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

I was able to present my scenario to the instructor and worked thru the regulations together. In the past, I attended another training firm's classes. Now, I have no intention of leaving Lion!

Diana Joyner

Senior Environmental Engineer

Lion courses always set the bar for content, reference, and practical application. Membership and access to the experts is an added bonus.

John Brown, CSP

Director of Safety & Env Affairs

The price was reasonable, the time to complete the course was manageable, and the flexibility the online training allowed made it easy to complete.

Felicia Rutledge

Hazmat Shipping Professional

Our instructor was very dynamic and kept everyone's interest. Hazmat shipping can be a dry, complicated topic but I was engaged the entire time.

Kimberly Arnao

Senior Director of EH&S

I really enjoyed this training. Even after years on both sides of the comprehension coin, I find myself still learning! The quality of the delivery exceeded much of the training I have received in the past.

Neil Ozonur

Safety Officer

Very good. I have always appreciated the way Lion Tech develops, presents and provides training and materials.

John Troy

Environmental Specialist

These are the best commercial course references I have seen (10+ years). Great job!

Ed Grzybowski

EHS & Facility Engineer

Amazing instructor; real-life examples. Lion training gets better every year!

Frank Papandrea

Environmental 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

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

Download Our Latest Whitepaper

In most cases, injuries that occur at work are work-related and must be recorded to maintain compliance with OSHA regulations. This report shows you the 9 types of injuries you don’t record.

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.