive the draft AWQC if any of the following conditions were met:

1.	The EPA's IRIS toxicological assessment was the only available source of a toxicity value.

2.	The EPA's IRIS toxicological assessment was the most current source of a toxicity value.

3.	The toxicity value from a more current toxicological assessment from a source other
than the EPA's IRIS program was based on the same principal study and was numerically
the same as an older toxicity value from the EPA IRIS program.

4.	A more current toxicological assessment from a source other than the EPA's IRIS
program was available, but it did not include the relevant toxicity value (chronic-
duration oral RfD or CSF).

5.	A more current toxicological assessment from a source other than the EPA's IRIS
program was available, but it did not introduce new science (e.g., the toxicity value was
not based on a newer principal study) or use a more current modeling approach
compared to an older toxicological assessment from the EPA's IRIS program.

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The EPA selected the toxicity value from a peer-reviewed, publicly available source other than
the EPA IRIS program to derive the draft AWQC if any of the following conditions were met:

1.	The chemical is currently used as a pesticide, and the EPA Office of Pesticide Programs
had a toxicity value that was used in pesticide registration decision-making.

2.	A toxicological assessment from a source other than the EPA's IRIS program was the
only available source of a toxicity value.

3.	A more current toxicological assessment from a source other than the EPA's IRIS
program introduced new science (e.g., the toxicity value was based on a newer principal
study) or used a more current modeling approach compared to an older toxicological
assessment from the EPA's IRIS program.

5.2 Toxicity Value for PFOA
5.2.1 Reference Dose

After following the approach outlined in Section 5.1, the EPA identified the final Human Health
Toxicity Assessment for Perfluorooctanoic Acid (PFOA) and Related Salts (EPA, 2024g). This
document is the most recent toxicity assessment identified for PFOA and used the best
available science in the evaluation of noncancer risk. The EPA did not identify any other
assessments that presented newer scientific information (i.e., unique RfVs) for PFOA.

The EPA's final human health toxicity assessment for PFOA (EPA, 2024g) considered all publicly
available human epidemiological, animal toxicological, mechanistic and toxicokinetic evidence
relevant to studies that evaluated health effects after oral PFOA exposure. Overall, the available
evidence indicates that PFOA exposure is likely to cause hepatic, immunological, cardiovascular,
and developmental effects in humans, given sufficient exposure conditions (e.g., at levels in
humans as low as 1.1 to 5.2 ng/mL and doses in animals as low as 0.3 to 1.0 mg/kg/day). These
judgments are based on data from epidemiological studies of infants, children, adolescents,
pregnant individuals, and non-pregnant adults, as well as short-term (28-day), subchronic (90-
day), developmental (gestational), and chronic (2-year) oral-exposure studies in rodents.

PODs were developed following EPA's Benchmark Dose Technical Guidance Document (EPA,
2012) and converted to external POD human equivalent doses (PODheds) using pharmacokinetic
modeling. Consistent with the recommendations presented in A Review of the Reference Dose
and Reference Concentration Processes (EPA, 2002), the EPA applied uncertainty factors (UFs)
to PODheds to address intraspecies variability, interspecies variability, extrapolation from a
lowest observed adverse effect level (LOAEL) to no observed adverse effect level (NOAEL),
extrapolation from a subchronic to a chronic exposure duration, and database deficiencies. The
EPA derived and considered multiple candidate RfDs from both epidemiological and animal
toxicological studies across the four noncancer health outcomes that the EPA determined had
the strongest weight of evidence (i.e., immune, cardiovascular, hepatic, and developmental).

Decreased serum anti-tetanus and anti-diphtheria antibody concentrations in children (Budtz-
Jorgensen and Grandjean, 2018), decreased infant birth weight (Wikstrom et al., 2020), and
increased total cholesterol in adults (Dong et al., 2019) were selected as the co-critical effects

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for the overall oral RfD of 3 x 10"8 mg/kg/day (EPA, 2024g). This RfD was derived by applying a
total UF of 10 to account for intraspecies variability (UFh). Critical effects observed during
developmental periods (decreased antibody concentrations in children, decreased birth weight)
represent effects in susceptible subpopulations. The RfD based on these effects is considered
protective of effects resulting from lifetime exposures to PFOA, as well as short-term risk
assessment scenarios, as the observed developmental endpoints can potentially result from a
short-term exposure during critical periods of development.

5.2.2 Cancer Slope Factor

Consistent with EPA's Guidelines for Carcinogen Risk Assessment (EPA, 2005a), the EPA's
Human Health Toxicity Assessment for Perfluorooctanoic Acid (PFOA) and Related Salts (EPA,
2024g) reviewed the weight of the evidence across epidemiological, animal toxicological, and
mechanistic studies and concluded that PFOA is Likely to Be Carcinogenic to Humans via the
oral route of exposure. Epidemiological studies provided evidence of kidney and testicular
cancer in humans and some evidence of breast cancer in susceptible subpopulations. Chronic
oral animal toxicological studies in Sprague-Dawley rats reported Leydig cell tumors (LCT),
pancreatic acinar cell tumors (PACT), and hepatocellular tumors. PFOA exposure is associated
with multiple key characteristics of carcinogenicity (Smith, 2016). Available mechanistic data
suggest that multiple MOAs could be involved in the renal, testicular, pancreatic, and hepatic
tumorigenesis associated with PFOA exposure in humans and animal models.

To derive a CSF for PFOA, the EPA followed agency risk assessment guidelines and
methodologies (EPA, 2005a, 2012, 2022c). EPA conducted benchmark dose modeling and used
a similar pharmacokinetic modeling approach as described for the derivation of noncancer RfDs
above (see Section 5.2.1). EPA derived and considered multiple candidate CSFs from both
epidemiological and animal toxicological studies across multiple tissue types and organ systems
(i.e., kidney, liver, pancreas, testes). CSFs were derived for epidemiological data on renal cell
carcinoma (RCC) and kidney cancer using weighted linear regressions to calculate quartile-
specific relative kidney cancer risks. Relative risks were then converted to the absolute risk
scale, yielding an internal CSF, which represents the excess cancer risk associated with each
ng/mL increase in serum PFOA. The internal serum CSF was then divided by the selected
clearance value and converted to an external dose CSF. For animal toxicological studies,
multistage cancer models were used to predict the doses at which the selected BMR for tumor
incidence would occur. BMDLs for each tumor type served as the PODs, which were then
converted to PODheds by applying the human clearance value. CSFs were then calculated by
dividing the selected BMR by the PODheds for each tumor type (EPA, 2024g).

The oral slope factor of 0.0293 (ng/kg/day)-1 (29,300 (mg/kg/day)-1) for RCC in human males
from Shearer et al. (2021) was selected as the basis of the overall CSF for PFOA (EPA, 2024g).
Per EPA's Guidelines for Carcinogen Risk Assessment and Supplemental Guidance for Assessing
Susceptibility from Early-Life Exposure to Carcinogens (EPA, 2005a,b) age-dependent
adjustment factors were not applied during CSF derivation, as a mutagenic mode of action
(MOA) was not determined for PFOA from a review of the available studies, and evidence did
not support increased susceptibility to cancer following PFOA exposure during early life.

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6 Relative Source Contribution (RSC) Derivation
6.1 Approach

The EPA applies an RSC to the RfD when calculating an AWQC based on noncancer effects or for
carcinogens that are known to act through a nonlinear mode of action to account for the
fraction of an individual's total exposure allocated to AWQC-related sources (EPA, 2000a). The
purpose of the RSC is to ensure that the level of a chemical allowed by a criterion (e.g., the
AWQC), when combined with other identified sources of exposure (e.g., diet, excluding
freshwater and estuarine fish and shellfish, ambient and indoor air) common to the population
of concern, will not result in exposures that exceed the RfD. In other words, the RSC is the
portion of total daily exposure equal to the RfD that is attributed to consumption of ambient
water (directly or indirectly in beverages like coffee tea or soup, as well as from transfer to
dietary items prepared with ambient water) and fish and shellfish from inland and nearshore
waters relative to other exposure sources; the remainder of the exposure equal to the RfD is
allocated to other potential exposure sources. The EPA considers any potentially significant
exposure source and route when deriving the RSC.

