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Per- and polyfluoroalkyl substances (PFAS) are a class of human-made chemicals that possess unique physiochemical properties and are found in a wide range of products used by consumers and industry. In fact, there are more than 5,000 different types of PFAS, some of which have been more commonly used than others. Many PFAS persist in the environment, and some accumulate in the human body. Research on the potential health effects of various PFAS suggests that certain PFAS may be associated with health conditions (FDA 2020a). In the general population, dietary exposure from the ingestion of food and drinks, including drinking water, is the predominant exposure pathway for PFAS (Poothong et al. 2020). According to the Environmental Protection Agency (EPA), the general population can be exposed to low levels of PFAS through food, including from contamination in soil and water used to grow the food, equipment that uses PFAS during food processing, as well as PFAS-containing food packaging (EPA 2018). Select PFAS have been authorized by the Food and Drug Administration (FDA) for limited use in cookware, food packaging, and food processing equipment due to their resistance to grease, oil, water, and heat (FDA 2020a). As part of their efforts to minimize potential exposure to PFAS from food, the FDA regularly conducts testing of food from the general food supply and from food grown or processed in areas with environmental PFAS contamination, monitors scientific developments related to PFAS, and takes action to ensure that compounds of concern are excluded from food (FDA 2020a).

On July 31, 2020, the FDA announced that three manufacturers were initiating a voluntary, 3-year phase-out of the sale of food contact substances containing 6:2 fluorotelomer alcohol (6:2 FTOH), which are used as grease-proofing agents in paper and paperboard food packaging. A fourth manufacturer stopped sales of food contact substances that may contain 6:2 FTOH in 2019 (FDA 2020b; Nelter 2019). Following the 3-year period, it is estimated to take 18 months to exhaust existing stocks of products containing these food contact substances from the market. These food contact substances replaced the long-chained PFAS that were used in food contact applications prior to 2011 (FDA 2020b). However, a recent animal study by Kabadi et al. (2020) reported that 6:2 FTOH was biopersistent in rats after repeated oral exposures, indicating that it may also persist in humans following dietary exposure.

It is noteworthy that various states have proposed or adopted regulations pertaining to PFAS in food contact materials. In 2018, Washington became the first state to prohibit the manufacture and sale of food packaging containing PFAS under bill HB2658/SB6396 (Safer States 2020; Washington SB 6396). In 2019, Maine adopted a similar bill (LD 1433), which “[p]rohibits the sale of food packaging with intentionally added toxic heavy metals, PFAS, or phthalates” (Safer States 2020). Several other states are in the process of adopting similar bills banning PFAS in food packaging, including Arizona, Connecticut, Illinois, Iowa, Massachusetts, Minnesota, New Hampshire, New Jersey, New York, Rhode Island, Vermont, Virginia, and Wisconsin. Based on the legislative progress, New York may become the third state to ban PFAS in food packaging (Safer States 2020).

Cardno ChemRisk scientists have extensive professional experience evaluating the possible hazards and risks posed by chemicals in consumer products, including PFAS. Please contact Dr. Marisa Kreider (marisa.kreider@cardno.com) and Ms. Heather Lynch (heather.lynch@cardno.com) for more information on our capabilities regarding PFAS, and Dr. Ernest Fung (ernest.fung@cardno.com) for more information on our capabilities regarding consumer products.