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

Well designed and thorough program. Excellent summary of requirements with references. Inclusion of regulations in hard copy form, as well as full electronic with state pertinent regulations included is a great bonus!

Oscar Fisher

EHS Manager

We have a very busy work schedule and using Lion enables us to take the course at our own time. It makes it easy for me to schedule my employees' training.

Timothy Mertes

Hazmat Shipping Professional

Excellent course. Very interactive. Explanations are great whether you get the questions wrong or right.

Gregory Thompson

Environmental, Health & Safety Regional Manager

Much better than my previous class with another company. The Lion instructor made sense, kept me awake and made me laugh!

Marti Severs

Enterprise Safety Manager

Lion is easily and consistently the best option for compliance training. I've learned new information from every instructor I've had.

Rachel Mathis

EHS Specialist

I have attended other training providers, but Lion is best. Lion is king of the hazmat jungle!!!

Henry Watkins

Hazardous Waste Technician

Lion's online training is more comprehensive, has better slides, and is a superior training experience than what I would get from other trainers.

Robert Brenner

District Environmental Manager

Given the choice, I would do all coursework this way. In-person courses go very fast without the opportunity to pause or repeat anything.

Ellen Pelton

Chemical Laboratory Manager

Very well structured, comprehensive, and comparable to live training seminars I've participated in previously. I will recommend the online course to other colleagues with training requirement needs.

Neil Luciano

EHS Manager

The instructor made the class enjoyable. He presented in a very knowledgeable, personable manner. Best class I've ever attended. Will take one again.

John Nekoloff

Environmental Compliance Manager

Download Our Latest Whitepaper

Decrease spill, release, and injury risk and increase savings with these "source reduction" strategies to prevent unused chemicals from becoming regulated as hazardous waste.

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.