Mark Rossi1
Clean Production Action1
In the search to replace per- and polyfluoroalkyl substances (PFAS) in materials and products, how can concerned/relevant parties such as researchers, companies, non-governmental organizations (NGOs), and governments have greater certainty that the alternatives to PFAS are safer and not regrettable substitutes? Regrettable substitutes are alternatives that themselves become problematic; for example, replacing polystyrene foam clamshells with compostable fiber-based (e.g., bagasse) containers made with PFAS.<br/> <br/>The entire class of PFAS is now a focus for elimination or restriction in many jurisdictions including state governments and the European Union. This is because over the past few decades PFAS contamination has grown into a serious global health threat due to the ability of these chemicals to persist in the environment for hundreds of years; their presence in almost all human populations; and increasing evidence of their health impacts. PFAS use in all industry sectors is under scrutiny, including food packaging, furniture, apparel/fabrics, firefighting foam, oil and gas, carpets and rugs, and cosmetics.<br/> <br/>The journey to safer chemicals in materials and products includes the following stages: a) identify all intentionally added chemicals in the material/product as well as residual chemicals of high concern; b) assess the toxicity of those chemicals; c) avoid known chemicals of high concern; and d) select materials/products with safer chemicals. This journey to safer solutions, for example, to products free of per- and polyfluoroalkyl substances (PFAS) is fraught with many challenges.<br/> <br/>Significant challenges to identifying safer alternatives to PFAS and other chemicals of high concern include: 1) confidential business information -- very few materials/products have complete disclosure of all the chemicals intentionally added to the product as well as residual chemicals of high concern to human health or the environment; 2) toxicological capacity -- very few organizations possess the technical capacity to assess the toxicity of the chemicals in materials/products and to understand how to interpret that data; and 3) availability of materials/products that do not contain chemicals of high concern.<br/> <br/>Product certifications provide a unique framework for overcoming these challenges because they create incentives for manufacturers to disclose chemical constituents to a trusted third party with the goal of receiving a product certification that can be used to promote a product for being “PFAS-free” and using preferred chemicals. “PFAS-free” is in quotes because it must be defined, for example as encompassing, no intentionally added PFAS and no residuals above a specified threshold such as 100 parts per million (ppm) per homogeneous material. <br/> <br/>To identify PFAS-free and preferred products Clean Production Action developed a certification program called GreenScreen Certified. The methodological requirements for identifying preferred products include: a) chemical ingredient disclosure; b) all chemicals assessed for hazards; c) avoidance of known chemicals or classes (e.g., PFAS) of chemicals of high concern, including carcinogens, mutagens, reproductive or developmental toxicants, endocrine disruptors, persistent/bioaccumulative/toxic chemicals (PBTs), or other similarly toxic chemicals; d) meets analytical testing requirements – for example, for PFAS residuals in the products.<br/> <br/>Overall, PFAS-free and preferred products have been identified for significant uses of PFAS, including in firefighting foam, food service ware, furniture and fabrics, textile chemicals, and cleaners and degreasers used in manufacturing.