are considered as important sources of PFOA to the environment, Most industrialized nations have average PFOA blood serum levels ranging from 2 to 8 parts per billion; the highest consumer sub-population identified was in Korea—with about 60 parts per billion. In Peru, Vietnam, and Afghanistan blood serum levels have been recorded to be below one part per billion. In 2003–2004 99.7% of Americans had detectable PFOA in their serum with an average of about 4 parts per billion, and concentrations of PFOA in US serum have declined by 25% in recent years. Despite a decrease in PFOA, the longer perfluorinated carboxylic acid PFNA is increasing in the blood of US consumers. PFAS are also found in paper mill residuals, digestates, composts, and soils. Given the ubiquity of PFAS, and the comparative background levels which may be found in wastewater, biosolids, and leachates, setting requirements near analytical detection limits on these sources may not provide a discernable benefit to protecting public health. Industrial sources PFOA is released directly from industrial sites. For example, the estimate for the DuPont Washington Works facility is a total PFOA emissions of 80,000 pounds (lbs) in 2000 and 1,700 pounds in 2004. A 2006 study, with two of four authors being DuPont employees, estimated about 80% of historical perfluorocarboxylate emissions were released to the environment from fluoropolymer manufacture and use. PFOA can be measured in water from industrial sites other than fluorochemical plants. PFOA has also been detected in emissions from the carpet industry, paper and electronics industries. The most important emission sources are carpet and textile protection products, as well as fire-fighting foams. Precursors PFOA can form as a breakdown product from a variety of precursor molecules. In fact, the main products of the fluorotelomer industry, fluorotelomer-based polymers, have been shown to degrade to form PFOA and related compounds, with half-lives of decades, both biotically and by simple abiotic reaction with water. It has been argued that fluorotelomer-based polymers already produced might be major sources of PFOA globally for decades to come. Other precursors that degrade to PFOA include 8:2 fluorotelomer alcohol (F(CF2)8CH2CH2OH), polyfluoroalkyl phosphate surfactants (PAPS), and possibly N-EtFOSE alcohol (F(CF2)8SO2N(Et)CH2CH2OH). When PTFE (Teflon) is degraded by heat (pyrolysis) it can form PFOA as a minor product. The Organisation for Economic Co-operation and Development (OECD) has compiled a list of 615 chemicals that have the potential to break down into perfluorocarboxylic acids (PFCA) including