PFAS: The Consequences of Chasing Zero

Food companies are often asking what they should be watching out for and what is on the horizon that is going to impact business from a food safety perspective. Currently heavy metals are clearly in the spotlight and so are what are known as “Forever” chemicals such as PFAS. For years, PFAS have been under siege for both actual and alleged usage and effects on public health and the environment. What is the real story? How is the food industry being impacted?

Let’s start with a few facts and regulatory actions:

1. Per- and polyfluoroalkyl substances (PFAS) are a group of over 9,000 synthetic chemicals that have been used in industry and consumer products, worldwide, for over 70 years. (CDC)
2. Some PFAS, particularly the longer-chained carbon species such as perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS) are environmentally persistent, bioaccumulative, and have long half-lives in humans.
3. PFAS have been manufactured and used broadly in commerce since the 1940s, but concern over potential adverse effects on human health grew in the early 2000s with the discovery of PFOA and PFOS in human blood. Most uses of PFOA and PFOS were phased out by U.S. manufacturers in the mid-2000s, but there are a limited number of ongoing uses. (Federal Register)
4. The FDA phased out the use of the long-chain PFAS including PFOA and PFOS in November 2016 resulting in the prohibition of their use in U.S. food-contact applications. Additionally, seven states have adopted legislation banning the use of PFAS in food packaging. (JD Supra)
5. The FDA and USDA have been monitoring for PFAS in a variety of foods that are under their jurisdiction. While they have found varying levels of PFAS in a small subset of foods, the vast majority of foods contain PFAS levels below the Method Detection Limit (MDL) (Analytical Results for PFAS in 2019 Total Diet Study Sampling (Parts Per Trillion)—Dataset 1 (fda.gov))
6. In June, EPA issued interim updated drinking water health advisories for PFOA and PFOS that replace those that it had issued in 2016 which were both set at 70 ppt. The interim updated health advisories are 0.004 parts per trillion (ppt) for PFOA and 0.02 ppt for PFOS. (Federal Register)

While it is understandable that there is concern around the use of these particular PFAS, EPA’s near-zero advisory may be taking precautions to the extreme and diluting the message. To explain, let’s consider the aspect of “the dose makes the poison.” Take, for example, the fact that 0.004 ppt is equivalent to 1 second/32,000 years – a fraction so astronomically low as to essentially be a nonissue. Additionally, what has changed so dramatically since 2016 to rationalize EPA’s assessment of “safe” levels in water declining from 70 ppt to 0.004 ppt – a 17,500-fold reduction? What has changed to support the reduction of the two PFAS to levels below that which barely be detected, let alone achieved? Why are we chasing zero? 

One of the greatest concerns around the use and banning of PFAS is the public misperception that all PFAS are the same – that all are bad. They cannot all be grouped as one, because not all PFAS are toxicologically equivalent.

The areas of the food industry that are most impacted by both public perception and part-per-trillion advisories are packaging and water usage for production purposes (well and municipal, depending on the area and ground water concentration of a variety of PFAS). PFAS is a very effective grease-proofing agent that is effectively used to contain and extend the shelf-life of products such as microwavable popcorn and pet foods that are often enrobed in animal fat and/or grease. As previously mentioned, other areas of impact, particularly focused on the new EPA ruling, are facilities that use well water that may need to consider processes such as reverse osmosis to try to mitigate down to the near-zero levels. Another issue is that many of the food-contact studies are epidemiological and don’t consider other competing/compounding factors, such as the impacts of the food matrix. Even if the levels are toxic in water, a food compound may make it inert in the context of a food matrix. Therefore, many studies need to consider the bioavailability of PFAS within the context of a food matrix.

While TAG isn’t trying to say that there should be no regulations limiting the use of PFAS in packaging and other food-contact applications, education around the true risks and reality need to play a part in such considerations. Additionally, if industry doesn’t want to see PFAS, as a whole, going the way of BPA and GMOs, it’s time to add industry’s voice to the mix to educate consumers on the realities and keep regulators from chasing zero.