The RSC is derived by applying the Exposure Decision Tree approach published in the EPA's
2000 Methodology (EPA, 2000a). The Exposure Decision Tree approach allows flexibility in the
RfD apportionment among sources of exposure and considers several characteristics of the
contaminant of interest, including the adequacy of available exposure data, levels of the
contaminant in relevant sources or media of exposure, and regulatory agendas (i.e., whether
there are multiple health-based criteria or regulatory standards for the contaminant). The RSC
is developed to reflect the exposure to the U.S. general population or a sensitive population
within the U.S. general population, depending on the available data.

An RSC determination first requires "data for the chemical in question... representative of each
source/medium of exposure and... relevant to the identified population(s)" (EPA, 2000a). The
term "data" in this context is defined as ambient sampling measurements in the media of
exposure, not internal human biomonitoring metrics. More specifically, the data must
adequately characterize exposure distributions including the central tendency and high-end
exposure levels for each source and 95% confidence intervals for these terms (EPA, 2000a). The
EPA's approach recommends a "ceiling" RSC of 80% and a "floor" RSC of 20% to account for
uncertainties including unknown sources of exposure, changes to exposure characteristics over
time, and data inadequacies.

The EPA's Exposure Decision Tree approach states that when there are insufficient
environmental monitoring and/or exposure intake data to permit quantitative derivation of the
RSC, the recommended RSC is 20%. In the case of AWQC development, this means that 20% of
the exposure equal to the RfD is allocated to the consumption of ambient water and fish and
shellfish from inland and nearshore waters and the remaining 80% is reserved for other
potential sources, such as diet (excluding fish and shellfish from inland and nearshore waters),
air, consumer products, etc. This 20% RSC can be replaced if sufficient data are available to
develop a scientifically defensible alternative value. If scientific data demonstrating that sources
and routes of exposure other than drinking water are not anticipated for a specific pollutant,

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the RSC can be raised as high as 80% based on the available data, allowing the remaining 20%
for other potential sources (EPA, 2000a). Applying a lower RSC (e.g., 20%) is a more health
protective approach to public health and results in a lower AWQC.

To derive an RSC for PFOA, the EPA evaluated the exposure information identified through
conducting prior systematic literature searches performed as part of the EPA's final human
health toxicity assessment for PFOA (EPA, 2024g). To identify information on PFOA exposure
routes and sources to inform RSC determination, the EPA considered primary literature
published between 2003-2020 that was collected by the EPA's Office of Research and
Development as part of an effort to evaluate evidence for pathways of human exposure to
eight PFAS, including PFOA. This search was not date-limited and spanned information collected
across the Web of Science, PubMed, and ToxNet/ToxLine (now ProQuest) databases. An
updated literature search was conducted and captured relevant literature published through
March 2021. Literature captured by this search is housed in the EPA's HERO database
(https://hero.epa.gov/). To supplement the primary literature database, the EPA also searched
the following gray literature sources in February 2022 for information related to relative
exposure of PFOA for all potentially relevant routes of exposure (oral, inhalation, dermal) and
exposure pathways relevant to humans. The full description of methods used to identify and
screen relevant literature is available in the EPA's Final Appendix: Human Health Toxicity
Assessment for Perfluorooctanoic Acid (PFOA) and Related Salts (EPA, 2024h). The following
description in Section 6.2 is a summary of the information provided in the Appendix of the final
PFOA toxicity assessment.

6.2 Summary of Potential Exposure Sources of PFOA Other Than Water and Freshwater and

Estuarine Fish/Shellfish
6.2.1 Dietary Sources

A number of studies support food ingestion as a major source of exposure to PFOA based on
early studies that modeled the relative contributions of various sources among the general
populations of North America and Europe (Fromme et al., 2009; Trudel et al., 2008; Vestergren
and Cousins, 2009). The exposure to adults in the U.S. population is typically estimated to be
about 2 ng/kg-d to 3 ng/kg-d (Gleason et al., 2017). The dominance of the food ingestion
pathway is attributed to bioaccumulation in food from environmental emissions, relatively large
amounts of foods being consumed, and high gastrointestinal uptake (Trudel et al., 2008).
However, the estimates are highly uncertain due to analytical methods with poor sensitivity,
relatively few food items with detectable levels, and levels that can vary greatly depending on
sources or location (Gleason et al., 2017).

There is currently no comprehensive, nationwide Total Diet Study (TDS) for PFOA that can be
used to draw conclusions about the occurrence and potential risk of PFOA in the U.S. food
supply for the general population. In 2021, the FDA released PFAS testing results from their first
survey of nationally distributed processed foods, including several baby foods, collected for the
TDS (FDA, 2021a). Results of the survey showed that 164 of the 167 foods tested had no
detectable levels of PFAS measured. Three food samples (fish sticks, canned tuna, and protein
powder) had detectable levels of PFAS but did not include PFOA (FDA, 2021b). PFOA was not

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detected in any of the food samples analyzed in the FDA TDS samples of produce, meats, dairy
and grain products in 2019 or 2021 (FDA, 2020a,b, 2021c). In a 2018 focused study near a PFAS
production plant in the Fayetteville, North Carolina area, PFOA was detected in several produce
samples (cabbage, collard greens, kale, mustard greens, swiss chard, and lettuce) (FDA, 2018).
In bottled water, PFOA was below the lower limit of quantification (LOQ; 4 ng/L) in all (30)
analyzed samples of domestic and imported carbonated water and noncarbonated bottled
water (FDA, 2016). The sample size in these studies is limited, and thus, the results cannot be
used to draw definitive conclusions about the general levels of PFAS in the U.S. food supply
(FDA, 2023). In a 2010 study, PFOA was detected in food samples collected from five grocery
stores in Texas (Schecter et al., 2010); based on the results from this study and on dietary
intakes from the 2007 USDA food availability data set, the estimated daily exposure to PFOA
per capita was 60 ng/day (EPA, 2016a).

As a component of a scientific evaluation on the risks to human health related to PFAS in food,
the European Food Safety Authority (EFSA) conducted an exposure assessment using
consumption data from the EFSA Comprehensive Food Consumption Database and
69,433 analytical results for 26 PFAS in 1,528 samples of food and beverages obtained from
16 European countries (EFSA, 2020). Samples were collected between the years 2000 and 2016
(74% after 2008), mainly from Norway, Germany, and France. With 92% of the analytical results
below the LOD or LOQ, lower bound dietary exposure estimates were obtained by assigning
zero to values below LOD/LOQ. Median chronic dietary exposures of PFOA for children and
adults were estimated as 0.30 and 0.18 ng/kg body weight per day, respectively. The most
important contributor was "fish and other seafood6," followed by "eggs and egg products,"
"meat and meat products," and "fruit and fruit products." "Vegetables and vegetable products"
and "drinking water" were also found to be important contributors to dietary PFOA exposure. It
is unclear whether or not the contribution from food contact material is reflected in the data.

The 2020 EFSA report highlighted a recent study of aggregate exposure to PFAS from diet,
house dust, indoor air, and dermal contact among Norwegian adults (Poothong et al., 2020).
Dietary exposures were estimated for 61 study participants using food diaries and data on
concentrations from an extensive Norwegian database of concentrations in 68 different food
and drinks (including drinking water). For PFOA, dietary intake was by far the greatest
contributor to aggregate exposure (contributing 92% of total estimated PFOA intake), but
intake from ingestion of house dust represented the dominant pathway for some of the top
20% most highly exposed individuals. On average, measured serum concentrations of PFOA
were similar to modeled concentrations based on intakes. It is notable that while the authors
reported significant positive correlations between PFOA concentrations in serum and estimated
intakes based on surface dust and vacuum cleaner bag dust samples, correlations with
estimated dietary intakes were not significant, which the authors attributed to temporal
variations in dietary intakes over several years. While the authors did not separately quantify
intake from food and drinking water, an earlier article from the same research group

e Some dietary studies use the term "seafood" to indicate fish and shellfish from ocean, freshwater, or estuarine
water bodies. Information about the water bodies assessed in individual studies is reported in the articles.

