Summary: This post analyzes how the Trump administration’s push to fast-track chemical reviews tied to data centers could lower barriers for new chemicals — including PFAS-like “forever chemicals” — to enter U.S. markets with less oversight. I walk through the policy mechanics, who benefits, the science behind immersion cooling and semiconductors, the regulatory gaps, likely outcomes, and practical checks that would reduce risk without killing innovation. Read it as both a warning and a set of pragmatic fixes that balance manufacturing momentum with public health.
Policy shift and the fast-track for “qualifying project” chemicals
The Environmental Protection Agency announced it will prioritize reviews for new chemicals used in data centers or related projects. That means companies can ask for expedited attention by showing the chemical supports a qualifying project. Qualifying project is the exact phrase used: a data center, a project that adds at least 100 megawatts to the grid, a project protecting national security, or any project a cabinet secretary declares applicable.
On paper the EPA says no steps in the review will be skipped and that scientific standards remain intact. In practice, the change hands power to political and interagency signoffs that can be as informal as a letter from a contact at Defense or Commerce. That creates a new path to speed: fast-track the approval of new chemicals by tying them to a high-priority infrastructure project. Fast-track the approval. Fast-track the approval. Saying it twice isn’t repetition — it’s the hinge of the policy.
Who benefits: chemicals firms, cooling suppliers, and chip makers
Industry players are clear about what they hope to gain. Big oil-and-chemical firms like Exxon and Shell have moved into specialty cooling fluids. Chemours has publicly pushed two‑phase immersion fluids and told regulators that faster approvals would help U.S. competitiveness. Semiconductor trade groups such as SEMI are lobbying for access to chemicals used across fabrication steps.
There’s social proof here: companies with deep pockets and regulatory experience — and a record of litigation over similar substances — are already lining up. Microsoft tested immersion cooling but says it’s not using the tech at scale right now. That caution signals firms know the public and legal stakes. Yet the commercial pressure is strong: faster approvals speed product launches, secure market share, and lower capital risk for huge data center and fab projects.
What immersion cooling is and why PFAS-like fluids matter
Immersion cooling swaps air and fans for liquids. Two‑phase immersion pushes it further: a liquid boils into gas at the hot components, condenses on cooling coils, and drips back. The result is far higher cooling efficiency and much lower electricity draw. The savings matter: data centers burn enormous power to keep chips running.
The fluids that enable two‑phase cooling frequently contain fluorine‑carbon chemistries that behave like per‑ and polyfluoroalkyl substances, commonly called PFAS. PFAS are persistent in the environment and bioaccumulate. Studies link them to cancer, reproductive harm, and immune effects. Regulators in the European Union and several U.S. states are moving to curb PFAS. That regulatory pressure is why some companies explicitly market PFAS‑free products, and why others — like Chemours — test new fluorinated fluids with one eye on approvals.
Regulatory mechanics and the loopholes
The new program requires proof that a chemical is tied to a qualifying project. But current instructions let a single endorsement from a cabinet agency official suffice — no technical proof required. Greg Schweer, who ran EPA’s new chemicals branch for years, warns that this is a big loophole. An industry contact at Commerce, Defense, or Energy can sign a letter and the expedited path opens. That makes the process vulnerable to influence, and reviewers pressured to move quickly may look for shortcuts when data are ambiguous.
We should ask: who benefits when review timelines are compressed? Companies with ready dossiers and regulatory experience. Who loses if evidence is thin or long‑term harm is missed? The public, downstream communities, and taxpayers who pay cleanup costs. That tension between speed and rigor is the policy’s practical fault line.
Why the semiconductor sector matters here
Semiconductor fabs use a wide array of advanced chemicals, including fluorinated substances in photolithography and cleaning steps. If the EPA prioritizes chemical reviews supporting chip fabs and data centers, then a large proportion of new chemical submissions could come from the semiconductor supply chain.
