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Get involved with the PFAS alternatives assessment

Join our email list to stay up-to-date on where we are in the process. 

We welcome your input and feedback. If you have information or data to share that could help inform our alternatives assessment process, please submit your comments to us. Review feedback received from stakeholders throughout the alternatives assessment process on our comments page.

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Stakeholder engagement update  

Ecology and Health know there is a lot of interest in the PFAS Alternatives Assessment (AA) and we thank you for your engagement. We will continue to offer engagement opportunities for those interested through this website, email list, eComment site, and future webinars.

In the meantime, if you’re looking for ways to reduce exposure to PFAS at home, check out our PFAS infographic.

Peer review process

Under state law, Ecology is required to conduct an external peer review, publish the AA findings and peer review feedback in the Washington State Register, and provide a report to the relevant committees of the state Legislature. The Washington State Academy of Sciences (WSAS) will provide a summary report to Ecology with committee members’ comments on the PFAS AA Peer Review Draft, including:

• The assessment methodologies derived from the IC2 Alternative Assessment Guide,
• Whether suitable alternatives have been considered, and
• The report’s conclusions regarding alternatives for food packaging containing PFAS.

Visit the WSAS website to see the list of committee members who will conduct the PFAS AA peer review, or read their professional bios for more information.

Ecology does not plan to share the draft PFAS in Food Packaging AA or the related report to the Legislature before finalizing and submitting it. Because the AA documents are still undergoing deliberative reviews and our conclusions may change, we are unable to share drafts prior to publication.

The statute (now codified at RCW 70A.222.070) requires Ecology to submit “a report with the findings and the feedback from the peer review of the department’s alternatives assessment…” Our determinations about the availability of safer alternatives must be “supported by feedback from an external peer review of the department's alternatives assessment…” Based on this language, the AA we submit to the Legislature must be the same as what we provide to the peer reviewers.

Thank you for your continued interested in the PFAS AA. Please reach out to Rae Eaton (rae.eaton@ecy.wa.gov) with any questions.

Alternative Assessment Summary

Hazard Assessment update

The project team updated the draft hazard methodology that we issued in October 2019 (see documents section). Ecology is using a tiered approach to the hazard assessment based on the IC2 Guidelines for a Level 2 Hazard Assessment (herein IC2 Guide) and our May 2019 Stakeholder Webinar. The approach categorizes the alternatives into three groups:

• Process treatments: Dry-end coatings or wet-end additives that are applied to the base material to provide oil and grease repellent properties to the product.
• Base materials: The primary substrate (paper, paperboard, fiber pulp, plastics, and aluminum), treated (including mechanical densification) or untreated.
• System alternatives: Alternatives that provide the desired function but are not process treatments or base material alternatives. The primary system alternative for the PFAS in Food Packaging AA is reusable packaging and service ware.

The tiered approach helps us assess these substances to ensure project efficiencies, reduce potential redundancy, and maintain consistency with the IC2 Guidelines. This approach incorporates previous assessments and methods such as the GreenScreen® List Translator, the Safer Chemical Ingredients List (SCIL), and other publicly-available, high-quality assessments.

The Hazard Assessment Methodology is available in the documents section below.

Exposure Assessment update

The exposure assessment approach for this AA is based on the IC2 AA Guide for a Level 1 Basic Comparative Exposure Assessment, which is a qualitative, property-based approach to characterizing exposure.

This approach meets the U.S. National Academy of Sciences (NAS) “Path B” recommendations for comparative exposure assessment. Our approach also incorporates elements of EPA’s Sustainable Futures Interpretative Assistance Document for Assessment of Polymers (2013) and the Health and Environmental Sciences Institute’s (HESI) Sustainable Chemical Alternatives Technical Committee’s qualitative comparative approach (Greggs W et al., 2018).

The IC2 Guide organizes the Basic Comparative Exposure Assessment via a series of questions. The questions assess readily-available data to identify whether material differences exist between the chemical of concern and potential alternatives. If the properties and potential pathways are similar, additional evaluation is not necessary and the decision rules are applied. If there are material differences, an additional evaluation is conducted to address questions related to biomonitoring data, manufacturing criteria, or lifecycle information. See the documents below for the complete exposure assessment approach.