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(Papadopoulou et al., 2017) reported measured concentrations in duplicate diets with median
estimated intake of PFOA approximately three times higher from solid food than from liquids.

Zafeiraki et al. (2019) analyzed about 250 samples of marine fish, farmed fish, crustaceans,
bivalves and European eel, caught in Dutch waters or purchased at Dutch markets between
2012 and 2018. Samples were analyzed for 16 PFAS, including PFOA. Brown crab and shrimp
had the highest average concentrations of PFOA (0.78 ng/g ww and 0.43 ng/g ww,
respectively). PFOA was also detected in farmed fish including eel and trout, and marine fish
species including cod, haddock, and sole.

In seafood samples collected for the FDA 2021-2022 seafood survey (FDA, 2022), Young et al.
(2022), analyzed concentrations of 20 PFAS, including PFOA, in eight of the most highly
consumed marine seafood products in the United States. PFOA was detected most frequently
(100% of samples; n = 10) and at the highest average concentrations (8,334 parts per trillion
[ppt]) in clams and was also detected in 100% of crab samples (n = 11; 300.9 ppt average
concentration). The study reported detections in cod (20% of samples; n = 10; 103.5 ppt
average concentration in samples with detections). PFOA was not detected above the MDL
(68 ppt or 90 ppt) in tuna, salmon, shrimp, or pollock.

6.2.2 Food Contact Materials

The FDA has authorized the use of PFAS in food contact substances due to their nonstick and
grease, oil, and water-resistant properties since the 1960s. There are four categories of
products that may contain PFAS (FDA, 2020a,b):

•	Nonstick cookware: PFAS may be used as a coating to make cookware nonstick.

•	Gaskets, O-Rings, and other parts used in food processing equipment: PFAS may be used
as a resin in forming certain parts used in food processing equipment that require
chemical and physical durability.

•	Processing aids: PFAS may be used as processing aids for manufacturing other food
contact polymers to reduce build-up on manufacturing equipment.

•	Paper/paperboard food packaging: PFAS may be used as grease-proofing agents in fast-
food wrappers, microwave popcorn bags, takeout paperboard containers, and pet food
bags to prevent oil and grease from foods from leaking through the packaging.

Paper products used for food packaging are often treated with PFAS for water and grease
resistance. In previous testing, sandwich wrappers, french fry boxes, and bakery bags were all
been found to contain PFAS (Schreder and Dickman, 2018). Older generation PFAS (e.g., PFOA,
PFOS) were manufactured and used in products for decades, and the bulk of the information
available on PFAS toxicity relates to the older compounds. However, because newer generation
PFAS are more mobile than their predecessors, they migrate more readily into food. In 2016,
the FDA deauthorized the remaining uses of long-chain "C8" PFAS in food packaging, which are
therefore, no longer used in food contact applications sold in the United States (FDA, 2020a,b).

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Schaider et al. (2017) collected 407 samples of food contact papers, beverage containers, and
paperboard boxes from locations throughout the United States. Twenty fast food packaging
samples of the 407 total samples were selected for more extensive PFAS specific analysis.

PFOA, was among the PFAS with the highest detection rates and was detected in six out of
20 samples.

An analysis of popcorn bags, snack bags, and sandwich bags purchased in 2018 from international
vendors and grocery stores in the United States found little evidence of PFOA, with only two
popcorn bags with content above the limit of quantitation of 5.11 ng per gram (ng/g) of paper
(Monge Brenes et al., 2019). The authors presented these results as evidence of a reduction in
PFOA concentrations in microwave packaging between 2005 and 2018. In an analysis of
microwave popcorn bags from around the world, Zabaleta et al. (2017) reported no measurable
concentrations of PFOA in the two bags from the United States, levels typically at about 4 ng/g in
those from several European countries, and levels around 50 ng/g in bags from China.

Yuan et al. (2016) analyzed 25 food contact materials purchased in Columbus, Ohio for PFAS as
compared to 69 products purchased in China. In food packaging materials from China, of the
15 detected perfluorinated carboxylic acids, PFOA was the most frequently detected (90%) and
was detected with the highest median concentration (1.72 ng/g). The authors also report a
migration efficiency of PFOA from paper bowl packaging into food stimulants of 1.58%. This is a
relatively low efficiency compared to several of the fluorotelomer alcohols (FTOHs) which the
authors reported to migrate with greater than 90% efficiency.

Zabaleta et al. (2020) also monitored migration of the PFAS carboxylates (C6 to C10) from
packaging materials into cereal, rice, or milk. For each PFAS studied the percent migration to
milk exceeded that to rice with the lowest percent migration being that to cereal. The migration
percentage of PFOA into cereal, rice, and milk powder products over six months ranged from
1.4%-5.6%.

6.2.3 Consumer Product Uses

A targeted analysis of 29 U.S. and Canadian cosmetic products with high fluorine content
(Whitehead et al., 2021) found high concentrations of FTOH, including 8:2 FTOH, commonly
present in the formulations. A fraction of 8:2 FTOH is believed to undergo metabolic
transformation into PFOA. In addition to direct contact with personal care products, products
and articles (and the use of these) may be sources in the indoor environment that manifest as
measured occurrence in house dust and indoor air. An earlier investigation of consumer
exposure to PFOA by Trudel et al. (2008) used mechanistic modeling together with information
on product use habits to estimate oral and dermal exposures from clothes, carpet, upholstery,
and food contact materials. Noting that PFOA may be contained as a contaminant in older and
in new products, the authors estimated exposure via both mill-treated and home-treated
carpets. The authors concluded that contact with consumer products is not a significant
contributor to total exposure, but that since PFOA may be a contaminant in even new products,
consumer exposure may continue to occur, particularly via both mill-treated and home-treated
carpets. The authors also point out that carpet and other textiles are likely to be continuing

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sources of PFOA in house dust. In contrast, in an analysis of 116 articles of commerce from the
United States, the EPA (2009) identified carpets and related products as potentially the most
significant source of perfluorinated carboxylic acids (PFCAs) out of 13 total product categories
analyzed. PFOA was detected in all 13 product types. Other important indoor sources of PFCAs
include floor wax/sealant and home textiles, upholstery, and apparel. In a similar analysis of
52 European products collected between 2014-2016, Borg and Ivarrson (2017) reported that
PFOA was the most commonly detected PFAS and was detected in all samples except those that
did not contain any detectable levels of PFAS. Notably, the authors specifically targeted
products that were known or suspected to contain PFAS in their analyses.

Liu et al. (2014) investigated trends in PFAS content of household goods between 2007 and
2011. They reported that while PFOA concentrations displayed an overall downward temporal
trend with significant reductions observed in nearly all product categories, PFOA was still
detected in many products. Kotthoff et al. (2015) similarly reported broad detection of PFOA in
a 2010 sampling effort that collected 115 European consumer products, including carpets,
leather, outdoor textiles, cooking materials, and others. PFOA was detected in all but one
sample type, often at the highest median concentration compared to other PFCAs. The product
samples with the highest concentrations of PFOA included ski wax (median concentration of
15.5 |-ig/kg), leather products (median concentration of 12.4 |ag/m2), and outdoor materials
(median concentration of 6 |ag/m2). PFOA has also been detected in textile samples of outdoor
apparel from Europe and Asia (Gremmel et al., 2016; van der Veen et al., 2020). PFOA was
detected in jackets ranging from concentrations of 0.02-4.59 |-ig/m2 (Gremmel et al., 2016).
Interestingly, the level of almost all individual PFAS, including PFOA, and total PFAS increased
when the textiles were subjected to weathering (i.e., increased ultraviolet [UV] radiation,
temperature, and humidity for 300 hours to mimic the average lifespan of outdoor apparel)
(van der Veen et al., 2020).

6.2.4 Indoor Dust

Several studies suggest that PFOA and its precursors in indoor air and/or house dust may be an
important exposure source for some individuals (Shoeib et al., 2011; Schlummer et al., 2013;
Gebbink et al., 2015; Poothong et al., 2020). PFOA is generally a dominant ionic PFAS
constituent in indoor air and dust, frequently occurring above detection limits and at relatively
high concentrations in all or most samples (Shoeib et al., 2011; Kim et al., 2019; Wu et al., 2015;
Poothong et al., 2020; Makey et al., 2017; Byrne et al., 2017; Fraser et al., 2013).

