Forever Chemicals: Is PFAS lurking in your products? What can you do?
Perflourinated compounds (PFCs - including PFAS) are often toxic to people & ecosystems, do not degrade in the environment, can accumulate in our food chain, and are used in products and manufacturing processes across the global economy.
They’re bad, and they’re everywhere.
These chemicals highlight the continuing need for effective management strategies across many categories of consumer products.
What are Forever Chemicals?
The term “forever chemicals” refers to a huge class of man-made compounds that have been created to contain varying numbers of fluorine molecules arranged in either long or short chains of carbon atoms.
Depending on the way the fluorine molecules are arranged in the compound they are either “per” or “poly” flourinated compounds (PFCs).
Two of the more common groups in this giant (and growing) class of PFCs are perfluoroalkyl substances (PFAS), perfluorooctanoic acids (PFOA), and Perfluorooctane Sulfate (PFOS).
Since the 1940s, over 12,000 of them have been used in consumer products because of their helpful ability to make products water-repellent, stain-resistant, non-stick, and more. These same properties are also useful in manufacturing and storage.
Why is PFAS a concern for businesses and consumers?
PFAS and their many cousin chemicals continue to be found in surprising places across our economy, in our ecosystems, even in the blood of babies before they are born. Equally concerning, there is a large body of science showing health and environmental impacts.
They are scientifically linked to health impacts in people & animals
Many of the individual chemicals in this class of compounds are scientifically linked to human and environmental health impacts.
According to recent scientific studies, increased exposure to these chemicals can lead to a number of health issues, including impacts to reproduction, development, increased risk of cancers, immune system strength, hormone levels, and cholesterol, to name a few.
The scariest part of it all is the fact that we don’t know the full effects of these chemicals since there are thousands of them, they change composition over time, and they were introduced relatively recently.
They don’t naturally degrade and accumulate in the food chain
PFCs also break down very, very slowly–which is how they got the name “forever chemicals.” Their resistance to degradation means they can be found in the environment, in our blood, and in animals worldwide.
In 2022, researchers from North Carolina State University found biomagnification happening at every step of the food chain during a study on PFAS in the Yadkin-Pee Dee River. “We are part of the food chain, and when we ingest these foods, we accumulate their PFAS loads, too,” says Greg Cope, author of the study.
It’s not just human and environmental factors that are concerning, we’ve seen growing regulatory risk as well.
In California, beginning on January 1, 2025, an update to two laws prohibits intentionally adding PFAS in textile and cosmetic products.
New Hampshire will prohibit the sale and distribution of food packaging that contains perfluoroalkyl and polyfluoroalkyl substances beginning January 1, 2024.
A new federal ban on PFAS in cosmetics is anticipated to be introduced by the end of 2023.
As awareness of these chemicals grows, so does the backlash with huge lawsuits. In 2022 there was a class action suit filed against REI’s waterproof coat and Almay and Revlon for their PFAS levels.
Taking steps to ban these chemicals from being added to our products is only a starting point. Forever chemicals sneak their way into products via workers' clothing, equipment, lubricants, bottles, drums, totes, and more.
Just because they are not “intentionally” added doesn’t mean a company can’t be liable for their presence, which makes taking action for brands who want to do the right thing very challenging.
These forever chemicals are in essentially every consumer goods category. We can’t escape them–from tape, shampoo, furniture, cell phones, to-go food containers, cleaning products, cookware, clothing, and more.
Whether they are ending up in our products intentionally or unintentionally, they are a serious and material sustainability issue that demand action.
How can companies best address PFAS and other PFCs?
There are two ways PFAS can end up in your products: They are intentionally added and/or are present due to contamination.
While the challenges are real and numerous, we’ve worked to build leading-edge chemical management programs with brands in apparel, beauty, food & beverage, and packaging to come up with some universal best practices.
Implementing these recommendations won’t completely mitigate the risks - but they will demonstrate to people that you are taking intentional, proactive steps to address this material issue.
We’ve seen firsthand how this kind of due diligence can help insulate a company from both legal and reputational impacts.
Here’s our top recommendations for a comprehensive approach to managing PFAS risks in products:
1. Restrict their intentional use in your products
Problem: Brands don't know what ingredients are being used by their contract manufacturers and their suppliers.
Solution: Add them to your Restricted Substances List (RSL) and Manufacturing Restricted Substance List (MRSL) banning them from being added to your products as far up your value chain as possible. Confirming at each manufacturing step is another reason supply chain traceability is essential for consumer and environmental safety.
2. Identify safer alternatives using a hazard-based approach
Problem: These chemicals are common ingredients in a lot of products because of their performance qualities.
Solution: Work to find safer alternatives using a hazard based (as opposed to a risk based) approach and a robust alternatives assessment framework. Although this has proven to be difficult for some applications we need to continue to innovate and encourage solutions.
The outdoor gear market caught heat (legal and reputational) over the last couple of years for their use of PFAS in water proof clothing. Companies like Patagonia and Fjallraven have started create solutions through safer chemistry innovation.
As with any complex challenge, optimizing solutions that are safer as well as being competitive in terms of cost and performance takes time.
We’re optimistic about these solutions, like Biosurfactants, a green chemistry win that contains microorganisms (bacteria, fungi, and yeast) to create a surface-active agent that can be used to replace forever chemicals.
