Comment-20158-Queensland Department of Environment and Science

Only listing PFOA as a single substance is not adequate to address the risk. PFOA has been out of production for some time. However, there are dozens of C8 substitute fluorotelomer PFAS in common use that are PFOA precursors that transform to PFOA upon release. This has long been established. All PFOA related compounds must be regarded as of the same risk and concern as PFOA as is now internationally recognised (see UNEP CoP9 recommendation). This includes complex fluorotelomer PFAS such as 8:2, 10:2, 12:2 and 14:2 fluorotelomers commonly used in firefighting foam and materials treatments. These compounds all have long-chain fluorinated carbon backbones as does PFOA with a diversity of functional groups that degrade in the environment to generate end-point carboxylate compounds including PFOA. At a minimum all fluorotelomers with a perfluorinated chain of C8 (8:2Ft etc.) that generate PFOA should be regarded the same as PFOA. Longer chain fluorotelomers can also generate PFOA through progressive transformation.