PFOA was measured at the highest concentrations (geometric mean concentrations ranging
from 41.4-45.0 ng/g) and frequencies (ranging from 89%-91% detected) in dust sampled from
Californian households (Wu et al., 2015). Similarly, PFOA was found at the second highest levels
(mean concentration of 1.98 ng/g) of 15 PFAS measured in dust samples taken from households
in Seoul, South Korea (Kim et al., 2019). PFOA was detected in all dust samples from that study.
Makey et al. (2017) measured PFOA and PFOA precursors in dust and found weak correlations
between concentrations in dust and serum PFOA concentrations in pregnant Canadian
participants. One study in Alaska Natives found no correlation between dust and serum PFOA
concentrations (Byrne et al., 2017).

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6.2.5	Ambient Air

Perfluoroalkyl chemicals have been found in ambient air globally, with the highest
concentrations observed or expected in urban areas and nearest to industrial facilities, areas
where AFFF firefighting foams are used, wastewater treatment plants, waste incinerators, and
landfills (Ahrens et al., 2011b). Perfluorinated acids were measured in Albany, New York air
samples (gas mean concentration of 3.16 pg/m3 and particulate phase mean concentration of
2.03 pg/m3) (Kim and Kannan, 2007). In Minneapolis, Minnesota, PFOA in the particulate phase
ranged from 1.6 pg/m3to 5.1 pg/m3 and from 1.7 pg/m3 to 16.1 pg/m3 in the gas phase (MPCA,
2008). Even remote areas far from urban centers have previously reported PFOA
concentrations in air samples; PFOA has been detected in Resolute Bay, Nunavut, Canada
(Stock et al., 2007), as well as other Arctic environments (Butt et al., 2010).

The EPA's Toxics Release Inventory reported release data for PFOA in 2022 (EPA, 2024o). PFOA
is not listed as a hazardous air pollutant under the Clean Air Act (EPA, 2024p). However, two
states (New York and Michigan) have set enforceable air emissions limits. Ambient air is a
possible source of exposure to PFOA for the general population; however, the contribution of
air to total exposure is likely low. For example, De Silva et al. (2021) estimated that less than 1%
of PFOA exposure to humans in the United States is from inhalation.

6.2.6	Summary and Recommended RSC for PFOA

As mentioned above, the scope of exposure sources considered for the draft recommended
human health AWQC is limited to surface water used for drinking water and the consumption
of freshwater/estuarine fish and shellfish (EPA, 2000a), consistent with previous human health
AWQC (EPA, 2015). The EPA followed the Exposure Decision Tree approach to determine the
RSC for PFOA (EPA, 2000a; see Figure 2).

To identify the population(s) of concern (Box 1, Figure 2), the EPA first identified potential
subpopulations or life stages based on the PFOA exposure interval in the critical studies from
which the critical effect was selected for RfD derivation in the PFOA toxicity assessment (EPA,
2024d). Since the critical effects are the most sensitive adverse health effects that were
identified from the available data of sufficient quality, then the exposure intervals may be
sensitive windows of exposure. Three co-critical effects were identified for PFOA in three
human epidemiological studies (decreased serum anti-tetanus and anti-diphtheria antibody
concentrations in children, decreased infant birth weight, and increased total cholesterol in
adults); however, the specific critical windows of exposure for each of the critical effects is not
known. However, based on epidemiological study design, potentially sensitive life stages
include women of childbearing age who may be or become pregnant, pregnant women and
their developing fetuses, lactating women, and early childhood. Limited information was
available regarding specific PFOA exposure in these life stages from different environmental
sources. Therefore, the EPA considered exposures in the general U.S. population, ages 21+,
which includes some of these potentially sensitive life stages (i.e., women of childbearing age,
pregnant women and their developing fetuses, and lactating women).

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Figure 2. RSC exposure decision tree framework for PFOA; figure adapted from EPA (2000a)
with gray boxes indicating key decision points for this chemical.

Second, the EPA identified PFOA-reievant exposure sources/pathways (Box 2, Figure 2)
including dietary consumption, incidental oral, inhalation, or dermal exposure via dust,
consumer products, and soil, and inhalation exposure via ambient air. Several of these may be
potentially significant exposure sources.

Third, the EPA evaluated whether adequate data were available to describe the central
tendencies and high-end exposures for all potentially significant exposure sources and
pathways (Box 3, Figure 2). The EPA determined that there were inadequate quantitative data
to describe the central tendencies and high-end estimates for all of the potentially significant
sources. For example, studies from the United States, Canada and Europe indicate that
consumer products may be significant sources of exposure to PFOA. Although several studies
report PFOA detections in consumer products, most examined very few samples (i.e., n = 1-5)
of only a few types of media. Therefore, the agency does not have adequate quantitative data
to describe the central tendency and high-end estimate of exposure for this potentially
significant source in the U.S. population.

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Fourth, the agency determined whether there were sufficient data, physical/chemical property
information, fate and transport information, and/or generalized information available to
characterize the likelihood of exposure to relevant sources (Box 4, Figure 2). Sufficient
information for PFOA was available to characterize the likelihood of exposure. To determine if
there are potential uses/source of PFOA other than AWQC-related sources (Box 6, Figure 2), the
agency relied on the studies summarized in Section 6 (this document). There are potential other
uses/sources of PFOA. PFOA has been detected in soils, dust in carpets and upholstered
furniture in homes, offices, and vehicles. Incidental exposure from soils and dust is an
important exposure route, particularly for small children because of their increase level of
hand-to-mouth behaviors compared to adults. Also, the levels in soils and surface waters can
affect the concentrations in local produce, meat/poultry, dairy products and particulates in the
air. Based on this information, the next step was to determine if adequate information was
available on PFOA to characterize each source/pathway of exposure (Box 8a, Figure 2). The EPA
determined there is not enough information available on each source to make a quantitative
characterization of exposure among exposure sources. Therefore, the data are insufficient to
allow for quantitative characterization of the different exposure sources. The EPA's Exposure
Decision Tree approach states that when there is insufficient environmental and/or exposure
data to permit quantitative derivation of the RSC, the recommended RSC for the general
population is 20% (EPA, 2000a). Thus, the EPA recommends an RSC of 20% (0.20) for PFOA (Box
8b, Figure 2) for both the water plus organism AWQC as well as the organism only AWQC.

7 Criteria Derivation: Analysis

Table 3 summarizes the input parameters used to derive the draft recommended human health
AWQC that are protective of exposure to PFOA from consuming drinking water and/or eating
fish and shellfish (organisms) from inland and nearshore waters. The criteria calculations are
presented below. These criteria recommendations are based on the 2000 Methodology (EPA,
2000a) and the toxicity and exposure assumptions described above (see Section 4, AWQC Input
Parameters; Section 5, Selection of Toxicity Value; and Section 6, Relative Source Contribution
Derivation).

Table 3. Input parameters for the human health AWQC for PFOA.

Input Parameter

Value

RfD

0.00000003 mg/kg-d

CSF

29,300 [mg/kg-d]"1

RSC

0.20

BW

80.0 kg

DWI

2.3 L/d

FCR

TL 2

0.0076 kg/d

TL 3

0.0086 kg/d

TL 4

0.0051 kg/d

BAF

TL 2

22 L/kg

TL 3

49 L/kg

TL 4

31 L/kg

Notes: RfD = reference dose; CSF = cancer slope factor; RSC = relative source contribution; BW = bodyweight;
DWI = drinking water intake; FCR = fish consumption rate; TL = trophic level; BAF = bioaccumulation factor.

