Chemical companies are phasing out certain PFAS commonly used in fast food wrappers – read the full story and report at C&EN.
Chemical manufacturers are planning to gradually ramp down sales of certain short-chain per- and polyfluoroalkyl substances (PFAS) used as grease-proofing agents on fast food wrappers, take-out containers, and other paper-based food packaging, the US Food and Drug Administration announced July 31.
AGC Chemicals Americas, Archroma Management, and Daikin America will phase out sales of substances that contain 6:2 fluorotelomer alcohol (6:2 FTOH) for use in paper and cardboard food packaging beginning in January 2021. The process is expected to take 3 years, with up to an additional 18 months to use up existing stocks. A fourth company, Chemours, told the FDA last year that it has already stopped selling the substances in the US market.
PFAS that contain 6:2 FTOH replaced long-chain PFAS in food packaging nearly a decade ago because of concerns about the safety of long-chain PFAS, which are linked to cancer and immune disorders. FDA scientists, however, are now questioning the safety of those replacements. Data from rodent studies suggest that 6:2 FTOH accumulates in the body, the FDA reported in January (Toxicol. Appl. Pharmacol. 2020, DOI: 10.1016/j.taap.2020.114878).
“The data suggest the potential of 6:2 FTOH to also persist in humans from chronic dietary exposure,” the FDA says in a statement. “Further scientific studies are needed to better understand the potential human health risks from dietary exposure to food-contact substances that contain 6:2 FTOH.”
Rather than conduct those tests, the three manufacturers of the substances in question agreed to phase out sales in the US. – read the full story and report at C&EN.
Our most recent Bulletin summarizes the 2020 USEPA Adds 172 PFAS Chemicals to EPCRA TRI Reporting Program. The new PFAS rule went into effect on June 22, 2020. However, the rule requires PFAS to be included in TRI reports submitted for all 2020 calendar year activity (i.e., January 1 through December 31). The deadline for submitting the 2020 TRI reports is July 1, 2021.
All Other Miscellaneous Manufacturing (includes 1119, 1133, 2111, 4883, 5417, 8114)
424 Merchant Wholesalers, Non-durable Goods
425 Wholesale Electronic Markets and Agents Brokers
511, 512, 519 Publishing
562 Hazardous Waste
Federal Facilities
SCS Engineers will continue to post timely information, resources, and presentations to keep you well informed. These include additional guidance, industry reaction, and webinars for our clients.
When a release of PFAS occurs at a metal finishing facility, it is often due to the integrity of the wastewater system. Due to the persistence of PFAS and very low concentrations considered to be toxic, even water containing a small amount of PFAS can result in a large impact on the environment. If water can migrate into the subsurface, so can PFAS. Once in the soil, any water introduced into the soil can transport the PFAS into the groundwater.
The Californian chrome plating facilities are being required to test for PFAS even if there is no evidence of historical contamination at the property from any chemicals. Current testing is requiring the analysis of 25 different kinds of PFAS, including PFOS and 6:2 FTS.
Because such low concentrations of PFAS are considered to be toxic and their prevalence in common consumer products and tools, false-positive detections are common during the investigations for PFAS. False positives detections can lead to unnecessary expense and additional investigations. Therefore, selecting a knowledgeable, skilled, and experienced environmental consulting firm, is paramount to keeping the investigation as low cost as possible.
The author is Lynleigh Love a Senior Professional Geologist at SCS Engineers specializing in emerging contaminants.
PFAS are also key components in aqueous film-forming foam (AFFF), which is used to fight petroleum-based fires at aviation and manufacturing facilities. For decades, AFFF containing PFAS has been used extensively at airports throughout the world to protect the safety of passengers, crew, and others. The FAA requires that commercial airports train with, calibrate equipment with, and use the best performing AFFF fire suppression systems. AFFF is required to be used at airports and must be certified to meet strict performance specifications, including those mandated by the U.S. Department of Defense Military Specifications.
How can airports, the aviation industry, and manufacturers begin to mitigate PFAS health risks?
Lynleigh Love and Chris Crosby of SCS Engineers discuss the risks and issues with PFAS-based firefighting foam used at airports. The authors cover the regulatory climate, contamination investigations, operational and environmental management and litigation, along with alternatives to using traditional AFFF. There are some possible alternatives that can mitigate health risks in your community.
