EDF Health

Beyond paper: PFAS linked to common plastic packaging used for food, cosmetics, and much more

Tom Neltner, Chemicals Policy Director, Maricel Maffini, consultant, and Tom Bruton with Green Science Policy Institute. 

Update August 11, 21 – Added FDA’s Response to FOIA.

Results from an Environmental Protection Agency (EPA) investigation into PFAS-contaminated pesticides have much broader, concerning implications for food, cosmetics, shampoos, household cleaning products, and other consumer products, as well as recycling. This investigation, first announced earlier this year, found that fluorinated high-density polyethylene (HDPE) containers used for pesticide storage contained a mix of short and long-chain per- and polyfluorinated alkyl substances (PFAS), including PFOA, that leached into the product. From what EPA can tell, the PFAS were not intentionally added to the HDPE containers but are hypothesized to have been produced when fluorine gas was applied to the plastic.

Since EPA released its investigation, we have learned the disturbing fact that the fluorination of plastic is commonly used to treat hundreds of millions of polyethylene and polypropylene containers each year ranging from packaged food and consumer products that individuals buy to larger containers used by retailers such as restaurants to even larger drums used by manufacturers to store and transport fluids.

The process of polyethylene fluorination was approved by the Food and Drug Administration (FDA) in 1983 for food packaging to reduce oxygen and moisture migration through the plastic that would cause foods to spoil. The fluorination process forms a barrier on the plastic’s surface and it also strengthens the packaging.

Fluorination of plastic leading to the inadvertent creation of PFAS may be another reason these ‘forever chemicals’ show up in many unexpected places. This significant source of PFAS contamination needs to be addressed. Much remains to be resolved as FDA and EPA actively investigate this new source of PFAS; however, preventive steps need to be taken quickly, especially since other PFAS-free barrier materials are available as alternatives.

Growing evidence links PFAS to a wide range of serious health effects – from developmental problems to cancer.

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Heart disease and adult lead exposure – the evidence grows more compelling

Tom Neltner, J.D.is Chemicals Policy Director

Two recent articles add to the already strong evidence that adult exposure to relatively low levels of lead is associated with heart disease, the leading cause of death in the United States, after COVID-19. These studies reinforce the urgent need to reduce not only children’s exposure to lead but also adult exposure through regulatory action.

A February 2021 Environmental Health Perspectives article found that blood lead levels were positively associated with prevalence of moderate to severe coronary artery stenosis (CAS), the narrowing of at least 25% of these vital arteries to the heart. The researchers studied a cohort of 2,000 Korean adults studied with no history of CAS, cardiovascular disease (CVD), or occupational exposure to lead. The vast majority of their blood lead levels were below the U.S. Center of Disease Control’s (CDC) reference level.[1] The researchers found that he severity of CAS is an important predictor for life threatening cardiovascular disease, even after adjusting for factors such as age, sex, hypertension, body mass index, regular exercise, smoking, and alcohol drinking.[2]

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FDA’s short-sighted approach to building trust in the safety of cell-cultured meat and seafood products

Tom Neltner, J.D.is Chemicals Policy Director

Consumer trust that products are safe to eat is essential to acceptance of any innovative food product.

One of the most innovative food products expected to enter U.S. markets in coming years is cell-cultured meat and seafood. Producing these products by culturing cells in tanks and forming them into foods that look and taste like their conventionally produced counterparts is a technological achievement. Proponents enthusiastically tout these products as climate-friendly alternatives that provide real hope to meet the world’s growing demand for animal protein in a sustainable way that also minimizes animal welfare concerns.

Consumer trust that products are safe to eat is essential to acceptance of any innovative food product. That trust is built through a rigorous, transparent, and independent scientific review to ensure safety. Without that, questions linger that undermine widespread consumer adoption.

Unfortunately, we have serious concerns that the process the Food and Drug Administration (FDA) may be planning to use to review the safety of cell-cultured meat and seafood is inadequate and will undermine consumer trust. From our perspective, the manufacturing process for cell-cultured meat and seafood is a significant departure from current practice and warrants careful scrutiny. FDA guidance is clear that, for these types of changes, the appropriate review options are a food additive petitions or the voluntary Generally Recognized as Safe (GRAS) notification process. We strongly recommend FDA rely on these existing options existing options rather than create a new approach.

