Per- and Poly-fluoroalkyl substances (PFAS) are a class of synthetic chemicals widely used in consumer products, industrial processes, and firefighting foams. The chemicals have drawn national attention as communities across the country grapple with how to manage contamination of drinking water by PFAS, often from industrial or firefighting uses.
Due to the chemicals’ ability to make water- and grease- resistant coatings, they are also used in food packaging to treat paper and paperboard that contacts food. EDF focuses on PFAS in food, whether due to environmental contamination or ongoing use in packaging.
Why PFAS are a concern
PFAS are extremely persistent in the environment and the few chemicals in the class that have been studied have been associated with a host of serious health effects, from developmental problems to cancer.
EDF has reviewed documents related to the Food and Drug Administration’s (FDA) approval of PFAS for food uses (received in response to a Freedom of Information Act Request). Our review has brought some startling information to light, including that paper mills using FDA-approved PFAS for grease-proofing paper are a potentially significant source of contamination in drinking water.
In June 2019, FDA announced steps the agency is taking on PFAS, including sampling food and reviewing approved uses. With this announcement, the agency released initial test results for PFAS in certain foods and a statement essentially declaring the chemicals are not a concern in food. The agency has since released a revision of its June testing results and a new validated method for analyzing the chemicals in food.
EDF is encouraged to see FDA's ongoing work on the chemicals, but we have raised significant concerns with the agency’s broad conclusion of PFAS safety given the evidence of health risks at low levels of exposure and the criteria used for the agency's testing method.
Due to our findings about FDA-approved PFAS, including evidence of contamination in the food supply and growing concerns about the class of chemicals, EDF recommends that FDA take the following steps while the agency reviews authorized PFAS in food:
- Notify PFAS manufacturers that FDA has determined that all active PFAS Food Contact Notifications (FCNs) are no longer effective and give companies the opportunity to provide additional information demonstrating the use is safe.
- Ensure companies provide all relevant data as required by law. Without relevant data the agency cannot make informed decisions regarding the health risks of PFAS.
- Test foods for mixtures of PFAS in the effective FCNs. So far, FDA has not tested for the large number of PFAS authorized for use in food packaging.
- Require companies to provide comprehensive estimates of environmental releases of their products given the extent of environmental contamination by PFAS and FDA’s obligations under the National Environmental Policy Act.
- Demand that companies provide samples of the products for each FCN to better match PFAS found in products with their authorized uses in food packaging.