Beyond the Firehouse: PFAS Occupational Exposures Across Industries
Firefighter PFAS exposure has received significant public and scientific attention—rightly so, given the intense PFAS burdens documented in this occupational group. But firefighters represent only one of many worker populations facing significant occupational PFAS exposures. Electronics and semiconductor workers, fluorochemical manufacturing employees, metal plating workers, textile and carpet manufacturing operatives, and workers in food packaging production all face PFAS exposures in workplace environments that lack comprehensive occupational exposure standards. For these millions of workers, the gap between firefighter-focused PFAS health protection discourse and the actual occupational PFAS regulatory framework creates a significant inequality in worker protection.
Semiconductor Manufacturing: A High-Exposure Industry
Semiconductor fabrication relies on perfluorinated etching gases (PFCs including CF4, C2F6, NF3), PFAS photoresists, fluorinated cleaning agents, and PFAS-based chemical mechanical planarization (CMP) slurries in processes running continuously across massive cleanroom facilities. Workers in semiconductor fabs—wafer operators, process engineers, and maintenance technicians—handle or work in proximity to PFAS-containing process chemicals daily. Industrial hygiene monitoring programs at semiconductor fabs have detected airborne PFAS in certain process areas, and biomonitoring studies of semiconductor workers have found elevated blood PFAS concentrations compared to general population levels.
The global semiconductor manufacturing workforce—concentrated in Taiwan, South Korea, the United States, Japan, and increasingly Europe—represents a substantial occupationally exposed population whose PFAS health risks are poorly characterized relative to their exposure magnitude. The semiconductor industry’s rapid expansion under government subsidization programs in the CHIPS Act era will increase the number of workers in high-PFAS-exposure settings, making occupational health standard development for semiconductor PFAS an urgent priority.
Fluorochemical Manufacturing Workers: The Highest Exposures
Workers in PFAS manufacturing facilities—producing PTFE, fluoropolymers, PFOA, PFOS, and their replacements—face the highest occupational PFAS exposures of any workforce. Historical biomonitoring programs at DuPont’s Washington Works facility found serum PFOA levels in plant workers that were orders of magnitude above general population levels. Medical surveillance of these workers—the earliest and most intensively exposed PFAS cohort—provided some of the first evidence of PFAS health effects in humans, including liver enzyme elevation, thyroid dysfunction, and the basis for DuPont’s C8 panel health findings.
Current fluorochemical manufacturing workers—at facilities producing GenX compounds, PFBS, and fluoropolymers that have replaced legacy PFAS—are exposed to the replacement chemistry in facilities where legacy PFAS may persist in environmental media from historical production. Occupational exposure limits for replacement PFAS compounds are largely absent, with NIOSH and OSHA yet to develop permissible exposure limits specific to the new generation of fluorochemicals. This regulatory gap creates a worker protection vacuum precisely where exposures are highest.
OSHA and NIOSH Action
The Occupational Safety and Health Administration (OSHA) has not established permissible exposure limits (PELs) for any PFAS compound—leaving worker PFAS exposure unregulated under federal occupational health law. The National Institute for Occupational Safety and Health (NIOSH) has conducted health hazard evaluations at several PFAS-using workplaces and published recommended exposure limits for PFOS and PFOA, but NIOSH recommendations lack OSHA enforcement authority. The AFL-CIO and industrial hygiene professional organizations have petitioned OSHA to develop PFAS occupational exposure standards, with the agency’s response—and timeline for any rulemaking—remaining uncertain as of 2024. In the absence of federal standards, employers relying on voluntary best practices and state-level programs in states with occupational PFAS health standards (including California’s Prop 65 requirements) provide uneven worker protection across the PFAS-using workforce.