EPA Moves Forward on Key Drinking Water Priority Under PFAS Action Plan
WASHINGTON (Dec. 4, 2019) — Yesterday, the U.S. Environmental Protection Agency (EPA) sent the proposed regulatory determination for perfluorooctanesulfonic acid (PFOS) and perfluorooctanoic acid (PFOA) in drinking water to the Office of Management and Budget for interagency review. This step is an important part of EPA’s extensive efforts under the PFAS Action Plan to help communities address per- and polyfluoroalkyl substances (PFAS) nationwide.
“Under President Trump, EPA is continuing to aggressively implement our PFAS Action Plan – the most comprehensive cross-agency plan ever to address an emerging chemical,” said EPA Administrator Andrew Wheeler. “With today’s action, EPA is following through on its commitment in the Action Plan to evaluate PFOA and PFOS under the Safe Drinking Water Act.”
The action will provide proposed determinations for at least five contaminants listed on the fourth Contaminant Candidate List (CCL4), including PFOA and PFOS, in compliance with Safe Drinking Water Act requirements.
Background
The Safe Drinking Water Act establishes robust scientific and public participation processes that guide EPA’s development of regulations for unregulated contaminants that may present a risk to public health. Every five years, EPA must publish a list of contaminants, known as the Contaminant Candidate List or CCL, that are known or anticipated to occur in public water systems and are not currently subject to EPA drinking water regulations. EPA publishes draft CCLs for public comment and considers those prior to issuing final lists.
After issuing the final CCL, EPA determines whether or not to regulate five or more contaminants on the CCL through a process known as a Regulatory Determination. EPA publishes preliminary regulatory determinations for public comment and considers those comments prior to making final regulatory determinations. If EPA makes a positive regulatory determination for any contaminant, it will begin the process to establish a national primary drinking water regulation for that contaminant.
PFAS are a large group of man-made chemicals used in consumer products and industrial processes. In use since the 1940s, PFAS are resistant to heat, oils, stains, grease, and water—properties which contribute to their persistence in the environment.
The agency’s PFAS Action Plan is the first multi-media, multi-program, national research, management and risk communication plan to address a challenge like PFAS. The plan responds to the extensive public input the agency received during the PFAS National Leadership Summit, multiple community engagements, and through the public docket. The PFAS Action Plan outlines the tools EPA is developing to assist states, tribes, and communities in addressing PFAS.
EPA is taking the following highlighted actions:
Highlighted Action: Drinking Water
EPA is committed to following the national primary drinking water regulation rulemaking process as established by the Safe Drinking Water Act (SDWA).
EPA has sent the proposed regulatory determination for PFOA and PFOS to the Office of Management and Budget for interagency review.
The agency is also gathering and evaluating information to determine if regulation is appropriate for other chemicals in the PFAS family.
EPA is initiating the regulatory development process for listing certain PFAS as hazardous substances under CERCLA.
Highlighted Action: Monitoring
EPA will propose nationwide drinking water monitoring for PFAS under the next UCMR monitoring cycle.
Highlighted Action: Toxics
EPA has issued an advanced notice of proposed rulemaking that would allow the public to provide input on adding PFAS to the Toxics Release Inventory toxic chemical list.
A supplemental proposal to ensure that certain persistent long-chain PFAS chemicals cannot be manufactured in or imported into the United States without notification and review under the TSCA is currently undergoing interagency review at the Office of Management and Budget.
Highlighted Action: Surface Water Protection
EPA plans to develop national Clean Water Act human health and aquatic life criteria for PFAS, as data allows.
EPA is examining available information about PFAS released into surface waters by industrial sources to determine if additional study is needed for potential regulation.
Highlighted Action: Biosolids
EPA will be developing risk assessments for PFOA and PFOS to understand any potential health impacts.
EPA continues to compile and assess human and ecological toxicity information on PFAS to support risk management decisions.
EPA continues to develop new methods to test for additional PFAS in drinking water.
The agency is also validating analytical methods for surface water, ground water, wastewater, soils, sediments and biosolids; developing new methods to test for PFAS in air and emissions; and improving laboratory methods to discover unknown PFAS.
EPA is developing exposure models to understand how PFAS moves through the environment to impact people and ecosystems.
EPA continues to assess and review treatment methods for removing PFAS in drinking water.
EPA is working to develop tools to assist officials with the cleanup of contaminated sites.
Highlighted Action: Enforcement
EPA uses enforcement tools, when appropriate, to address PFAS exposure in the environment and assists states in enforcement activities.
Highlighted Action: Risk Communications
EPA will work collaboratively to develop a risk communication toolbox that includes multi-media materials and messaging for federal, state, tribal, and local partners to use with the public.