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7.1	AWQC for Noncarcinogenic Toxicological Effects

For consumption of water and organisms:

AWQC(|ag/L) = RfD (mg/kg-d) x RSC x BW (kg) x 1.000 (ug/mg)

DWI (L/d) + £?=2 (FCRi (kg/d) x BAFi (L/kg))

=	0.00000003 mg/kg-d x 0.20 x 80.0 kg x 1,000 |-ig/mg

2.3 L/d + ((0.0076 kg/d x 22 L/kg) + (0.0086 kg/d x 49 L/kg) + (0.0051 kg/d x 31 L/kg))

= 0.0001575 |ag/L

= 0.0002 |ag/L (rounded)

For consumption of organisms only:

AWQC (|-ig/L) = RfD (mg/kg-d) x RSC x BW (kg) x 1.000 (ug/mg)

JZi (FCRi (kg/d) x BApi (L/kg))

=	0.00000003 mg/kg-d x 0.20 x 80.0 kg x 1,000 |-ig/mg

(0.0076 kg/d x 22 L/kg) + (0.0086 kg/d x 49 L/kg) + (0.0051 kg/d x 31 L/kg)

= 0.0006428 |ag/L

= 0.0006 |ag/L (rounded)

7.2	AWQC for Carcinogenic Toxicological Effects

The EPA derives cancer-based HHC for contaminants that have been determined to be
Carcinogenic to Humans or Likely to Be Carcinogenic to Humans (EPA, 2000a; EPA, 2000d). Since
PFOA was determined to be Likely to Be Carcinogenic to Humans (EPA, 2024b,c), the EPA
derived AWQC for carcinogenic toxicological effects.

Consumption of water and organisms:

AWQC = RSDx BWx 1.000f

DWI +£f=2 (FCRi x BAFi)

=	(10~6 / 29,300) mg/kg-d x 80.0 kg x 1,000 |-ig/mg

2.3 L/d + ((0.0076 kg/d x 22 L/kg) + (0.0086 kg/d x 49 L/kg) + (0.0051 kg/d x 31 L/kg))

= 0.000000896175 jig/L

= 0.00000090 |ag/L (rounded)

f 1,000 ug/mg is used to convert the units of mass from milligrams to micrograms.

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For consumption of organisms only:

AWQC = RSDx BWx l.OQQB

Yj\=2 (FCRj x BAFi)

= 	(10~6 / 29,300) mg/kg-d x 80.0 kg x 1,000 |ag/mg	

(0.0076 kg/d x 22 L/kg) + (0.0086 kg/d x 49 L/kg) + (0.0051 kg/d x 31 L/kg)

= 0.00000365659 |ag/L

= 0.0000036 |ag/L (rounded)

7.3 AWQC Summary for PFOA

The EPA derived the draft recommended AWQC for PFOA using both noncarcinogenic and
carcinogenic toxicity endpoints. The human health AWQC for noncarcinogenic effects for PFOA
are 0.0002 |ig/L (0.2 ng/L) for consumption of water and organisms and 0.0006 |ig/L (0.6 ng/L)
for consumption of organisms only for the general population (> 21 years old) (Table 4). The
EPA also evaluated the use of exposure factors relevant to sensitive subpopulations based on
the critical effect(s) used to derive the noncarcinogenic RfD (Appendix B). For children
1 to < 3 years old, the criteria calculated for illustrative purposes based on noncarcinogenic
effects are slightly lower than for the general population (> 21 years old), 0.0001 |ag/L (0.1 ng/L)
for consumption of water and organisms and 0.0005 |ag/L (0.5 ng/L) for consumption of
organisms only. The human health AWQC for carcinogenic effects (at a 10"6 cancer risk level) for
PFOA are 0.00000090 ng/L (0.0009 ng/L) for consumption of water and organisms and
0.0000036 ng/L (0.0036 ng/L) for consumption of organisms only (Table 4). The EPA
recommends the lower AWQC, based on the carcinogenic effects of PFOA, as the national
recommended human health AWQC because they are protective of the general population,
including potentially sensitive subpopulations.

Under the EPA's recently finalized Method 1633 (EPA, 2024q) for aqueous samples, the level of
quantification (LOQ) representing the observed LOQs in the multi-laboratory validation study,
range from 1 to 4 ng/L for PFOA. The pooled MDL for PFOA is 0.54 ng/L. The pooled MDL value
is derived from the multi-laboratory validation study using MDL data from eight laboratories
and represents the sensitivity that should be achievable in a well-prepared laboratory but may
not represent the actual MDL used for data reporting or data quality assessments (EPA, 2024q).
The MDLs and ranges presented here provide a reference for comparison of analytical
concentrations and recommended criteria.

Table 4. Summary of the E

3A's recommended human health AWQC for PFOA chemicals.



Human Health AWQC for
Carcinogenic Effects

Water and Organism

0.00000090 ng/L (0.0009 ng/L)

Organism Only

0.0000036 ng/L (0.0036 ng/L)

g 1,000 ng/mg is used to convert the units of mass from milligrams to micrograms.

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8 Consideration of Noncancer Health Risks from PFAS Mixtures

The EPA recently released its final Framework for Estimating Noncancer Health Risks Associated
with Mixtures of Per- and Polyfluoroalkyl Substances (PFAS) (referred to here as the PFAS
mixtures framework; EPA, 2024r). The PFAS mixtures framework describes three flexible, data-
driven approaches that facilitate practical component-based mixtures evaluation of two or
more PFAS based on dose additivity, consistent with the EPA's Guidelines for the Health Risk
Assessment of Chemical Mixtures (EPA, 1986) and Supplementary Guidance for Conducting
Health Risk Assessment of Chemical Mixtures (EPA, 2000c). The approaches described in the
EPA PFAS mixtures framework may support interested federal, state, and Tribal partners, as
well as public health experts and other stakeholders to assess the potential noncancer human
health hazards and risks associated with PFAS mixtures. The EPA is providing an illustration of
one approach which could be applied to PFAS mixture HHC derivation. The PFAS mixtures
framework underwent peer review by the EPA Science Advisory Board (EPA, 2022b) and public
review and the EPA responded to comments (EPA, 2024s). The public comment period ended
on May 30, 2023. The public docket can be accessed at www.regulations.gov under Docket ID:
EPA-HQ-OW-2022-0114.

Dose additivity means that the combined effect of the component chemicals in a mixture is
equal to the sum of the individual doses or concentrations scaled for potency. As noted in the
PFAS mixtures framework, exposure to a number of individual PFAS has been shown to elicit
the same or similar profiles of adverse effects in various organs and systems. Many toxicological
studies of PFAS as well as other classes of chemicals support the health-protective conclusion
that chemicals that elicit the same or similar observed adverse effects following individual
exposure should be assumed to act in a dose-additive manner when in a mixture unless data
demonstrate otherwise (EPA, 2024r). Importantly, few studies have examined the toxicity of
PFAS mixtures, particularly with component chemical membership and proportions that are
representative of the diverse PFAS mixtures that occur in the environment. Mixtures
assessments for chemicals that share similar adverse health effects, and therefore assume dose
additivity, typically apply component-based assessment approaches.

The Hazard Index (HI) approach is one of the component-based mixtures assessment
approaches described in the PFAS mixtures framework. In order to support states and Tribes
interested in addressing potential noncancer risks of PFAS mixtures, the application of the HI
approach for deriving HHC for mixtures is described below. States and authorized Tribes may
choose to adopt this approach to derive HHC for PFAS mixtures. Use of the HI approach to
assess risks associated with PFAS mixtures was supported by the EPA Science Advisory Board
(EPA, 2022b).

In the HI approach (see PFAS mixtures framework; EPA, 2024r), a hazard quotient (HQ) is
calculated as the ratio of human exposure (E) to a human health-based toxicity value (e.g.,
reference value [RfV]) for each mixture component chemical (i) (EPA, 1986). The HQs for the
component chemicals are then summed to derive a mixture-specific HI (for the specified
exposure route/medium). Since the HI is unitless, the E and the RfV inputs to the HI formula
must be expressed in the same dose units (e.g., mg/L) (Eq. 5). For example, in the context of the

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human health criteria, HQs for each individual PFAS are calculated by dividing the measured
ambient water concentration of each component PFAS (e.g., expressed as |ag/L) by its
corresponding human health criterion (e.g., expressed as |ag/L), and the resulting component
PFAS HQs are summed to yield the PFAS mixture HI (Eqs. 5-7). Either water-plus-organism or
organism-only HHC can be used in the PFAS mixtures HI approach; however, the type of HHC
selected for HI calculation should be consistent. Because cancer data are lacking for most PFAS,
the HI approach is currently recommended for PFAS HHC based on noncancer effects.

