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The U.S. Environmental Protection Agency (EPA) is taking the next step to address per- and polyfluoroalkyl substances (PFAS) related to packaging potentially used to house pesticides and other substances. EPA is releasing the results from its evaluation of several fluorinated containers to determine the potential for PFAS to leach into the contents of these containers.
Previously, EPA learned of potential PFAS contamination in a small number of mosquitocide products. Prompted by this concern, from December 2020 through January 2021, EPA studied several samples of used and unused fluorinated high-density polyethylene (HDPE) containers. In March 2021, EPA released the data that preliminarily determined PFAS was most likely formed from a chemical reaction during the container fluorination process, which then leached into the pesticide product.
To build upon the initial findings, EPA completed another study to test the leaching potential of PFAS over a specific time into test solutions packaged in different brands of HDPE fluorinated containers. The results from this study indicate:
- Water or methanol used as surrogates for pesticide formulations (or other solutions similar to water or methanol) stored in fluorinated containers had quantifiable PFAS levels, which indicated that PFAS from container walls leached into the contents of the container.
- The total amount of leached PFAS at each point in time varied for different brands of fluorinated containers, which is likely a reflection of different fluorination levels and techniques used to fluorinate these containers.
- The total PFAS leached into the solutions increased gradually over the 20-week test period.
- Higher amounts of total PFAS were found in methanol solution than in water for the same containers, an observation consistent with the chemistry of methanol as a stronger solvent in dissolving organic compounds.
Based on these results, EPA has determined that liquid products packaged in HDPE containers treated with fluorination technology could leach certain PFAS into products from the container walls, even with water-based products. In addition, the total amount of PFAS leached into the products could increase over storage time and cause undisclosed levels of PFAS in a pesticide (or other) product. It is unclear at this time if PFAS would be present in all fluorinated containers treated by different fluorination technologies (since this study did not test all containers made using such technologies).
EPA’s PFAS Strategic Roadmap renewed the Agency’s commitment to using sound science and investing in research to proactively stop PFAS chemicals from entering the environment. Studies like this one advance EPA’s understanding of PFAS and shape further studies that can help determine the risk to human health and the environment from PFAS contamination.
EPA remains committed to using all available regulatory and non-regulatory tools to continue tackling PFAS. Most recently, EPA announced the removal of certain PFAS-related compounds from being authorized for use as inert ingredients in pesticides. This action adds to EPA’s commitment to better manage potential PFAS-related exposures to pesticides.
EPA continues to ask companies using fluorinated containers and entities providing container fluorination services to examine their distribution chains to identify potential sources of contamination. Under the Federal Insecticide, Fungicide and Rodenticide Act section 6(a)(2), pesticide registrants should report to EPA additional factual information on unreasonable adverse effects, including metabolites, degradates and impurities (such as PFAS).
EPA considers any level of PFAS to be potentially toxicologically significant. 6(a)(2) information about impurities must be received by EPA no later than the 30th calendar day after the registrant first possesses or knows of the information.
Furthermore, EPA considers the manufacturing of certain PFAS from the fluorination of polyolefins to be subject to EPA’s 2020 long-chain perfluoroalkyl carboxylate (LCPFAC) significant new use rule (SNUR) under the Toxic Substances Control Act (TSCA). Specifically, the SNUR requires industry to notify EPA at least 90 days before starting manufacturing or processing of these chemical substances for this significant new use, so that EPA could review any associated risks and impose any needed protections. The failure to submit such a notification would be a violation of TSCA.
If companies find PFAS in their products, they should notify EPA and take action to remove contaminated products. If product packaging is suspected as a source and replacing the packaging is being considered, please consult with EPA on data to be submitted for review prior to distribution of the pesticide product with the alternative packaging.
As more information becomes available, EPA will continue to work with other federal entities to provide guidance to states and localities that may be affected by PFAS in pesticide containers.
To review the leaching testing results and to learn more, please visit https://www.epa.gov/pesticides/pfas-packaging.
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