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Have you ever wondered why PFAS is all over the news in recent months?
Per- and polyfluoroalkyl substances (PFAS) were first detected in wildlife1 and oceanic waters2 in the early 2000s. Recently, however, these chemicals have been found in school uniforms,3 cosmetics4 and food contact materials,5 shifting what was initially considered an environmental issue to a public health crisis. As concerns have grown about the toxicological impact of long-term PFAS exposure on human health, questions about food-borne exposure have surged, especially since these chemicals are used in disposable food packaging materials, non-stick cookware and even in food processing machinery.
What’s the issue?
Due to their ability to confer oil-, stain- and water-repellency to food-contact paper and paperboard, PFAS have been widely reported in food-contact materials in Canada, the U.S. and Europe.5-7 In a European survey of disposable food packaging and tableware, every participating country exhibited samples with PFAS, with some at total organic fluorine (TOF) levels up to 60x higher than the indicator threshold for intentional PFAS addition set by the Danish Veterinary and Food administration.7 Even more concerning, only a small fraction of the TOF measured could be attributed to known PFAS from targeted analysis, which leaves a significant proportion shrouded in a black box of yet-to-be-identified and less frequently monitored PFAS, such as fluorotelomer mercaptoalkyl phosphates (FTMAPs).8
Another issue, which may be surprising, is compostable materials. While many countries have adopted the use of compostable materials due to the phase out of plastic in the food packaging industry, some of these products—such as those made of molded fiber—have been shown to contain high concentrations of PFAS (up to 1,200 mg/kw dry weight), which are ironically not degradable themselves despite the biodegradability of the source materials.7 These levels are problematic considering the increase in restaurant deliveries and takeout during the pandemic, and they represent a source of repeated exposure for consumers and environmental pollution.
Here’s the good news
The news isn’t all bad, though, especially in Europe, where regulation has motivated some companies to shift from PFAS to nonfluorinated alternatives. In Denmark, where PFAS application in food-contact materials has been banned since 2020,9 none of the french-fry bags from a popular fast-food chain demonstrated any intentional PFAS treatment, which was in stark contrast to samples from the same restaurant chain in the Czech Republic, Germany and the U.K.7 Other good news includes the lower frequency of detection of globally restricted or banned long-chain PFAS (≥8 carbons)—such as perfluorooctane sulfonic acid (PFOS) and perfluorooctanoic acid (PFOA)—in recent food packaging surveys, although short-chain PFAS (≤7 carbons) are still consistently observed.
Previously, global manufacturers shifted their fluorochemical production toward short-chain PFAS alternatives, but some of these compounds—such as perfluorobutane sulfonic acid (PFBS), perfluorohexanoic acid (PFHxA) and hexafluoropropylene oxide dimer acid (HFPO-DA)—have recently come under regulatory scrutiny. Specifically, regulatory pressure is being actively proposed as a tool to offset the cost differential between short-chain PFAS and the more expensive nonfluorinated alternatives in the hope of raising the latter’s market share in the food packaging industry.10
Fortunately, similar regulatory actions are starting to take effect in North America. As of today, 11 U.S. states have adopted legislative bans on the use of PFAS in food packaging, some of which will become effective in early 2023 with more to follow in 2024.11 However, closer examination of these regulations raises several questions:
- What is considered “intentionally added”?
- What kind of materials are within the scope of the food packaging ban (for example, paper, paperboard and plastics)?
- Are other food applications, such as processing aids, considered in the ban?
- Is a threshold of 100 ppm TOF enforceable considering that California is the only state to establish a limit for intentionally added PFAS?