A hypothetical example is included below to illustrate using the HI approach to derive an HHC
for a mixture of three PFAS. A PFAS mixture HI exceeding 1 indicates that co-occurrence of two
or more PFAS in a mixture in ambient water exceeds the health-protective level(s), indicating
potential health risks. Some individual PFAS have HHC below the analytical MDLs (e.g., PFOA,
PFOS). If one such PFAS is included as a component PFAS in the HI approach, then any
detectable level of that component PFAS in surface water will result in a component HQ greater
than 1, and thus, an HI greater than 1 for the PFAS mixture.

HI = Z"=1 HQi = ZF=i^	(Eq.5)

HI = HQPFASx + HQPFASy	(Eq. 6)

j_jj 	 /[PFASx,ambientwater]\ _|_ /[PFASy^ambientwater]\	y\

V [pfasx,hhc] / \ [pfasy,hhc] /

Where:

HI = hazard index

n = the number of component (i) PFAS

HQi = hazard quotient for component (i) PFAS

Ei = human exposure for component (i) PFAS

HHQ = human health criterion for component PFAS (i)

HQpfas = hazard quotient for a given individual PFAS

PFASx= Hypothetical PFAS

PFASy= Hypothetical PFAS

[PFASambient water] = concentration of a given PFAS in ambient water
[PFAShhc] = water-plus-organism HHC or organism-only HHC for a given PFAS

9 Chemical Name and Synonyms

•	Perfluorooctanoic Acid (PFOA) (CASRN 335-67-1)

•	PFOA

•	2,2,3,3,4,4,5,5,6,6,7,7,8,8,8-pentadecafluorooctanoic acid

•	pentadecafluoro-l-octanoic acid

•	pentadecafluoro-n-octanoic acid

•	octanoic acid, pentadecafluoro-

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•	perfluorocaprylic acid

•	pentadecafluorooctanoic acid

•	perfluoroheptanecarboxylic acid

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Appendix A: Bioaccumulation Factor (BAF) Supporting Information
BAF Calculation Description for PFOA

The EPA used the decision framework presented in the Technical Support Document, Volume 2:
Development of National Bioaccumulation Factors (Technical Support Document, Volume 2)
(EPA, 2003) to identify procedures to derive national trophic level-specific BAFs for PFOA based
on chemical's properties (e.g., ionization, hydrophobicity), metabolism, and biomagnification
potential (see Figure 1 this document). The EPA followed the guidelines provided in Section 5.5
of the EPA's 2000 Methodology (EPA, 2000), to assess the occurrence of cationic and anionic
forms of PFOA at typical environmental pH ranges. Based on the dissociation constant (pKa)
information provided in the Hazardous Substance Data Bank (HSDB) for PFOA, it was
determined that ionization of PFOA was significant at typical environmental pH ranges (NCBI,
2023; EPA, 2024a,b).

As explained in Section 5.5 of EPA's 2000 Methodology (EPA, 2000), when a significant fraction
of the total chemical concentration is expected to be present as the ionized species in water,
procedures for deriving the national BAF rely on empirical (measured) methods (i.e.,

Procedures 5 and 6) in Figure 1. EPA followed the guidelines in Section 3.2.1 of the Technical
Support Document, Volume 2, to evaluate the biomagnification potential of PFOA. Based on
information in the peer-reviewed literature, it was determined that biomagnification of PFOA
was unlikely (Houde et al. 2011; Du et al., 2021; Munoz et al., 2022). Based on the
characteristics of PFOA, EPA selected Procedure 5 for deriving national BAF values for this
chemical.

As described in Section 4.2.1, for a given procedure, the EPA selected the method that provided
BAF estimates for all three TLs (TL 2-TL 4) in the following priority:

•	BAF estimates using the BAF method (i.e., based on field-measured BAFs) if possible.

•	BAF estimates using the laboratory BCF method if (a) the BAF method did not produce
estimates for all three TLs and (b) the BCF method produced national-level BAF
estimates for all three TLs.

The EPA was able to locate field-measured BAFs for TLs 2, 3, and 4 for PFOA from the peer-
reviewed literature sources for which sufficient information was provided to determine the
quality and usability of the data. Therefore, the EPA used the Field BAF method (EPA, 2003) to
derive the national BAF values for this chemical.

Calculating Baseline BAFs

The EPA calculated baseline BAFs for PFOA using a procedure analogous to the baseline BAF
calculation for nonionic organic chemicals to account for the physical and chemical properties
of PFOA. Dissolved field measured BAFs were considered to be 100 percent bioavailable for the
purposes of the baseline BAF calculation. Field measured BAFs reported in total concentrations
were converted to dissolved BAFs using Kpoc values (the equilibrium partition coefficient of the
chemical between the particulate organic carbon [POC] phase and the freely dissolved phase of
water), from the peer-reviewed literature; these BAF data converted from total to dissolved

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were added to the dissolved field measured BAF data set and used to calculate baseline BAFs
forTLs 2, 3, and 4.

Methods for calculating baseline BAFs ((Baseline BAF)ii_n) involves normalizing the field-
measured BAF, which are based on total concentrations in tissue and water, by the lipid
content in the organism and the freely dissolved concentration in the study water (EPA, 2000,
2003). As described in ATSDR (2021), the partitioning of PFOA is related to protein binding
properties (ATSDR, 2021). The EPA considered protein-normalizing measured BAF values in the
baseline BAF equation. However, insufficient data were available from the scientific literature
on protein content of aquatic organisms and on the binding efficiencies of PFOA to various
proteins in aquatic organisms. Because of this lack of data on the relationship between protein
content and PFOA bioaccumulation, attempts to normalize BAFs based on protein content
would likely introduce greater uncertainty into BAF averages.

Consistent with the EPA's 2000 Methodology (EPA, 2000), a procedure analogous to the one
used to adjust for the water-dissolved portions of a nonionic organic chemical is applied to
measured BAFs for PFOA. As described in the EPA's (2003) Technical Support Document,
Volume 2, the Kpoc is approximately equal to the Kow of a hydrophobic organic chemical. It is
further described in the EPA's (2003) Technical Support Document, Volume 2, that Kdoc (the
equilibrium partition coefficient of the chemical between the dissolved organic carbon (DOC)
phase and the freely dissolved phase of water) is directly proportional to the Kow of a
hydrophobic organic chemical, and that Kdoc is less than the Kow. Due to the unique physical-
chemical properties of PFOA, Kow cannot be reliably measured for these compounds and
therefore cannot be used to estimate Kpoc or Kdoc (ATSDR, 2021).

Using the Koc information in Higgins and Luthy (2006), the EPA determined that the Koc values
were applicable to POC but there is no indication that they would be applicable to DOC.
Currently, information is not available on the partitioning of PFOA to DOC, nor on the
bioavailability of PFOA partitioned to DOC. In addition, Higgins and Luthy (2006) included DOC-
bound PFOA in the aqueous phase of their calculations. Thus, the amount of PFOA partitioned
to DOC was presumed to be part of the aqueous fraction of the//d equation, resulting in the
following formula (Equation 1):

ffd_	(Eq.l)

n + (POC-Koc)l

Where:

•	ffd = fraction of the total concentration of chemical in water that is freely dissolved.

•	POC = national default value of 0.5 mg/L (refer to page 5-44 of EPA's 2000 Methodology
(EPA, 2000)) is used in baseline BAF calculations, unless this value is reported in the BAF
source.

•	Koc = PFOA log Koc = 2.06 (Higgins and Luthy, 2006).

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Because the measured BAFs for PFOA are not adjusted for lipid or protein content, the baseline
BAF equation (refer to Equation 5-10 on pages 5-24 and 5-25 of the EPA's 2000 Methodology
[EPA, 2000]) is adjusted (as shown below in Equation 2) to determine the freely dissolved
concentration of PFOA BAFs in water:

.. _ . _ Measured BAF .

Baseline BAF =			1	(Eq. 2)

ffd

The EPA used this equation to calculate baseline BAFs from field measured BAFs based on total
concentrations.

