The Debate over PFAS—A Global Manufacturing Concern

PFA Safety, Use, and Regulations—A Major Global Manufacturing Concern

Perfluoroalkyl and polyfluoroalkyl substances—more commonly referred to as PFAs—are known as “forever chemicals” because they break down very slowly over time. PFAS are so persistent and so widely used that they are routinely detected in water, air, fish, soil, food and consumer products around the world.

However, many of these chemicals are toxic. This article covers what PFAS are, what the major PFA safety concerns and known health risks are of these substances, the challenges of eliminating them from the environment, and what is currently being done to mitigate PFA usage in the global manufacturing industry.

What is a PFA?

Perfluoroalkyl and polyfluoroalkyl substances (PFAS) are a large group of manmade chemicals that have been used since the 1950s to help manufacture a wide variety of common everyday consumer goods used throughout the world and across a broad range of industries, including aerospace, automotive, construction, electronics.

From a manufacturing standpoint, PFAS are desirable because they are generally effective at resisting things like heat, water, oil, and grease and therefore can help products resist stains, corrosion, avoid weather damage, improve fuel efficiency, and more.

You can find PFAS in hundreds of products and goods, including:

• Food packaging
• Non-stick cookware
• Water- and stain-resistant clothing
• Carpets, furniture, and upholstery
• Household cleaning products
• Cosmetic products, including makeup and dental floss

At their molecular level, PFAS contain a chain of linked carbon and fluorine atoms, in addition to other elements. Since carbon-fluorine bonds are considered one of the strongest known bonds, these chemicals are incredibly resistant to degradation.

For this reason, PFAS readily accumulate in the environment and can easily find their way into soil, water, air, animals, and humans. According to the National Institute of Environmental Health Sciences, more than 9,000 PFAS have been identified. Some of the more common ones include:

• Perfluorooctane sulfonic acid (PFOS)
• Perfluorooctanoic acid (PFOA)
• Perfluorononanoic acid (PFNA)
• Perfluorodecanoic acid (PFDA)
• Perfluorooctane sulfonamide (PFOSA or FOSA)
• Perfluorohexane sulfonic acid (PFHxS)

The CDC has created a "family tree" of PFAs to help people understand the structure and relationship between these different chemicals.

What Are the Health Risks Associated with PFAS?

Many of the PFAs in use today are known or suspected to be toxic to humans and animals. Because of the sheer volume of different PFAS currently used and found in the environment, however—and because of their ability to accumulate in the environment over time—it's difficult to accurately study these chemicals and determine just how many of them pose a health risk to humans, or how serious those health risks may be in the long-term.

What is clear is that human exposure to PFAS is incredibly common. Some of the most common methods of human PFA exposure include:

• Eating foods, including fish, that contain high levels of PFAS
• Using consumer products that contain and/or were made with PFAS
• Ingesting dust, soil and other substances contaminated with PFAS
• Drinking PFA-contaminated water (including private well water or municipal water)
• Living somewhere near places where PFAS are used and/or made

It should come as no surprise that PFAS are readily found in the blood and urine of both animals and humans. One report shared by the Centers for Disease Control and Prevention's National Health and Nutrition Examination Survey (NHA0NES) showed that PFAS are detectable in 97% of Americans.

Interestingly, NHANES data also reveals that blood levels of two types of PFA chemicals—perfluorooctane sulfonic acid (PFOS) and perfluorooctanoic acid (PFOA)—have declined significantly over the past two decades, with PFOS blood levels down by more than 85% and PFOA levels down by more than 70% from 1999 to 2018.

This decline in PFOS and PFOA blood levels can be attributed to prior PFA regulations spearheaded by the Environmental Protection Agency, which required the phasing out of these two chemicals from commercial use. "However," the CDC notes, "as PFOS and PFOA are phased out and replaced, people may be exposed to other PFAS."