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A consequential day in the effort to prevent lead poisoning

Tom Neltner, J.D.is Chemicals Policy Director

Lead poisoning prevention advocates should mark May 14, 2021 as a consequential day in our collective efforts to protect public health. Last week, two decisions and a preliminary report were issued that lay a solid foundation for further progress. When translated into action, the decisions and report should result in significantly reduced lead exposure for children. These developments were:

  • A court ruling on lead-based paint hazard standards: The U.S. Court of Appeals for the Ninth Circuit directed the Environmental Protection Agency (EPA) to reconsider – and most likely tighten – the agency’s 2019 revisions to its lead-based paint (LBP) hazard standard that define the levels of lead in paint, dust, and soil that are dangerous. The current standards remain in place until EPA revises them to comply with the law and the court’s order. This decision has significant implications for home renovations, real estate disclosures, lead cleanups, and homeowner testing. This welcome step toward stronger protections for children was only possible thanks to Earthjustice and the petitioners that challenged EPA’s flawed rule.
  • Lowered federal elevated blood lead level: The Centers for Disease Control and Prevention’s (CDC) Lead Exposure and Prevention Advisory Committee (LEPAC) unanimously recommended that the agency lower its blood lead reference level (aka “elevated blood lead level” or EBLL) from 5 micrograms per deciliter (µg/dL) of lead in young children’s blood to 3.5 µg/dL. CDC appears ready to act on the recommendation. When it does, the decision will have significant implications for state and local health and housing agencies reacting to blood lead testing results for at-risk children and for action levels for lead in food.
  • New national survey of lead-based paint hazards: The U.S. Department of Housing and Urban Development (HUD) presented to LEPAC the preliminary results of its American Healthy Homes Survey II (AHHS-II), a long-overdue update to its 2006 survey. This survey of lead-based paint hazards serves as the basis for federal agencies to set priorities, assess impacts of policy decisions, and track progress. The results of samples taken in 2018-19 shows modest but significant progress across many demographics including African American households, government-supported households, and households in poverty – most likely an indication that the federal investment to fix low-income housing is paying off.

These actions put added urgency to President Biden’s America Jobs Plan that includes $45 billion in federal funding to fully replace the nation’s 9 million lead service lines and $213 billion for housing – both critical aspects of our nation’s infrastructure that need a lead poisoning prevention-oriented upgrade. We encourage Congress to provide at least $19 billion as part of an investment in housing to reduce lead-based paint hazards in pre-1940 housing, especially by replacing old, single-pane windows to get the combined benefits of safer and more energy efficient homes.

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The Chemical Industry Hid Evidence of Harm from PFAS: 3 Takeaways

Tom Neltner, J.D., Chemicals Policy Director and Maricel Maffini, Ph.D., Consultant

Yesterday, The Guardian published a powerful story by reporter Tom Perkins detailing how chemical manufacturers hid evidence of dangerous health impacts from certain types of PFAS and the Food and Drug Administration (FDA) did not take sufficient and swift action to protect the public.

The story is largely based on data revealed in the FDA’s response to a Freedom of Information Act request by EDF and Environmental Working Group. The analysis showed that two major PFAS manufacturers, Daikin and DuPont, withheld safety information from the agency both by 1) not submitting it when the agency was considering whether the chemical should be on the market, and 2) not alerting the FDA when later analysis revealed a problem.

The companies’ failures are disturbing. What FDA did (or, more precisely, failed to do) after finding out is also disconcerting. While the agency’s scientists have taken strides to more fully understand the harm posed by PFAS, management has failed to adequately translate the science into timely action to protect people from toxic chemicals like these in their food.

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California water utilities fear the unknown when it comes to lead service lines

Tom Neltner, Chemicals Policy Director.

Last month, two California trade associations submitted disconcerting comments to the Environmental Protection Agency (EPA) as the agency considers what to do with the revised Lead and Copper Rule (LCR) published in the waning days of the Trump Administration. The associations – the Association of California Water Agencies (ACWA) and the California Municipal Utilities Association (CMUA) – represent 90% of the state’s drinking water utilities.

The trade associations are asking EPA to allow water utilities to tell the agency, the state, their customers, and the public that they have no lead service lines (LSLs) even when they know it may well be false. This would seriously undermine one of the most important positive aspects of the revised LCR – the service line inventory. California’s unusual definition of a “user service line” has been a long-running problem: it does not include the portion of the service line on private property. This definition is narrower than the federal one – and even the state’s definition of an LSL that has been in place for more than a quarter century.

Under EPA’s revised LCR, utilities can only claim that they have no LSLs – and thus avoid the need to comply with the rule’s more protective sampling and corrosion control requirements for systems with LSLs – if they are confident there are no LSLs based the entire length of the service line, including the portion on private property. The two state trade associations are asking EPA to put the burden of determining the composition of this portion of the service line entirely on the customer, allowing a utility to ignore a lead pipe if the customer does not provide the information. This approach will render the inventory effectively useless and misleading.

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