Seeking a path to PFAS collaboration

Baltimore — Plastics companies looking for 100 percent clarity around how to phase-down fluorinated PFAS compounds in their manufacturing processes will have to keep waiting.

That much was clear at a recent Society of Plastics Engineers technical conference, Per- and Polyfluoroalkyl Substances (PFAS) in the Plastics Industry, which took a deep dive into the calls to eliminate PFAS chemicals and what that could mean for the industry.

An overriding theme was how much remains uncertain, both technically and commercially, and as is common at conferences on complex topics, there were a lot of calls for collaboration to find new approaches.

But like beauty, collaboration was also something that was in the eye of the beholder.

For some, it meant working with others in industry to develop new chemicals to replace the fluoropolymer or fluorinated compounds that are used as process aids in manufacturing or as key components in products like medical devices, flame retardants and electric car batteries.

"We're not up here saying we have all the answers," said Andrew Ro, a process engineer with medical device maker Boston Scientific, in a presentation at the Oct. 18-19 conference in Baltimore. "We're actually looking for you guys and potential collaboration through SPE to find the answers."

For others, collaboration means influencing governments to make distinctions between the thousands of different PFAS-related chemicals in the market, when they start to write new public health standards.

Specifically, for the American Chemistry Council, it meant having regulators keep fluoropolymers separate from chemicals like PFOA or PFOS, which face strict new federal drinking limits.

"Our basic message is to keep fluoropolymers separate," said Jay West, executive director of ACC's Performance Fluoropolymer Partnership, arguing that fluoropolymers, within the broad class of fluorinated chemicals, are safe.

He told the conference at another point that he views working together as an industry on PFAS government affairs a top priority.

"I'd like collaborate with all of you so that you can feel comfortable being heard in your states and educating your local legislators about the importance of fluoropolymers to your products [and] your workers," he said. "I'd like to collaborate with you in the public policy space."

And for others, collaboration meant having industry share much more data with the Environmental Protection Agency and other agencies about PFAS substances, to help develop safer alternatives and fill in the large gaps in publicly available science.

"To move forward and look for safer alternatives, that requires a huge amount of collaboration," said Liz Harriman, deputy director of the Toxics Use Reductions Institute at the University of Massachusetts-Lowell, speaking on a panel discussion.

"I also think industry owes it to EPA and the states, but especially the EPA, to be transparent and give them all the information they have and all the information that EPA needs," she said. "They've been kept in the dark way too long."

West argued that public debate too often links all PFAS chemicals together, considering all of them to have the same toxicity profiles as substances like perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS) that are drawing the most concern.

"There are some interests that have positioned all PFAS as being the same. They communicate on PFAS like all PFAS are PFOA," he said. "This creates a great deal of confusion, but it is known that not all PFAS are the same.

"It causes confusion with the public, it causes confusion in terms of what's happening regulatory-wise and it causes tremendous confusion with investors who are looking at the regulatory climate and whether or not they're going to make big investments in semiconductor manufacturing and the hydrogen economy and those kinds of things," he said. "This non-specific, general conversation really gets in the way."

But Harriman argued that governments pass legislation that industry groups say is too broad because they lack information from industry about what PFAS chemicals are being used and can't evaluate the risks from what could be released into the environment.

"I'm sure you recognize the frustration that exists in these states," Harriman said to West, arguing that governments don't know what PFAS chemicals are being used, "where they are [and] why they are there."

To illustrate that frustration, she pointed to an industry study a few years ago that found about 250 PFAS substances in commercial products, including their ingredients and byproducts, but she said industry groups declined to make that list of chemicals public, citing confidentially restrictions they had to follow in gathering the information.

"We don't have access to industry or the information to answer those questions," she said, before asking West what type of legislation or regulation industry would prefer.

West said legislation should include narrower definitions of PFAS focused on the smaller molecules that seem to be drawing the most public concern, as well as greater recognition of critical uses like medical devices.

"We think this is a way to be much more surgical, either starting by how you define PFAS at the beginning or just giving a greater amount of certainty to certain uses and certain businesses, that they are not part of this," West said.

He said that for many applications, finding drop-in replacements could prove difficult for fluoropolymers.

"From talking to my members and especially the members who are processors and end users, they would have to reconfigure their entire manufacturing process … because there is not for the fluoropolymers they use, an easy drop-in substitute," West said.

EPA officials speaking at the conference said the agency is trying to take a surgical approach that categorizes PFAS chemicals differently, rather than treating them monolithically.

But they also noted growing research on PFAS-related health problems and evidence that PFAS compounds are in the bloodstream of the general population.

"We are definitely not … looking at this as a monolithic PFAS [situation]," said Jeff Dawson, a senior advisor in EPA's Office of Chemical Safety and Pollution Prevention. "That's why we're pursuing the categorization process and developing information to support that categorization process, so we can look at this in a surgical way and focus on the things that need to be dealt with first."

A second EPA official who spoke at the conference, Matt Klasen, suggested regulators are catching up with new health science, after decades of PFAS chemicals being widely used in products including fire-fighting foams and barrier coatings on packaging, clothing and carpets, with little information available to governments.

"We did not know about this class of chemicals, we did not know about particularly hazardous chemicals within this chemical family, for a very long time," said Klasen, who manages the EPA Council on PFAS. "But we're working very hard in our roadmap, both to give us the tools to better understand that challenge and where that's appropriate, to use some of the policy and regulatory approaches to take appropriate action."

For plastics, part of that includes an EPA plan announced in 2021 to develop new regulations to limit PFAS discharges from plastics, synthetic fabric and organic chemicals factories and trying to gather data on whether such rules would be needed for the plastics molding sector.