3. Engage in supply chain due diligence
Problem: Your procurement process may not be effectively integrating your safety standard and chemicals management policies
Solution: Conduct robust due diligence before selecting a new contract manufacturer and/or suppliers. This often includes engaging your internal procurement partners to build out supplier questionnaires and lists of required documentation.
We have helped brands in the beauty, apparel, and food & beverage industries build effective chemicals management programs - we can help yours too. Get in touch!
4. Craft smart contractual agreements
Problem: Brands don’t own and operate their manufacturing process, so how can they ensure these chemicals are not being used?
Solution: Updating your Contract Manufacturing (CM) agreements to include a chemical management section creates another line of defense to ban the use of these chemicals intentionally.
Make sure to include provisions related to purity testing for raw materials, data sharing, process chemistry, and other provisions that address both intentionally added ingredients and contaminants.
5. Provide strategic partner onboarding
Problem: Many contract manufacturers and suppliers are lagging in their ability to identify and address restricted chemicals.
Solution: Once you’ve selected a new contract manufacturer and/or suppliers plan on hosting a user-focused onboarding process that helps educate and familiarize their team with your requirements.
6. Establish a comprehensive testing process
Problem: Even with all the “paper” controls in place, PFCs can still make their way into products for a variety of reasons - often as contaminants.
Solution: Create an analytical testing standard operating procedure for higher risk ingredients and products. This should include raw materials, ingredients, and finished products before launch.
Continue random spot testing for finished products currently in the market as appropriate. Use third party accredited laboratories with experience analyzing for this class of chemicals.
Obtaining accurate test results for PFAS and related chemicals continues to be very challenging.
From our experience this is true for the following reasons:
There are thousands of individual chemicals in this class and very few of them have standard test methods available
Few commercial laboratories have experience testing for these chemicals in consumer products
The chemical composition of PFCs means that false positives can be obtained when fluoride or flourite are present but not PFCs
Brands are morally (and legally) responsible for the ingredients in their products.
Forever chemicals can have well documented effects on people, the planet, and our environment.
Take the steps necessary to address this materially relevant sustainability and ESG issue.
Article Sources
Green Science Policy Institute. (2023). “PFAS”. Accessed at https://greensciencepolicy.org/harmful-chemicals/pfas/ on 12/5/23.
National Academies of Sciences, Engineering, and Medicine; Health and Medicine Division; Division on Earth and Life Studies; Board on Population Health and Public Health Practice; Board on Environmental Studies and Toxicology; Committee on the Guidance on PFAS Testing and Health Outcomes. Guidance on PFAS Exposure, Testing, and Clinical Follow-Up. Washington (DC): National Academies Press (US); 2022 Jul 28. Summary. Available from: https://www.ncbi.nlm.nih.gov/books/NBK584702/#
Agency For Toxic Substances and Disease Registry. (2022). “What are PFAS?”. Accessed at https://www.atsdr.cdc.gov/pfas/health-effects/overview.html on 12/5/23.
John Hopkins University. (2012). “PFOA and PFOS Detected in Newborns”. Accessed at https://publichealth.jhu.edu/2007/goldman-pfoa-pfos on 12/5/23.
EPA (2023). “Our Current Understanding of the Human Health and Environmental Risks of PFAS.” Accessed at https://publichealth.jhu.edu/2007/goldman-pfoa-pfos on 12/5/23.
United States Department of Health & Human Services. National Toxicology Program. (2023). “Per- and Polyfluoroalkyl Substances (PFAS)”. Accessed at https://ntp.niehs.nih.gov/go/PFAS on 12/5/23.
United States Environmental Protection Agency. (2023). “Our Current Understanding of the Human Health and Environmental Risks of PFAS.” Accessed at https://www.epa.gov/pfas/our-current-understanding-human-health-and-environmental-risks-pfas on 12/5/23.
World Health Organization. International Agency for Research on Cancer. (2023). “IARC Monographs evaluate the carcinogenicity of perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS)”. Accessed at https://www.iarc.who.int/news-events/iarc-monographs-evaluate-the-carcinogenicity-of-perfluorooctanoic-acid-pfoa-and-perfluorooctanesulfonic-acid-pfos on 12/5/23.
Environmental Health News. (2022). “Unintentional PFAS in products: A “jungle” of contamination”. Accessed at https://www.ehn.org/pfas-products-2656825930.html on 12/5/23.
American Bar Association (2023). “Product liability and intentionally—versus unintentionally—added PFAS”. Accessed at https://www.americanbar.org/groups/environment_energy_resources/publications/trends/2022-2023/july-aug-2023/product-liability-intentionally-versus-unintentionally-added-pfas/ on 12/5/23.
Time Magazine (2023). “All The Stuff in Your Home That Might Contain PFAS 'Forever Chemicals'”. Accessed at https://time.com/6281242/pfas-forever-chemicals-home-beauty-body-products/ on 12/5/23.
Greepeace (2023). “Detox My Fashion”. Accessed at https://www.greenpeace.org/international/act/detox/ on 12/5/23.
Natural Resources Defense Council. (2022). “Going Out of Fashion: U.S. Apparel Manufacturers Must Eliminate PFAS “Forever Chemicals” From Their Supply Chains”. Accessed at https://www.nrdc.org/resources/going-out-fashion-us-apparel-manufacturers-must-eliminate-pfas-from-their-supply-chains on 12/5/23.
Time Magazine (2023). “Inside the Race to Get Forever Chemicals Out of Raincoats”. Accessed at https://time.com/6252365/pfas-raincoats/ on 12/5/23.