Dissolved PFOA Baseline BAFs

The EPA included results from several field BAF studies for PFOA reported as dissolved (i.e.,
filtered) concentrations in its baseline BAF calculations. Because these dissolved PFOA data are
presumed to represent the freely-dissolved (non-particulate) fraction, the ffd term in Equation
2 is set to 1. Also, as described above, the measured BAFs for PFOA are not being adjusted for
lipid or protein content to calculate baseline BAFs for PFOA. Thus, Equation 3 is used to
calculate the freely dissolved concentration of PFOA for "baseline BAFs" using field-measured
dissolved PFOA BAFs:

Baseline BAF = Measured (dissolved) BAF — 1	(Eq. 3)

Calculating National BAFs

Final baseline BAFs were used to compute national BAFs for PFOA. Equation 4 (an equation
analogous to the equation used for nonionic organic chemicals for calculating national BAFs
(see Equation 5-28 on Page 5-42 of the EPA's 2000 Methodology (EPA, 2000)) is used to convert
the baseline BAF to a national BAF for each trophic level:

National BAF(XLn) = [(Final Baseline BAFfd)TLn + 1] • (ffd)	(Eq. 4)

Where:

•	National BAF = national BAF (L/kg-tissue).

•	(Final Baseline BAF)iLn= mean baseline BAF forTL "n" (L/kg-lipid).

•	ffd = fraction of the total concentration of chemical in water that is freely dissolved.

In summary, for PFOA, the baseline BAFs are calculated using Equation 2 (for field BAFs
calculated from total water concentrations) and Equation 3 (for field BAFs calculated from
dissolved water concentrations) for each TL. National BAFs are then calculated from TL baseline
BAFs using Equation 4.

National Trophic level BAF calculations:

National BAF PF0A(TL2) = [(21.2)TL2 + 1] x (0.999942596)

= 22.2 L/kg
= 22 L/kg (rounded)

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National BAFPFOA(XL3) = [(47.9)XL3 + 1] x (0.999942596)

= 48.9 L/kg
= 49 L/kg (rounded)

National BAF PF0A(TL4) = [(30.0)TL4 + 1] x (0.999942596)

= 30.9 L/kg
= 31 L/kg (rounded)

The corresponding values for TL 2, TL 3 and TL 4 were computed as 22.2 L/kg, 48.9 L/kg and
30.9 L/kg, respectively. Rounding the values to two significant figures yields national BAF values
of 22, 49 and 31 L/kg for TLs 2, 3, and 4, respectively.

References

ATSDR (Agency for Toxic Substances and Disease Registry). 2021. Toxicological Profile for
Perfluoroalkyls. U.S. Department of Health and Human Services, Agency for Toxic
Substances and Disease Registry, Atlanta, GA.
https://www.atsdr.cdc.gov/ToxProfiles/tp200.pdf.

Du, D., Y. Lu, Y. Zhou, Q. Li, M. Zhang, G. Han, H. Cui, and E. Jeppesen. 2021. Bioaccumulation,
trophic transfer and biomagnification of perfluoroalkyl acids (PFAAs) in the marine food
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EPA (Environmental Protection Agency). 2000. Methodology for Deriving Ambient Water
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EPA (Environmental Protection Agency). 2003. Methodology for Deriving Ambient Water

Quality Criteria for the Protection of Human Health (2000), Technical Support Document
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EPA (Environmental Protection Agency). 2015. Development of National Bioaccumulation

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EPA (Environmental Protection Agency). 2024a. Final Human Health Toxicity Assessment for
Perfluorooctanoic Acid (PFOA) and Related Salts. EPA 815-R-24-006. EPA, Office of
Water, Washington, DC. https://www.epa.gov/system/files/documents/2024-
04/main final-toxicity-assessment-for-pfoa 2024-04-09-refs-formatted.pdf.

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EPA (Environmental Protection Agency). 2024b. Final. Appendix: Human Health Toxicity

Assessment for Perfluorooctanoic Acid (PFOA). EPA 815-R-24-008. EPA, Office of Water,
Washington, DC. https://www.epa.gov/svstem/files/documents/2024-
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Higgins, C. and R. Luthy. 2006. Sorption of perfluorinated surfactants on sediments.
Environmental Science & Technology 40(23):7251-7256.

Houde, M., A.O. De Silva, D.C. Muir, and R.J. Letcher. 2011. Monitoring of perfluorinated

compounds in aquatic biota: An updated review. Environmental Science & Technology
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Munoz, G., L. Mercier, S.V. Duy, J. Liu, S. Sauve, and M. Houde. 2022. Bioaccumulation and

trophic magnification of emerging and legacy per-and polyfluoroalkyl substances (PFAS)
in a St. Lawrence River food web. Environmental Pollution 309:119739.
https://www.sciencedirect.com/science/article/pii/S02697491220Q9538.

NCBI (National Center for Biotechnology Information). 2023. PubChem Compound Summary for
Perfluorooctanoic Acid. U.S. National Library of Medicine, NCBI, Bethesda, MD.
https://pubchem.ncbi.nlm.nih.gov/compound/Perfluorooctanoic-acid.

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Appendix B: Comparative Analysis for Potentially Sensitive Populations for PFOA

The EPA evaluated several exposure scenarios for PFOA to determine whether the national
recommended criteria based on carcinogenic effects are sufficiently protective of potentially
sensitive subpopulations related to the noncancer health effects. To accomplish this, the EPA
considered four additional exposure scenarios, as supported by data from the EPA Exposure
Factors Handbook (EFH; EPA, 2011) and the Human Health Methodology (EPA, 2000).
Specifically, the EPA evaluated exposure parameters for "all ages" as well as four potentially
sensitive life stages associated with the critical effects used to derive the PFOA chronic RfD, i.e.,
co-critical effects of decreased serum anti-tetanus and anti-diphtheria antibody concentrations
in children (PFOA concentration measured at age 5 and antibody concentration measured at
age 7), decreased infant birth weight, and increased total cholesterol in adults. Based on this
exposure interval in the critical study, the potentially sensitive subpopulations in humans
include women of childbearing age who may be or become pregnant, pregnant women,
lactating women, and early childhood (ages 1 to < 3 years and 3 to < 6 years) (EPA, 2024; Table
B-l, this document). The age ranges for early childhood were selected because they are
relevant to the exposure in the critical study (e.g., children were exposed through infancy to
age five) and based on data availability (e.g., trophic level specific fish consumption rates).

For the body weight exposure parameter, a mean bodyweight of 75 kg for pregnant women (all
trimesters) was identified in the EFH (2011, Ch. 8, Table 8-29). Representative body weights for
the "all ages" scenario and lactating women populations were not specifically presented in the
EFH (EPA, 2011). To address this data limitation, for this exercise, the EPA assumed that the
average body weight for "all ages" was 71.6 kg based on the sum of the time-weighted
averages of the mean male and female combined body weights from 1 year up to 80 years old
from the NHANES (1999-2006) (Table 8-3; EPA, 2011). A body weight average of 67 kg for
women of childbearing age was identified in the Human Health Methodology (EPA, 2000);
however, this average is based on an older NHANES dataset (NHANES III; WESTAT 2000). More
recent NHANES data (1999-2006) suggest that the mean body weight for women of
childbearing age ranges from 65.9 kg for 16 to < 21-year-olds to 77.1 kg for 40 to < 50-year-olds
(Table 8-5; EPA, 2011). Using these data, the EPA assumed a time-weighted average body
weight of 73.4 kg for women of childbearing age (Table 8-5; EPA, 2011). The EPA also used this
body weight for women of childbearing age as a proxy for lactating women, in the absence of
other data. For children 1 to < 3 years, an average bodyweight of 11.4 kg for children
1 to < 2 years was used as a proxy for children 1 to < 3 years (EPA, 2011, Table 8-1). For children
3 to < 6 years, a mean of 18.6 kg was used (EPA, 2011, Table 8-1).

Drinking water intake values were available for all populations (Table B-l, this document).