To date, research in this field suggests that—at least speaking broadly—exposure to PFAS has been associated with a wide range of possible adverse health problems, including:

• Liver problems
• Kidney disease
• Impaired fertility and reduced fetal growth and development
• Increased risk of obesity
• Altered metabolism, including lipid and insulin dysregulation
• Impaired immune and thyroid function
• Decreased ability to fight infections
• Increased risk of certain cancers
• Decreased vaccine effectiveness

Current and Future PFA Regulations: What Manufacturers Need to Know

Given what we know and continue to learn about the health and environmental risks of PFAs, it's important to understand what is being done—and what is being proposed—to limit the use of PFAS in the global manufacturing industry.

Among community stakeholders in the United States who are trying to curb PFA use, California legislators are certainly leading the charge. Proposed bill AB-1817, "Product Safety: textile articles: PFAS" would prohibit manufacturing, distributing, selling, or offering for sale any new textile articles (such as clothing) which contain regulated PFAS. The bill also requires a manufacturer to use the "least toxic alternative" when removing regulated PFAS to comply with these provisions. Should this bill pass, the new legislation would go into effect on January 1, 2025.

An existing and landmark California law prohibits—as of January 1, 2023 of this year—the distribution, sale or offer of any food packaging or "juvenile products" (such as infant car seats and child mattresses) containing regulated PFAS in the state.

Other states are following suit. In April 2022, Vermont passed Senate Bill 113, which provides medical monitoring provisions for individuals exposed to PFAS. This is one of the first bills in the nation that ensures the right to medical monitoring after toxic exposure via statute, unlike other states—including Arizona, California, the District of Columbia, Florida, Massachusetts, Missouri, New Jersey, Ohio, Pennsylvania, Utah and West Virginia—where the right to medical monitoring is a right recognized by the courts.

And in 2021, Maine passed a law that requires manufacturers to report products that contain PFAS to the state's environmental agency. In addition, more than 20 U.S. states have proposed or enacted legislation that would regulate the amount of PFAS found in drinking water.

PFA regulations are a hot button topic on an international stage, as well. Policymakers in countries like Norway, Sweden, Denmark, Germany, and the Netherlands are in the process of passing legislation that would restrict or ban certain PFA substances.

What Are the Challenges to Eliminating PFA Use?

While both the public and scientific communities increasingly agree that the potential health risks of PFAS warrant much more careful consideration of these compounds' widespread use, eliminating PFA use completely poses a challenge to manufacturers and lawmakers alike. Consider the following:

• Currently, no federal laws exist in the United States which require manufacturing companies to eliminate PFAS from consumer products, nor warn consumers via labeling or otherwise that an item was made with or contains PFAS.
• In addition, and with literally thousands of variations of PFAS available to manufacturers, testing for, and verifying the presence of, these different PFAS in products would likely be prohibitively costly and time intensive.
• Finally, consumer demand for high-performing products would require the development and safe implementation of acceptable, cost-effective alternatives to PFAS. Not only would this have a widespread impact across a broad range of supply chains and industries, but it could also pose the potential issue of exposing the public to other chemicals that may have their own unique adverse health effects.
• The world saw this phenomenon with bisphenol-S (BPS), an "alternative" chemical used to replace the probable human carcinogen bisphenol-A (BPA) in plastic products that was only later found to increase the risk of cardiovascular disease, among other possible problems.

Conclusion

Major regulatory leaders in California and elsewhere have already begun crafting and enacting regulations to limit and control PFAS. For manufacturing companies, failing to adopt and comply with these regulations could lead to decreased business and lost profits—costs that could eventually outweigh the expense of investing in PFA alternatives.

In addition, research into the adverse health effects associated with human PFA exposure continues to advance. It's fair to say that as consumers become more educated about the potential dangers of PFAS, they will start looking for "PFA-free" products as they make their purchasing decisions. For these and other reasons, it would be prudent for manufacturers to begin exploring alternative methods of production that do not involve PFAS.