When it comes to PFAS (per- and polyfluoroalkyl substances), regulators and customers are crystal clear: The toxicity, global presence and persistence of these chemicals demands widespread restrictions to reduce and eliminate their presence in consumer and commercial products.
Regulatory bans and restrictions on PFAS content in products are being broadly implemented in several U.S. states and in the European Union (EU), triggering manufactures to identify vulnerabilities, reformulate products to eliminate PFAS and retool production lines before regulations take effect. Known and inadvertent PFAS use will have implications for many manufacturers where PFAS content in products is a significant threat. Conversely, it also creates an opportunity for Future Ready® companies to gain competitive advantage.
While the changing picture of ubiquitous PFAS presence from a customer and commerce access viewpoint poses considerable challenges, there are some critical steps that can be followed to successfully identify threats, manage risks and access opportunities.
Shift in Focus
Public and regulatory concerns around PFAS have largely focused on releases to the environment, such as firefighting foam application and industrial discharges. These releases impact the water we drink and air we breathe – our health.
Industry leaders are concerned about health impacts of these emerging contaminants. It might be a plume of PFAS-impacted groundwater that was migrating towards a water well or wetland. Increasingly, companies are unable to send wastewater to municipal water treatment plants due to concern about PFAS in the effluent. Manufacturers also risk difficulties selling surplus property due to PFAS impacted soil from testing fire suppression systems.
Those concerns are still very much alive, but growing PFAS commerce restrictions threaten the ability of manufacturers to sell their products and brings an urgent dynamic to company PFAS risk exposure.
Shifting Consumer and Regulatory Priorities
Regardless of current or upcoming regulations, many consumers and industrial buyers are concerned about PFAS, particularly in products intended for children. This means that being able to claim that a product is “PFAS free” creates a powerful market advantage. Consumers may be more inclined to choose a product that provides that reassurance, even if the price is higher.
As awareness of PFAS grows, companies wanting to export will have to satisfactorily respond to pointed questions about PFAS in their products, including proving PFAS-free status, or risk potentially losing customers.
Whether from customer concern or government restrictions and prohibitions, companies unable to certify that their products do not contain PFAS may be cut off from their markets. On the other hand, companies that have proactively removed PFAS from their products, including components and parts from further back in their supply chain, may find themselves with an expanded customer base.
More focus on PFAS inside the plant gates
Now that the focus of regulatory and public concern has turned to toxins in consumer products, identifying PFAS presence in supply chains and on processes are key initial steps to ensuring access to customers.
PFAS are used to impart durability characteristics and enhance production rates of thousands of consumer and industrial products. A huge swath of the global industrial base is impacted by PFAS that have penetrated supply chains.
Supplier-provided technical data sheets and safety data sheets frequently do not contain information on PFAS as this information is held back as a trade secret or a high composition reporting threshold.
What will the future of PFAS be?
PFAS are unlikely to disappear from the environment any time soon. Decades of uncontrolled use in industrial and consumer products has led to its distribution from the arctic to the Mariana Trench. PFAS are present in air, water and soil all over the globe, and their compounds are designed to be durable – it’s why they’re called “forever chemicals.”
Manufacturing prohibitions on toxic chemicals have proven to be effective at protecting health and the environment. The Montreal Protocol ban on ozone-depleting substances has led to a significant recovery of the ozone layer. Lead phaseouts in gasoline, paints and plumbing has lowered the populations average blood lead concentration. Similarly, the phaseout of two of the most toxic PFAS — PFOA (perfluorooctane sulfonic acid) and PFOS (perfluorooctanoic acid) — has lowered the blood concentrations of these chemicals. There are numerous examples of commerce restrictions having beneficial health outcomes.
Another aspect of “forever” is that PFAS materials continue to be made and used because they are so useful. This ranges from critical renewable energy components to lifesaving medical devices such as catheters, stents and implants. So, exemptions for some PFAS uses will likely continue – such as in medical devices, military and space applications, and the pharmaceutical sector.
Increasingly, we see companies going PFAS-free from the ground up – literally. They’re designing new facilities in which the structure itself is constructed without PFAS in the building materials, the manufacturing equipment that is PFAS-free, and the company uses processes, raw materials and components that do not include PFAS.
Managing PFAS risks, seizing opportunities
How can companies manage risks from PFAS and gain access to the opportunities that are available?
Companies can manage PFAS risks and access opportunities by addressing the challenge through a comprehensive approach. This involves both internal efforts and external collaboration.
Internally, employees who are familiar with the company's processes, supply chain and other facets must take the lead in understanding the PFAS picture.
Externally, companies can benefit from the expertise of firms like WSP that specialize in PFAS risk management. These firms:
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have developed methodologies for understanding business risks and creating strategies to mitigate them;
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can help companies benchmark best practices, find hidden PFAS in products, and identify substitutions and solutions for PFAS-free replacements; and
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Can assist in working with supply chain partners to identify PFAS in their products and prepare specifications for PFAS-free replacements
By combining internal knowledge with external expertise, companies can effectively manage PFAS risks and seize opportunities to gain a competitive advantage.
Learn more about PFAS management, investigation and treatment approaches and advanced destructive remediation technologies that WSP provides to its clients to help them overcome their PFAS challenges.