Search

Plastic Container Manufacturing Process May Create PFAS

Posted on 4/4/2022 by Lauren Scott

Last month, US EPA penned an open letter addressed to stakeholders who manufacture, process, distribute, use, or dispose of fluorinated high-density polyethylene (HDPE) containers and similar plastics (i.e., fluorinated polyolefins).

EPA has found that per- and polyfluoroalkyl substances (PFAS) may form as a byproduct during the manufacturing process and later contaminate the environment. 

The letter reminds stakeholders that these byproducts are not exempt from the TSCA Significant New Use Reporting requirements for long-chain perfluoroalkyl carboxylate (LCPFAC) at 40 CFR 721.10536.

Manufacturers must notify EPA of any PFAS byproduct generated via a Significant New Use Notice (SNUN). The SNUN allows EPA to assess the potential risks of this use under TSCA section 5 and determine whether the use should continue (under which conditions as necessary).

Normally performed to protect containers from weathering degradation, certain fluorination processes may run a higher risk of generating PFAS. EPA has found that fluorination using fluorine gas with an inert gas could reduce the potential for inadvertent PFAS manufacture.

TSCA Enforcement Alert: Unlisted PFAS in Ski Wax Products

Earlier this year, US EPA released an enforcement alert after identifying several ski wax products sold in the US that contain per- and polyfluoroalkyl substances (PFAS) that are not listed on the TSCA Chemical Substance Inventory. The alert follows enforcement actions in which two ski product distributors allegedly imported PFAS-containing ski waxes in violation of TSCA.

The Agency published the notice to remind ski wax sellers to ensure that the products they sell do not contain PFAS that are not on the TSCA Chemical Substance Inventory or have prohibitions on their use in sporting goods.

EPA recommends reviewing the product's Safety Data Sheet (SDS) or contacting a manufacturer or supplier for details about chemical identity information. Manufacturers and importers may also contact EPA's TSCA Hotline with additional questions about compliance.

Convenient, Effective Online EHS Manager Training

Managing site compliance with the many complex EPA programs that affect your business—from the Clean Air and Clean Water Acts to TSCA, EPCRA, CERLCA, and more—is a major challenge. If you’re new to the field or need an update on changing EPA rules, online training is a convenient way to quickly build in-depth expertise.

The Complete Environmental Regulations online course will prepare you to identify your site's liabilities and responsibilities under major environmental laws and regulations. This course is ideal for new EHS managers, environmental consultants, and anyone who wants clarity about how complex environmental requirements fit together. 

Or check out these courses on specific EPA programs:
 
TSCA Regulations Online
Clean Air Act Regulations Online
Clean Water Act & SDWA Regulations Online
Superfund and Right-to-Know Act Regulations Online 
 

Tags: environmental compliance, PFAS, TSCA

Find a Post

Compliance Archives

Lion - Quotes

The instructor made the class very enjoyable and catered to the needs of our group.

Sarah Baker

Planner

This course went above my expectations from the moment I walked in the door. The instructor led us through two days packed with useful compliance information.

Rachel Stewart

Environmental Manager

The instructor clearly enjoys his job and transmits that enthusiasm. He made a dry subject very interesting and fun.

Teresa Arellanes

EHS Manager

Lion Technology workshops are amazing!! You always learn so much, and the instructors are fantastic.

Dorothy Rurak

Environmental Specialist

Lion courses are the standard to which all other workshops should strive for!

Brody Saleen

Registered Environmental Health Specialist

Lion's information is very thorough and accurate. Presenter was very good.

Melissa Little

Regulatory Manager

I tried other environmental training providers, but they were all sub-standard compared to Lion. I will not stray from Lion again!

Sara Sills

Environmental Specialist

Attending Lion Technology classes should be mandatory for every facility that ships or stores hazmat.

Genell Drake

Outbound Lead

The instructor created a great learning environment.

Avinash Thummadi

CAD & Environmental Manager

Lion's training was by far the best online RCRA training I've ever taken. It was challenging and the layout was great!

Paul Harbison

Hazardous Waste Professional

Download Our Latest Whitepaper

Use this guide as a quick reference to the most common HAZWOPER questions, and get course recommendations for managers and personnel who are in need of OSHA-required HAZWOPER training.

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.