EDF Health

Understanding PFAS: Why a broad, transparent PFAS Testing Strategy is needed

By Maria Doa, PhD, Senior Director, Chemicals Policy / Published: March 2, 2022

Maria Doa, Senior Director, Chemicals Policy; Lauren Ellis, Research Analyst; and Lariah Edwards, Post-Doctoral Fellow

EDF this week sent EPA a letter identifying opportunities for the agency to improve the effectiveness and transparency of its strategy for testing per- and polyfluoroalkyl substances (PFAS).

EPA unveiled its National PFAS Testing Strategy (Testing Strategy) last fall, laying out its plan to better understand the class of chemicals and inform its future regulatory efforts. PFAS are a large group of synthetic chemicals used to impart water, oil, grease, and stain resistance to various materials, and they are used in hundreds of everyday products, from water-proof clothing to grease-proof food packaging. By its own count, EPA says there are more than 12,000 individual PFAS.

In their letter to EPA, EDF analyst Lauren Ellis and post-doctoral fellow Lariah Edwards commended the agency for developing a strategy to address some of the significant data gaps that exist around PFAS and committing to use its authority under the Toxic Substances Control Act (TSCA) ‒ the country’s main chemical safety law ‒ to require manufacturers to provide toxicity data on the chemicals.

As the letter points out, however, in its current state, the Testing Strategy lacks sufficient detail and is too narrow to fulfill the agency’s intended purpose to understand and regulate PFAS in a way that is protective of both human health and the environment. Read More »

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Seven ways we can turn off the tap on PFAS pollution

By Lauren Ellis / Published: November 23, 2021

This blog is adapted from an Op-Ed originally published by Environmental Health News on Nov. 23 and is authored by Lauren Ellis, Research Analyst and Maricel Maffini, consultant.

Per- and polyfluoroalkyl substances (PFAS) are a group of highly persistent chemicals used in hundreds of products. Many PFAS are toxic and have been detected in the bloodstream of virtually all Americans. It’s an ongoing public health and environmental emergency that requires immediate and comprehensive action.

The good news is the White House recently outlined its plan to tackle PFAS pollution already in our water, air and food.

These are worthy efforts, and EDF commends the Biden-Harris Administration for taking these important steps. In addition to these initial actions aimed at addressing legacy pollution, it is also crucial to prevent additional PFAS from entering commerce and further polluting our environment.

In an Op-Ed published today by Environmental Health News, EDF Environmental Health Research Analyst Lauren Ellis and EDF consultant Maricel Maffini laid out seven steps the federal government should take to address PFAS in commerce and help turn off the tap on new PFAS pollution. The recommendations range from adopting a comprehensive definition for PFAS and taking a class-based approach to regulating the chemicals to phasing out all but essential uses of the substances. Read More »

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Beyond paper, part 2: PFAS intentionally used to make plastic food packaging

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: August 12, 2021

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

Since 2002, FDA has authorized the use of four types of per- and polyfluorinated alkyl substances (PFAS) to make plastic food packaging, one as recently as 2016. The PFAS are allowed in plastic at levels up to 2000 parts per million (ppm); although lower than those used to greaseproof paper, these levels still contaminate food. The PFAS are added to facilitate the production of articles such as bottles and wraps. They reportedly improve polymer extrusion, reduce build-up on the injection mold, and improve surface roughness among other technical effects.

EDF submitted a Freedom of Information Act (FOIA) request for seven food contact substance notices (FCNs) that FDA has authorized. From FDA’s response[1], we learned that these PFAS can contaminate food in contact with the packaging. In one case the overall amount of the PFAS in the diet would be as high as 41 ppb (see pages 31-32 of FOIA response) – much more than is tolerated for some PFAS in drinking water.

These plastic processing aids, along with fluorinated polyethylene, are the latest additions to a growing list of sources of ‘forever chemicals’ in the diet. They join environmental contamination and greaseproofed paper and cardboard as sources that food companies must consider in order to keep PFAS out of their products and respond to consumer demand for safer food. Given the evidence, FDA needs to move forward pursuant to our June 2021 citizens petition to evaluate the safety of PFAS taking into account the cumulative effect of these chemicals in the diet from many sources.

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

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: July 7, 2021

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

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: May 13, 2021

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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FDA takes an important step by phasing out paper greaseproofing agents containing a specific PFAS

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: August 4, 2020

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

Last week, the Food and Drug Administration (FDA) announced the phase-out of per- and polyfluorinated alkyl substances (PFAS) used to greaseproof paper and paperboard food packaging made from a specific type of short-chain PFAS known as 6:2 fluorotelomer alcohol (6:2 FTOH).  The action, narrow as it is, is welcome news for efforts to protect public health and the environment from the risks posed by short chain PFAS, known as “forever chemicals” because they do not degrade.

FDA secured voluntary agreements with three companies, Archroma, Asahi Glass, and Daikin, to phase-out products based on 6:2 FTOH. A fourth company, Chemours, asked FDA to suspend the agency’s approvals on its products containing the PFAS one year ago. The action affects 15 food contact substance notifications (FCN) approved by the agency between 2006 and 2016. It does not address 13 FCNs for similar greaseproofing uses made from PFAS other than 6:2 FTOH. And, under the agreement, consumers may still find 6:2 FTOH-laden, carry-out containers until June 2025.

The process FDA took, and the time it took to get there, reveals the significant difficulties the agency has in reversing past actions in the face of mounting evidence of a chemical’s risk:

  • FDA must seek out information because companies have no obligation to affirmatively notify the agency of new studies showing potential problems;
  • When FDA finds the information and identifies potential safety concerns, it appears to act as if it has the burden of proving the use is no longer safe; and
  • FDA continued approving uses of 6:2 FTOH even after it identified problematic data gaps.

These difficulties reinforce the need for actions being taken by states such as Washington, Maine, New York, and California, by Congress, and by retailers to reduce uses of PFAS in their products. When it comes to food packaging, PFAS are dinosaurs and their time is running out.

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