Testing recommendations for PFAS
EDF's testing recommendations for PFAS
Companies should test selected food ingredients for per- and poly-fluorinated alkyl substances (PFAS) contamination and screen paper, paperboard and similar fiber-based products (e.g. bamboo and corn-derived polymers) for intentionally added PFAS. Specifically, companies should:
- Periodically test food ingredients that are potentially contaminated with PFAS using FDA’s approved method, and investigate possible sources whenever measurable PFAS is found.
- Systematically screen fiber products intended to contact food using a total fluorine method, and investigate levels over 100 parts per million (ppm) that indicate likely intentional use.
Why test for PFAS?
The extent of PFAS food contamination is poorly understood but potentially significant, especially when food is produced around facilities where PFAS is or has been manufactured, processed or used. In addition, there are significant concerns that PFAS-treated paper, paperboard and similar fiber-based food contact articles such as bowls and wrappers can contaminate not only food, but paper recycling and composting operations as well.
Given PFAS’ potential health consequences and recent attention in the media, food manufacturers and retailers need to know that their products are not contaminated. Testing is the best method to instill confidence. While food manufacturers and retailers may specify that PFAS-treated food contact articles not be used, low-cost screening tools can help verify compliance.
The problem with PFAS: A deep-dive
Why are PFAS important?
Virtually all Americans have PFAS in their body due to the chemicals’ extensive use in consumer products, persistence in the environment, and the tendency of some forms to bioaccumulate in the human body. The two most thoroughly studied forms, PFOA and PFOS, are associated with an array of serious health risks at very low levels of exposure; emerging evidence indicates that other forms are also problematic.
Given the mounting evidence, EDF recommends that food manufacturers avoid the intentional use of PFAS in food packaging such as paper, paperboard and similar fiber-based products. Click here for more information about the health implications of PFAS.
Are PFAS really in food?
Yes. PFAS have received a great deal of national attention, mostly due to contamination of drinking water affecting millions of Americans. Environmental contamination results from firefighting foam; releases from chemical manufacturing; industrial uses in paper and textile mills and metal plating operations; and contaminated biosolids from wastewater treatment used as fertilizer in farming. Food may also be contaminated from the intentional use of PFAS in paper, paperboard and similar fiber-based food packaging such as popcorn bags, sandwich wrappers, bowls and plates.
In 2019, FDA released testing results that found PFAS contamination in produce at farmer’s markets in North Carolina near a manufacturing facility and in dairy products in New Mexico from a firefighting foam used at a nearby military base. Contamination has also been found in food in other states.
Are PFAS still intentionally used in food contact materials?
Yes. In 2016, FDA removed approval for long-chain PFAS. However, the agency continues to allow the use of other forms of PFAS, primarily to greaseproof paper and paperboard, although it has begun a reassessment of forms of PFAS known as short-chain. Companies may have also self-certified additional PFAS and uses independent of FDA oversight. The additional uses include fiber-based packaging such as bamboo and corn-derived polymers that sometimes replace traditional cellulose-based paper and paperboard applications.
Worth noting, the Biodegradable Products Institute now prohibits intentionally added fluorinated chemicals to fiber materials in its compostability certification program; BPI uses 100 parts part million (ppm) of total fluorine as an indicator of an intentional use.
Beginning in 2018, public interest and media groups, such as Mind the Store, Center for Environmental Health, and New Food Economy, have been testing paper and cardboard products that contact foods for total fluorine to identify intentional uses. Some states such as Washington and Maine are considering whether to ban the intentional use of PFAS in food contact materials.