Schweer and other experts noted the semiconductor industry already filed many applications in his final years at EPA. SEMI’s push for regulatory certainty is straightforward: fabs are expensive and slow to build; chemical availability is a gating constraint. The result is an industry leaning on regulators for quicker access to new chemistries that support next‑generation chips.
Legal and reputational history matters
Companies such as 3M and DuPont, and spinoffs like Chemours, have deep litigation histories tied to PFAS contamination. Those records matter because they show what happens when persistent chemistries leave the plant: years of cleanup, settlements, and damaged trust. Some firms now advertise PFAS‑free lines. Some push new fluorinated fluids while noting energy savings of up to 90 percent for cooling. The sales pitch — save power, save money — lands easily with data center operators. The counterpoint — persistent pollution and future liability — lands with communities and regulators.
Risk trade-offs: speed, competitiveness, and long-term cost
The administration frames the move as a competitiveness play: build infrastructure to support AI and manufacturing, and don’t let regulation slow it down. That’s a legitimate economic goal. At the same time, environmental and public health risk is real and measurable. Approving persistent chemistries for broad industrial use creates long tails of liability and environmental burden we will pay for decades.
We can acknowledge both perspectives. Industry wants predictable, fast access to materials so projects don’t stall. Communities want confidence that new chemicals won’t create new contamination. How do we square these demands without reflexively choosing one over the other? I’ll ask you: what standards for proof and transparency would make rapid review acceptable to you?
Practical checks that protect public health while keeping progress moving
Speed is useful when it’s paired with guardrails. Here are concrete steps that keep the expedited path from becoming a shortcut to unknown harms:
- Require technical substantiation for qualifying project claims, not just a letter. If a secretary signs off, make the company attach the technical rationale and data showing unique need.
- Apply a precautionary conditional approval: allow pilot deployment limited in scale and duration while independent monitoring runs in parallel.
- Mandate third‑party testing and public disclosure of degradation, persistence, and bioaccumulation data for any fluorinated fluid proposed for two‑phase cooling.
- Use class‑based regulatory thinking: don’t approve single PFAS analogs while ignoring the class behavior of similar molecules.
- Require manufacturers to post financial assurance or bonds that cover remediation if contamination is later linked to the product.
- Create fast public comment windows and require agencies to publish a clear, documented rationale when they prioritize a review.
These checks don’t kill innovation. They create predictable, accountable paths to market. Predictability helps industry plan; accountability protects the public and reduces long-term litigation risk — which is what ultimately protects investors too.
What to watch next
Watch four things closely in the coming months: rule text at the EPA; product commercialization timelines from Chemours and others; public comments from SEMI and other trade groups; and state and EU regulatory moves on PFAS. Each will shape whether this fast-track becomes a safe accelerator or a loophole that invites future crises.
Questions to provoke better policy and better business choices
I’ll finish with open questions to start a discussion. These are the kind of questions regulators, companies, and communities should negotiate over — honestly:
- What definition of “qualifying project” would prevent misuse while keeping genuine projects fast? How would you test that definition in practice?
- If you were a data center operator, what transparency would you demand before using a new cooling fluid on site?
- If you work for a company seeking a fast review, what can you commit to publicly to build trust? What would you refuse to trade off? No?
- Who should hold liability if a fast‑tracked chemical later proves harmful — the manufacturer, the operator, the government? How do you allocate responsibility so incentives align for safety?
Mirror back the core choice: faster approvals for data center projects, or more exhaustive review that slows deployment. Which do you pick, and why?
The push to accelerate AI and data infrastructure is real and urgent for many businesses. I don’t deny the value of speed. I’m asking for a practical bargain: we move fast, but we bind speed to transparent testing, independent oversight, and financial accountability. That trade keeps markets healthy and prevents repeating mistakes that have cost companies and communities dearly before.
#DataCenters #PFAS #ChemicalSafety #AIInfrastructure #Manufacturing #EnvironmentalPolicy #RegulatoryReform
Featured Image courtesy of Unsplash and Đào Hiếu (2snX_tffBxM)