A full summary of EPA’s action to address PFAS can be found in the PFAS Action Plan:
For more information, article, and treatment options visit SCS Engineers.
Per- and poly-fluoroalkyl substances (PFAS) are receiving increasing attention from regulators and the media. Within this large group of compounds, much of the focus has been on two long-chain compounds that are non-biodegradable in the environment: PFOS (perfluorooctane sulfonate) and PFOA (perfluorooctanoic acid).
Long detected in most people’s bodies, research now shows how “forever chemicals” like PFAS accumulate and can take years to leave. Scientists have even tracked them in biosolids and leafy greens like kale. Recent studies have linked widely used PFAS, including the varieties called PFOA and PFOS, to reduced immune response and cancer. PFAS have been used in coatings for textiles, paper products, cookware, to create some firefighting foams and in many other applications.
Testing of large public water systems across the country in 2013 through 2015 found PFAS detected in approximately 4 percent of the water systems, with concentrations above the USEPA drinking water health advisory level (70 parts per trillion) in approximately 1 percent (from ITRC Fact Sheet). Sources of higher concentrations have included industrial sites and locations were aqueous film-forming foam (AFFF) containing PFAS has been repeatedly used for fire fighting or training. Source identification is more difficult for more widespread low-level PFAS levels.
With the EPA positioned to take serious action on PFAS in 2020 and beyond, regulators in many states have already started to implement their own measures, while state and federal courts are beginning to address legal issues surrounding this emerging contaminant. State actions have resulted in a variety of state groundwater standards for specific PFAS compounds, including some that are significantly lower than the USEPA advisory levels. These changes mean new potential liabilities and consequences for organizations that manufacture, use, or sell PFAS or PFAS-containing products, and also for the current owners of properties affected by historic PFAS use. If you operate a landfill or own a site with PFAS history this may be something you need to discuss and plan now.
Questions for property owners, property purchasers, and manufacturers include:
Should we test for PFAS? If so, where and how?
To what standards should we compare our results?
What will we do if we find PFAS?
If PFAS treatment or remediation is required, a number of established options to remove PFAS from contaminated soil and groundwater are available, including activated carbon, ion exchange or high-pressure membrane systems. On-site treatment options, including in-situ or ex-situ alternatives, the management of reject streams with concentrated PFAS waste where applicable, are also available.
Do You Need Help?
Need assistance with PFAS or have an idea that you would like to discuss? Contact , or find the SCS Engineers location nearest you.
This week, 271 chrome plating facilities in California received an order from the California State Water Resources Control Board (SWRCB) mandating the investigation of Per- and poly-fluoroalkyl substances (PFAS) at their facilities. Up until 2016, fume suppressants used by these facilities often contained perfluorooctanesulfonate (PFOS), a variety of PFAS.
PFAS consists of thousands of entirely man-made chemicals characterized by a strong bond between fluorine and carbon that have many manufacturing and industrial applications. They are also found in consumer products such as carpeting, apparel, personal care items, and fast food paper wrappings. PFAS is used in firefighting foam, wire and cable coatings, and in the manufacturing of semiconductors. Health studies have linked small doses of PFAS, including PFOS, to reduced immune response, raised cholesterol, and cancer.
PFAS has been widely used within the chrome plating industry as a chemical fume suppressant. According to the National Association for Surface Finishing, it’s estimated that 30 – 40% of surface finishing facilities have chromium electroplating processes. The beginning of its use in the industry goes back to the 1950s and most recently has been required by many states to reduce harmful hexavalent chrome air emissions. Because the chrome plating industry is so highly regulated and monitored, the required use of PFAS in the plating process is well known and therefore has been “on the radar” of state and federal enforcement agencies as potential sources for PFAS pollution.
For more information or assistance with PFAS in the chrome plating industry in California, contact for assistance.
This EREF Summit will bring together practicing engineers, academics, industry professionals, government personnel and policymakers to facilitate discussion and provide various perspectives on the management, issues, and policies related to PFAS.
Per- and polyfluoroalkyl substances (PFAS) are a group of compounds that are man-made and are commonly used in industrial processes and consumer products such as food packaging, fire-fighting foams, metal plating, outdoor gear, popcorn bags, food wrappers, facial moisturizers, mattresses, carpeting, and cookware. Despite the widespread use of PFAS in everyday products, there are still significant knowledge gaps associated with the management of these compounds.