The EPA encountered several data limitations for trophic level specific fish consumption rates
for some of these potentially sensitive populations. The EPA's national criteria are typically
derived using trophic-level specific fish consumption rates (FCRs), paired with trophic-level
specific bioaccumulation factors (BAFs) to account for the potential bioaccumulation of some
chemicals in aquatic food webs and the broad physiological differences between trophic levels
which may influence bioaccumulation (EPA, 2000). Trophic level specific FCRs for women of

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Table B-l. Comparison of noncancer-based HHC values for different candidate sensitive
populations identified from the critical effect and study.	

Population

Bodyweight
(kg)

Drinking
Water Intake
(L/day)

Fish Consumption Rate
(g/day)

Criteria (pg/L)

Total

TL 2

TL 3

TL 4

W + O

00

General, adult
(> 21 years)

80a

2.3b

22c

7.6C

8.6C

5.r

0.0002

0.0006

Women of childbearing
Age (13-49 years)

73.4d

2.1e

15.8C

5.6C

6.0C

2.9C

0.0002

0.0009

Children 1 to < 3 years

11.4f

0.507g

4.7h

1.2h

1.4h

1.2h

0.0001

0.0005

Children 3 to < 6 years

18.6'

0.588

5.8h

1.7h

2.5h

l.lh

0.0001

0.0006

All Ages

(Birth to 80 years)

71.6k

2.0b

19.31

NA

NA

NA

ND

ND

Pregnant Women

75m

2.1e

10"

NA

NA

NA

ND

ND

Lactating Women

73.4d

2.T

7.2°'p

NA

NA

NA

ND

ND

Notes: g/day = grams offish consumed per day; L/day = liters of water per day; NA = not available; ND = not

determined; 00 = organism only; W + O = water plus organism.

a EPA, 2011, Exposure Factors Handbook, Ch. 8, Table 8-1, NHANES 1999-2006. Recommended mean bodyweight
for adults.

b Estimated using the FCID calculator (University of Maryland, 2024; https://fcid.foodrisk.org/), NHANES 2005-
2010, community water, 90th percentile per capita rate.

c EPA, 2014; NHANES 2003-2010 survey data, 90th percentile per capita rate, freshwater and estuarine fish and
shellfish edible portion, adults > 21 years.

dTime weighted average of combined bodyweights for women ages 16 to < 50 years, NHANES 1999-2006 (EPA,
2011; Table 8-5).

e EPA, 2019, Exposure Factors Handbook; Update Ch. 3., Table 3-62, Community water, 90th percentile, per capita
rate.

f EPA, 2011, Exposure Factors Handbook, Ch. 8, Table 8-1, NHANES 1999-2006. Recommended mean bodyweight
ages 1 to < 2 years.

g Estimated using the FCID calculator (University of Maryland, 2024; https://fcid.foodrisk.org/), NHANES 2005-
2010, community water, 90th percentile per capita rate, age 1 to < 3 years.

h EPA, 2014. NHANES 2003-2010 survey data, 90th percentile per capita rate, freshwater and estuarine fish and
shellfish edible portion, Tables 27a, 28a, 29a, ages 1 to < 3 years.

' EPA, 2011, Exposure Factors Handbook, Ch. 8, Table 8-1, NHANES 1999-2006. Recommended mean bodyweight
ages 3 to < 6 years.

J Estimated using the FCID calculator (University of Maryland, 2024; https://fcid.foodrisk.org/), NHANES 2005-
2010, community water, 90th percentile per capita rate, ages 3 to < 6 years.

kTime weighted average of mean male and female combined body weights from 1 year up to 80 years, NHANES
1999-2006 (EPA, 2011; Table 8-3).

1 Estimated using the FCID calculator (University of Maryland, 2024; https://fcid.foodrisk.org/), NHANES 2005-
2010; freshwater and estuarine fish and shellfish combined, 90th percentile per capita rate; male and female, all
ages included.

m EPA, 2011, Exposures Factors Handbook, Ch 8, mean, NHANES 1999-2006, Table 8-29

" Estimated using the FCID calculator (University of Maryland, 2024; https://fcid.foodrisk.org/), NHANES 2005-
2010; freshwater and estuarine fish and shellfish combined, 90th percentile per capita rate pregnant females
only.

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° Estimated using the FCID calculator (University of Maryland, 2024; https://fcid.foodrisk.org/), NHANES 2005-
2010; freshwater and estuarine fish and shellfish combined, 90th percentile per capita rate, breastfeeding
females only.

p Estimates are less statistically reliable based on guidance published in the Joint Policy on Variance Estimation and
Statistical Reporting Standards on NHANES III and CSFII Reports.

childbearing age and children were identified (Table B-l). However, trophic level specific FCRs
are not available for three of the potentially sensitive life stages—all ages, pregnant women, or
lactating women. Therefore, criteria could not be calculated for these three life stages.
However, in these cases with available data, the total FCR for the alternative scenarios is lower
than the FCR for the general population. Because bodyweights for all ages, pregnant women,
and lactating women are similar to the general population (see above and Table B-l), the FCR is
likely to be the main determinant of the criteria value, with a larger FCR resulting in a lower,
more health protective criterion. Therefore, criteria based on the general population are
expected to be protective of the identified potentially sensitive life stages (Table B-l).
Separately, paired bodyweight adjusted FCRs are not available for specific trophic levels which
precludes the use of body-weight adjusted DWI rates to derive ambient water quality criteria.

For illustrative purposes, the EPA calculated noncancer-based criteria based on the exposure
parameters for women of childbearing age, children ages 1 to < 3 years, and children ages 3
to < 6 years. As demonstrated in Table B-l, criteria based on the exposure inputs for children
1 to < 3 years result in a slightly more health protective noncancer criteria as compared to the
general population; however, the national recommended criteria for PFOA
(0.00000060 |ag/L W + O and 0.0000036 |ag/L OO) are based on the carcinogenic toxicological
endpoint (CSF), which results in the most health protective criteria overall. Therefore, the
criteria based on carcinogenic effects of PFOA is protective of the noncancer-based criteria
derived for the potentially sensitive populations and life stages.

References

EPA (Environmental Protection Agency). 2000. Methodology for Deriving Ambient Water Quality
Criteria for the Protection of Human Health (2000). EPA-822-B-00-004. EPA, Office of
Water, Office of Science and Technology, Washington, DC. Accessed January 2024.
https://www.epa.gov/sites/default/files/2018-10/documents/methodology-wqc-
protection-hh-2000.pdf.

EPA (Environmental Protection Agency). 2011. Body Weight Studies. Chapter 8 in Exposure
Factors Handbook. EPA/600/R-09/052F. EPA, National Center for Environmental
Assessment, Office of Research and Development, Washington, DC. Accessed August
2024. https://www.epa.gov/sites/default/files/2015-09/documents/efh-chapter08.pdf.

EPA (Environmental Protection Agency). 2014. Estimated Fish Consumption Rates for the U.S.

Population and Selected Subpopulations (NHANES 2003-2010). EPA-820-R-14-002. EPA.
Accessed August 2024. https://www.epa.gov/sites/default/files/2015-
01/documents/fish-consumption-rates-2014.pdf.

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EPA (Environmental Protection Agency). 2019. Update for Chapter 3 of the Exposure Factors

Handbook, Ingestion of Water and Other Select Liquids. EPA/600/R-18/259F. EPA, Office
of Research and Development, National Center for Environmental Assessment,
Washington, DC. Accessed August 2024.

https://www.epa.gov/sites/default/files/2019-02/documents/efh -
chapter 3 update.pdf.

EPA (Environmental Protection Agency). 2024. Final. Appendix: Human Health Toxicity

Assessment for Perfluorooctanoic Acid (PFOA). EPA 815-R-24-008. EPA, Office of Water,
Washington, DC. https://www.epa.gov/system/files/documents/2024-
04/appendix final-toxicity-assessment-for-pfoa 2024-04-09-refs-formatted.pdf.

WESTAT. 2000. Memorandum on Body Weight Estimates Based on NHANES III Data, Including
Data Tables and Graphs. Analysis Conducted and Prepared by WESTAT under EPA
Contract No. 68-C-99-242. March 3, 2000.

University of Maryland. 2024. What We Eat in America—Food Commodity Intake Database
2005-10. University of Maryland, College Park, Maryland and EPA Office of Pesticide
Programs, Washington, DC. Accessed August 2024. https://fcid.foodrisk.org/.

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