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George R. Pilcher, Vice President, The ChemQuest Group, Inc, discusses the concern surrounding PFAS and how it could affect the paint and coatings industry
In his beloved poem, “Jabberwocky,” Lewis Carroll created a number of neologisms that became a part of the English Language circa 1871, including a few that are still in use today (e.g., “galumphing” and “chortle”). In the late 20th century, new words were created to name objects or describe situations that had hitherto lacked descriptors. Words such as “cyberspace,” “staycation,” “webinar” and “regift” are now firmly ensconced in modern writing and conversation.
The newest acronym-cum-neologism in the global speciality chemicals industry is a collective noun: PFAS, which stands for “per- and polyfluoroalkyl substances.” PFAS has become ubiquitous in referring to a family of fluorine-containing chemical compounds that, depending upon which study one consults, has somewhere in the vicinity of 3,700-10,000 members.
The problem is not how many family members there are in this branch of chemistry, but rather how many of them are potentially harmful to life and how producers, users and regulatory bodies are going to determine which PFAS must be eliminated from use, and which may continue to be used.
"While this may not ultimately be the case, it clearly indicates one of the many ways in which the EU and the US differ with regard to regulatory issues. China is a wild card—it will certainly take action with regard to either certain or possibly all PFAS, but only a crystal ball would enable anyone to offer a likely scenario going forward."
PFAS fulfill critical roles in myriad industrial- and consumer-facing applications. Examples of the latter include the ability to impart water-, stain- and grease-resistance to consumer goods (e.g., food packaging), waterproof clothing, dental floss, and nonstick cookware. They are also used in pharmaceuticals (both packaging and medical products), highly durable building products for exterior cladding, refrigerants, blowing agents, propellants and sundry other applications.
The role of PFAS in the production of microchips by companies such as Intel, Infineon, BASF and many others is absolutely critical. “Without some PFAS, semiconductor manufacturing is simply not possible,” says a leading European chip executive. “There are no alternatives in the market yet.”1
PFAS are nearly indestructible, hence the term “forever chemicals,” and they “are impossible to avoid. They are found in our homes, our offices, our supermarkets—practically everywhere.”2 Many public officials, NGOs and private citizens believe that certain PFAS are “extremely toxic” at extraordinarily low levels—parts per quadrillion.3 But which ones?
Evaluating and categorising PFAS
It is generally seen as an impossible task to evaluate somewhere north of 4,730 chemicals, per the 2018 joint report by the Organization for Economic Co-operation and Development (OECD) and the United Nations Environment Programme (UNEP). This is causing a number of regulatory bodies to lump all fluorine compounds as PFAS, even if they are not PFAS and do not fit the current definition, to wit4:
Fortunately, the Society of Environmental Toxicology and Chemistry (SETAC) published a 2021 study5 in which it identified a subset of the 4,730 PFAS chemicals numbering 256 (5.5%) that are “commercially relevant.” If this is indeed the case, it suggests that grouping and categorising PFAS using fundamental classification criteria based on composition and structure can be used to identify appropriate groups of PFAS substances for risk assessment, thereby dispelling assertions that there are too many PFAS chemistries to conduct proper regulatory risk assessments for the commercially relevant substances.
Moreover, the study determined that only 241 of the 256 commercially relevant substances met the definition of PFAS. Of those, 52 were polymers, which are of great importance to the paint and coatings industry and are unlikely to prove hazardous to either human health or the environment.
Differing regulations around the world
Government regulators don’t always take the most logical steps or give an appropriate level of consideration to even the most carefully conducted studies. In the case of PFAS, this is likely to be compounded by the fact that various regions of the world are currently viewing the subject through different lenses and from different perspectives.
For example, the EU is actively studying the PFAS issue under the aegis of REACH/ECHA (European Chemicals Agency), with particular emphasis on the following four chemicals but still within the context of banning all PFAS:
- Perfluorooctanoic acid (PFOA—of significant concern in both the US and EU)
- Perfluorooctane sulfonic acid (PFOS—of significant concern in both the US and EU)
- Perfluorohexane-1-sulphonic acid (PFHxS), its salts, and related substances (principally of concern in EU, at least currently)
- Undecafluorohexanoic acid (PFHxA), its salts, and related substances (principally of concern in EU, at least currently)
- There will be others—possibly even by the time this article is published.
In contrast, the US government appears to be satisfied that the regulatory activity during 2000-2010 involving certain PFAS went far enough and is currently showing no interest in resuming its inquiries. In fact, the federal government has indicated that this should be an issue for the individual states, which—if this line holds—promises to cause no end of confusion, leading to a mishmash of regulatory fiats.
While this may not ultimately be the case, it clearly indicates one of the many ways in which the EU and the US differ with regard to regulatory issues. China is a wild card—it will certainly take action with regard to either certain or possibly all PFAS, but only a crystal ball would enable anyone to offer a likely scenario going forward.
Strategies for the future
These are uncertain times with regard to PFAS that are of critical importance for a variety of applications in a number of vitally important global industries. While nothing is currently certain, it is likely that common sense will prevail in the long term.
At worst, PFAS for certain applications will be declared “set asides,” enabling their use in critical areas to continue. At best, the global regulatory agencies will consult with each other to decide upon appropriate scientific (rather than knee jerk) approaches to determining which PFAS actually pose threats to human life and the environment. As with most things, it is likely that Aristotle’s “Golden Mean” (the midpoint between extremes) will prevail, and we will have neither the best nor the worst outcome with regard to the PFAS issue.
In the meantime, however, every industry that either produces PFAS chemicals or uses them in their process or end products will be struggling to replace current systems with equal (or only slightly lower) performance products. Some will succeed; most will not.
The best way to make sure that success can be achieved will be to cast aside the “NIH” syndrome and seek outside expertise to help achieve PFAS replacement goals. This is an onerous process and most PFAS producers and users will not only need to bring their best game to the task, but they will need all the help that they can get from independent, third-party individuals and organisations so that they have the broadest knowledge base possible at their disposal.
- “The crackdown on risky chemicals that could derail the chip industry,” Financial Times, 2023, https://www.ft.com/content/76979768-59c0-436f-b731-40ba329a7544.
- M.M. Ginty and C. Lindwall, “‘Forever Chemicals’” Called PFAS Show Up in Your Food, Clothes, and Home,” April 12, 2023, https://www.nrdc.org/stories/forever-chemicals-called-pfas-show-your-food-clothes-and-home.
- C8 Science Panel, http://www.c8sciencepanel.org/. (Note: The C8 Science Panel concluded its work and no longer exists; this website, accessed on May 30, 2023, summarises the work of the panel but may or may not be accessible in the future.)
- F. Averbeck, “PFAS under REACH Universal Restriction Proposal,” Bundesanstalt für Arbeitsschutz und Arbeitsmedizin (BAUA), 2022, https://www.asercom.org/wp-content/uploads/2022/05/Averbeck.pdf.