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 love that the instructor emphasized the thought process behind the regs.

Rebecca Saxena

Corporate Product Stewardship Specialist

Lion was very extensive. There was a lot of things that were covered that were actually pertaining to what I do and work with. Great Job. I will be coming back in three years!

Tony Petrik

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

Very witty instructor, made the long times sitting bearable. One of the few training courses I can say I actually enjoyed.

John Hutchinson

Senior EHS Engineer

This is a very informative training compared to others. It covers everything I expect to learn and even a lot of new things.

Quatama Jackson

Waste Management Professional

I like the consistency of Lion workshops. The materials are well put together and instructors are top notch!

Kevin Pylka

Permitting, Compliance & Environmental Manager

The instructor was probably the best I ever had! He made the class enjoyable, was humorous at times, and very knowledgeable.

Mary Sue Michon

Environmental Administrator

Energetic/enthusiastic! Made training enjoyable, understandable and fun!

Amanda Walsh

Hazardous Waste Professional

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

My experience with Lion classes has always been good. Lion Technology always covers the EPA requirements I must follow.

Steven Erlandson

Environmental Coordinator

Download Our Latest Whitepaper

A guide to developing standard operating procedures, or SOPs, that help you select, manage, and audit your hazmat agents and contractors.

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.