3 Questions to Get Started with PFAS Risk Assessment

Determining the full extent of an organization’s PFAS risk and liabilities can be challenging, especially for companies that don’t have PFAS expertise in-house. Hidden sources of PFAS risk—like opaque supply chains and PFAS-contaminated process water—can make it difficult to determine whether or not companies have a PFAS problem and where exposures to PFAS are coming from. At the same time, complex and evolving PFAS regulations and rising litigation costs make understanding PFAS risk an urgent priority.

Our PFAS experts are here to help. Keep reading to learn why PFAS is a problem, and three questions to ask to get started with PFAS risk assessment.

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What’s the Problem with PFAS?

Per- and polyfluoroalkyl substances (PFAS) are a large group of manmade chemicals used in a broad range of consumer and industrial products. Since the mid-20th century, PFAS chemicals such as polytetrafluoroethylene (PTFE), perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS) have been prized for their non-stick, water- and oil-resistant, and heat-resistant properties. Over the last several decades, the use of PFAS has exploded, with thousands of PFAS chemicals now in use.

More recently, some PFAS have come under intense regulatory scrutiny due to human health and environmental concerns. Some have been linked to adverse health impacts, including cancer, liver and kidney damage, immune system effects, and other health problems. PFAS contamination in soil, water and air is also a growing concern. Companies now face a confusing landscape of state, national and international PFAS regulations and a growing risk of lawsuits, fines and remediation orders. They are also under consumer and stakeholder pressure to remove PFAS from products to reduce exposure for consumers and workers and keep these toxic substances out of the environment.

These conditions create considerable uncertainty and risk for manufacturers and suppliers. Risk related to PFAS encompasses the legal, financial, operational, and health and safety risks companies may face related to PFAS in products, supply chains and waste streams. Assessing PFAS risk can be challenging. Companies may not even be aware of what types of PFAS are in their products, where PFAS enters manufacturing processes, and how much total PFAS their products contain. Mitigating PFAS risk can be even more problematic, as it is difficult to find material substitutes that provide the same functional benefits as PFAS chemicals.

3 Questions in Assessing PFAS Risk

Addressing a PFAS challenge starts with assessing an organization’s associated PFAS risks, exposures and replacement options. Data gathered during PFAS risk assessment is then used to inform actionable steps like PFAS replacement and environmental remediation.

These three questions can help organizations define their potential for PFAS risk. While not a substitute for expert consulting, they can help companies determine if PFAS expertise is needed to help address their risks.

#1: Where does PFAS currently exist in products and supply chains?

The first step is figuring out where (or whether) PFAS exists in products, processes, packaging, supply chains and waste streams. In some cases, this may be known. Companies should start with an inventory of all known and suspected PFAS chemicals used in their products and processes and gather safety data sheets (SDS) for these substances.

In other cases, identifying PFAS is more difficult. Suppliers are not required to disclose the exact chemicals used in proprietary formulations, which means PFAS can be hiding in raw materials, production inputs and packaging. The SDS can provide important clues, even if it does not reveal the specific chemicals used. Materials that provide water, oil, heat or chemical resistance or non-stick properties should be considered highly likely to contain PFAS, even if it is not disclosed.

What To Do:

If you are not sure whether, how much or what types of PFAS are in your products, a chemical analysis may be needed. It can be helpful to start with a simple and low-cost screening test to determine whether or not PFAS is present.

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#2: What regulations govern PFAS used in my products?

Understanding the regulatory landscape around PFAS is critical to assessing regulatory PFAS risk for your organization. PFAS regulations are rapidly evolving on multiple levels, including state, national and international.

In the United States, the Agency for Toxic Substances and Disease Registry (ATSDR) (part of the U.S. Department of Health and Human Services) has set Minimal Risk Levels (MRLs) for several PFAS compounds, including PFOA and PFOS, which act as a guide for regulatory action. The U.S. Environmental Protection Agency (EPA) has set lifetime health advisories for PFOA and PFOS in drinking water and enforceable maximum contaminant levels (MCLs) for a number of PFAS chemicals. Several individual states, such as California and Maine, have set their own limits for PFAS in drinking water and consumer products. Regulation is also on the rise in Europe and other parts of the world.

Companies using certain PFAS chemicals in products and processes face a growing risk of material obsolescence as new regulations come into force. They may also be exposed to costs and liabilities due to regulatory action, such as environmental remediation orders or fines for non-compliance with product safety regulations. It is vital for companies to ask:

• What regulations related to PFAS currently exist in the areas in which we operate, manufacture and sell (or hope to sell in the future)?
• Do these regulations impact the specific PFAS chemicals used in our products, processes or packaging?
• Are new regulations proposed that will impact these chemicals in the future?
• What are our financial, legal and operational risks related to evolving regulations?

What To Do:

Navigating PFAS regulations can be complex and overwhelming. Consulting with PFAS experts can help companies ensure their regulatory PFAS risk is properly identified and addressed.

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#3: What benefit(s) does PFAS provide?

PFAS are found in a variety of consumer and industrial products due to their unique and highly useful chemical properties. In order to weigh potential business impacts, it’s important to identify all of the functional benefits that PFAS provides in products and processes and determine how essential these benefits are.

PFAS chemicals are often explicitly selected in product development for their functional properties—for example, to add stain-resistance or water-repellence to fabrics, grease-resistance to food packaging, non-stick surfaces to industrial or consumer goods, or heat-resistance to seals or coatings. Finding safer and less-regulated alternatives that provide similar functional benefits can be difficult. Companies should ask:

• What is the functional purpose provided by the chemical?
• How critical is that function to overall product effectiveness or competitiveness?
• Can it be replaced by another PFAS chemical that is safer and has less regulatory risk?
• Can it be removed without negatively impacting product performance?

What To Do:

A partner with expertise in advanced materials development and chemistry can help you evaluate your options for PFAS removal and material replacement. It is often possible to find safer material alternatives that provide similar functional benefits.

Getting Started with PFAS Risk Assessment

When it comes to PFAS risk assessment, count on the PFAS experts at Battelle. Our team uses a strategic and comprehensive risk analysis framework to evaluate technical, functional and business risks related to PFAS and recommend specific mitigations. We work across the entire PFAS lifecycle, including vulnerability assessment, analytical services, risk assessment and ranking, material alternative assessment, and environmental remediation.

Facing a PFAS challenge? Fill out a contact form here or email us at [email protected] to get in touch with our PFAS experts today.

Want to find out more about a framework for understanding, managing and mitigating PFAS risk? Hear from our experts by downloading our “Addressing PFAS Challenges” white paper.

Featured Expert

Dan Longbrake

Director, Commercial Business Development and Sales, PFAS, Emerging Chemicals, Permitting, Environmental Compliance

Dan leads and facilitates commercial engagements to develop and advance Battelle’s PFAS and environmental technologies, tools, and services. He has over 36 years of experience in the environmental industry. Dan joined Battelle in January 2021, and since that time has focused on developing and executing go-to-market strategies, creating alignment and nurturing client relationships, and positioning Battelle as a trusted partner.