These questions will hopefully be answered soon by the Keep Food Containers Safe from PFAS Act, first proposed in the U.S. Congress in 2021, which aims to harmonize the prohibition of PFAS in food-contact materials at the federal level. Another positive sign is the increased emphasis on supply chain transparency, where several states, including Washington and Maine, are now mandating that companies disclose PFAS as an ingredient in their food packaging products and that they transition to safer alternatives within two years of that first report. Again, the devil is in the details, as these alternatives must be deemed readily available, must have a comparable cost and must exhibit similar performance as PFAS in the packaging they would replace to minimize market disruptions.12
Decades of scientific research have led to the current state of evidence-based policymaking around the world to address PFAS, and the momentum continues. Non-fluorinated alternatives—such as bamboo, clay, biopolymers, bio-waxes and silicone—are being actively investigated with respect to their relative performance and cost as compared to PFAS-based materials.10
Repeated observations of PFAS in food-contact materials require additional research, such as migration studies, to provide context for their levels with respect to assessing risk to human health. These studies play an important role in the PFAS story and, in a stunning turn of events to close off the chapter, 3M just announced it will discontinue all production and usage of PFAS by the end of 2025, citing “accelerating regulatory trends” as a driving factor.13 This monumental decision is an incredible feat for scientific research and highlights its contribution to driving positive changes in both the regulatory and industry landscape.
- Giesy, J. and Kannan, K. Global Distribution of Perfluorooctane Sulfonate in Wildlife. Sci. Technol. 2001, 35, 1339-1342. https://pubs.acs.org/doi/10.1021/es001834k
- Yamashita, N. et al. A global survey of perfluorinated acids in oceans. Pollut. Bull. 2005, 51, 658-668. https://www.sciencedirect.com/science/article/abs/pii/S0025326X05001712?via%3Dihub
- Xia, C. et al. Per- and Polyfluoroalkyl Substances in North American School Uniforms. Sci. Technol. 2022, 56, 13845-13857. https://pubs.acs.org/doi/10.1021/acs.est.2c02111
- Harris, K.J. et al. Targeted and Suspect Screening of Per- and Polyfluoroalkyl Substances in Cosmetics and Personal Care Products. Sci. Technol. 2022, 56, 14594-14604. https://pubs.acs.org/doi/10.1021/acs.est.2c02660
- Minet, L. et al. Use and release of per- and polyfluoroalkyl substances (PFASs) in consumer food packaging in U.S. and Canada. Sci.: Processes Impacts. 2022, 24, 2032-2042. https://pubs.rsc.org/en/content/articlelanding/2022/em/d2em00166g
- Schaider, L.A. et al. Fluorinated Compounds in U.S. Fast Food Packaging. Sci. Technol. Lett. 2017, 4, 105-111. https://pubs.acs.org/doi/10.1021/acs.estlett.6b00435
- Straková, J. et al. Throwaway Packaging, Forever Chemicals: European wide survey of PFAS in disposable food packaging and tableware. 54 p. https://www.env-health.org/wp-content/uploads/2021/05/FINAL_pfas_fcm_study_web.pdf
- Bugsel, B. et al. LC-HRMS screening of per- and polyfluorinated alkyl substances (PFAS) in impregnated paper samples and contaminated soils. Bioanal. Chem. 2021, 414, 1217-1225.
- Danish Veterinary and Food Administration. (2020) Ban on fluorinated substances in paper and board food contact materials (FCM) fact sheet. https://www.foedevarestyrelsen.dk/english/SiteCollectionDocuments/Kemi%20og%20foedevarekvalitet/UK-Fact-sheet-fluorinated-substances.pdf
- OECD (2020). PFASs and Alternatives in Food Packaging (Paper and Paperboard) Report on the Commercial Availability and Current Uses. OECD Series on Risk Management, No. 58, Environment, Health and Safety, Environment Directorate, OECD. https://www.oecd.org/chemicalsafety/portal-perfluorinated-chemicals/PFASs-and-alternatives-in-food-packaging-paper-and-paperboard.pdf
- Federal and State Actions to Restrict PFAS: Impact on Food Companies [Webinar]. [Online]. Institute for the Advancement of Food and Nutrition Sciences, November 14, 2022.
- Maine Department of Environmental Protection. “Maine Toxics in Food Packaging Program.” Maine Department of Environmental Protection. December 19, 2022. https://www.maine.gov/dep/safechem/packaging/index.html#PFAS-packaging
- “3M to Exit PFAS Manufacturing by the End of 2025”. Cision PR Newswire. December 20, 2022. https://www.prnewswire.com/news-releases/3m-to-exit-pfas-manufacturing-by-the-end-of-2025-301707085.html