The Exposure Assessment Methodology is available in the documents section below.

Performance Assessment Module update

The performance assessment methodology for this AA is based on the IC2 AA Guide for a Level 1 Basic Performance Evaluation. The IC2 approach uses readily available qualitative descriptions and marketing information to answer several questions so the “assessor can make a reasonable evaluation of the alternative’s technical feasibility.” 

The goal of the performance assessment it to determine whether the PFAS alternatives perform the required function. This approach is designed to meet the requirements under RCW 70.95G.070 which states that alternatives perform as well as or better than PFAS chemicals in a specific food packaging application.

For more background, refer to the information highlighted in the Ecology PFAS Product and Alternatives Scoping Paper (2/24/2020) and the Performance Assessment Methodology in the document section below.

Cost and Availability

To assess PFAS-free alternatives, Ecology conducted a Basic Cost and Availability Evaluation (Level 1) based on the IC2 AA Guide. Chapter 70.95G RCW directs Ecology to perform an PFAS AA using the IC2, but also that, “the safer alternative must be readily available in sufficient quantity at a comparable cost.” Additional considerations of cost and availability were included to address these requirements.

Background

In 2018, Washington State passed a law to prohibit all Perfluoroalkyl and Polyfluoroalkyl (PFAS) in plant fiber-based food packaging. The PFAS ban takes effect following the identification of safer alternative products as described in the Toxics in Packaging law (RCW 70.95G). 

The PFAS Alternatives Assessment (PFAS AA) must consider chemical hazard, performance, cost and availability, and exposure. Following the product evaluations, the Washington State Department of Ecology (Ecology) will submit their findings for external peer review and publish the results in the Washington State Register. If Ecology does not find a safer alternative, then the department will conduct an annual review and report on alternatives.

Alternatives assessment scope

We originally planned to focus our analysis on food wrappers and liners, which are the most common application of PFAS in food packaging. Based on our research and feedback from interested parties, we’re expanding the scope of the assessment to include additional food packaging types.

In addition to food wrappers and bags, the new research includes other categories such as plates, bowls, trays and take-out containers. We will be reaching out to end users of these products for input on the use of alternatives in the market.

Other Resources

Alternatives Assessment Topics of Interest

Hear from the Association for the Advancement of Alternatives Assessment on the current state of environmental justice and health equity considerations in the alternatives assessment approach. Get a list of the resources they provide in the webinar on their past webinars page.

Other PFAS Information

Completed webinars (audio posted)

• August 10, 2020: Cost and Performance Assessment, and Performance Assessment Module
• May 26, 2020: Performance Assessment Module
• April 14, 2020: Performance Assessment Module
• March 3, 2020: Project Update & Exposure Methodology
• February 11, 2020: Hazard Methodology, Product & Alternatives Prioritization Update and Environmental Justice
• Ecology provided a project update on the hazard assessment methodology and our approach to prioritizing product categories and alternatives assessment. Ecology shared a copy of the PFAS in Food Packaging user questions to seek input from interested parties.
• Ecology also included a brief update on efforts to integrate environmental justice into the project. A copy of the Racial Equity Toolkit developed by the Government Alliance on Race and Equity is provided below. Racial equity tools are designed to integrate explicit consideration of racial equity in decisions, including policies, practices, programs, and budgets. Materials are posted below.
• January 28, 2020: Ecology PFAS AA update
• Ecology hosted a project update webinar on the recent staff changes and project schedule. Materials are posted below.

For more information, contact the PFAS AA Team:

• Rae Eaton, Ecology Project Coordinator – rae.eaton@ecy.wa.gov
• Ken Zarker, Ecology Project Manager – ken.zarker@ecy.wa.gov
• Cathy Rudisill, SRC, Project Manager – rudisill@srcinc.com
• Jenn Rhoades, SRC, Stakeholder Outreach Lead – rhoades@srcinc.com
• Courtney Hard, SRC, Technical Lead – hard@srcinc.com

For previous updates, see the archived documents below. 

Questions?

Contact Rae Eaton at rae.eaton@ecy.wa.gov. 

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