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Department of Ecology
Committees, Boards, and Workgroups

PFAS in Food Packaging Alternatives Assessment

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.

Register for upcoming webinars

These webinars will provide a project update on the PFAS in Food Packaging alternatives assessment.

May 26 webinar materials: Ecology presented a webinar on May 26, 2020 focused on the Performance Assessment Module of the PFAS in Food Packaging AA. Listen to a recording of the webinar or review the presentation slides, available in the documents section below.

Business leaders step forward on GreenScreen® chemical hazard assessments

Several chemical manufacturers and producers informed Ecology they are working to develop and submit chemical hazard assessments for safer alternatives to the agency. Working in partnership with industry, Ecology’s new PFAS in Food Packaging program has statutory authority to protect confidential business information (CBI) regarding chemical formulation information.

We encourage businesses to reach out to Rae Eaton at Ecology to learn how to participate in the CBI submission process.

How to get started with a GreenScreen® hazard assessment

Interested parties may contract their own GreenScreen® hazard assessment and share the report with Ecology under the following criteria:

  1. Interested parties are solely responsible for funding the development of the GreenScreen® profile should they choose this option.
  2. The assessment must be conducted by a Licensed GreenScreen® profiler using the most recent methodology.
  3. Ecology will require access to the full report in order to fully consider your product in the assessment. Stakeholders have the option to publish a redacted version of the document.

For more information, please refer to the CBI Process for PFAS AA 4-8-20 document.

Performance Module update

The performance assessment methodology for this AA will follow the IC2 Guidelines 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).

Welcome Rae Eaton

Ecology is pleased to welcome Rae Eaton, Ph.D., to the HWTR Program. Rae will be working in the Reducing Toxic Threats Unit, contributing to the PFAS in Food Packaging AA team as the Ecology project coordinator.

Rae is currently finishing her Senior Policy Fellow duties at the California Council on Science and Technology. Rae is developing guidance and a project inventory for natural resources monitoring projects at the California Natural Resources Agency.

Rae has BAs in Chemistry and Biochemistry from Oberlin College and a Ph.D. in Chemistry from the University of Washington. Rae is also a volunteer science educator with several organizations, including the Pacific Science Center and Out in STEM. In her off hours Rae enjoys baking bread, knitting hats, and going on long walks around town.

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.

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 packing 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.

The point of contact for the project is Ken Zarker, Ecology’s Pollution Prevention Section Manager: ken.zarker@ecy.wa.gov. For more information, see our PFAS AA Focus Sheet, or browse the documents available below.

Recent updates

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 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.

Exposure Assessment update

The exposure assessment approach for this AA will follow the IC2 Guidelines for a Level 1 Basic Comparative Exposure Assessment (herein IC2 Guide), 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 (herein HESI Exposure Guidance) (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.

Previous updates

In 2018, the Washington State Legislature passed a law (70.95G) prohibiting the manufacture, sale and distribution of these types of food packaging. It directs Ecology to study alternative products and report findings to the Legislature in 2020.  

Product category & alternatives prioritization

Our product categories include wraps and liners, bags, dinnerware, and takeout containers. This allows us to leverage information and data on the current uses across multiple product categories to seek opportunities to replace several toxic products with alternatives. Choosing products with a material overlap will help to maximize the positive impact on business that use these products.

We’re conducting research on the current market availability of the many types of materials used in food packaging, both with and without PFAS. As a result, we’re prioritizing the products in the alternatives assessment based on product volume and availability of alternatives, focusing on the most viable options while considering timeline and budget. More details are provided in the documents below.

Cost and availability data

Ecology and SRC received cost and availability data for alternative paper wraps, liners, bags & sleeves, dinnerware, and foodservice containers. We encourage interested parties who have not contacted the project team to send any data on cost and availability of alternative food packaging products, such as price lists, to Jenn Rhoades (rhoades@srcinc.com).

Completed webinars (audio posted)

  • 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:

For previous updates, see the archived documents below. 

Other PFAS resources

Washington Department of Ecology's PFAS Chemical Action Plan website
Washington PFAS in firefighting agents and equipment law (RCW 70.75A) and other information about firefighting foam and equipment.
Washington PFAS in food packaging law (RCW 70.95G), which also applies to metals in packaging.
Washington Department of Ecology's PFAS website.
Washington Department of Health's PFAS website.
Agency for Toxic Substances and Disease Registry (ATSDR) PFAS fact sheet and PFAS and your health website.
EPA's PFAS fact sheet and PFAS in your environment website.

Questions?

Contact Ken Zarker at ken.zarker@ecy.wa.gov or 360-407-6724. 

Documents

 File NameFile SizeDescriptionCategoryDate Added
PFAS AA Update Webinar 6-30-2020.mp4 62 MB
Webinar Materials 07/01/20 08:17 AM
WA PFAS in Food Contact AA June 30 2020 Webinar FINAL e-comment.pdf 1.5 MB
Webinar slides 06/30/20 12:41 PM
PFAS AA Performance Methodology_0601820 DRAFT APPROVED.pdf 759.1 KB
General information 06/18/20 08:56 AM
PFAS AA Update Webinar Recording 5-26-2020.mp4 58.9 MB
Webinar Materials 05/27/20 09:41 AM
PFAS AA Webinar Polling Question - May 26, 2020.xlsx 9 KB
Webinar Materials 05/26/20 01:41 PM
PFAS in Food Contact AA May 26 2020 FINAL.pptx 18.9 MB
Webinar slides 05/26/20 01:40 PM
Peer Reviewer NDA 4-3-20.docx 18 KB
General information 05/13/20 05:35 PM
PFAS AA Update Webinar Polling Questions 4-14-2020.xlsx 10.9 KB
Webinar Materials 05/04/20 01:31 PM
PFAS in Food Contact AA Apr 14 2020_FINAL.pdf 1.3 MB
Webinar slides 04/15/20 08:57 AM
PFAS AA Project Update Webinar Recording 4-14-2020.mp4 76.5 MB
Webinar Materials 04/15/20 08:53 AM
CBI process for PFAS AA 4-8-20.pdf 159.8 KB
Confidential Busines... 04/10/20 01:40 PM
PFAS_AA_CBI_Request_Template 4-8-20.pdf 93.3 KB
Confidential Busines... 04/10/20 01:40 PM
WA Ecology PFAS AA Exposure Methodology 03192020.pdf 376.4 KB
General information 03/20/20 04:13 PM
Ecology PFAS AA Hazard Methodology 03192020.pdf 192.2 KB
General information 03/20/20 04:12 PM
PFAS AA Project Update Webinar Recording 3-3-2020.mp4 55.9 MB
Webinar Materials 03/04/20 09:16 AM
Ecology PFAS Product and Alternatives Scoping Paper 02-24-2020.docx 26.7 KB
General information 02/25/20 11:14 AM
WA_Food Packaging_UserQuestions.docx 19 KB
General information 02/12/20 08:25 AM
GARE-Racial_Equity_Toolkit.pdf 4.5 MB
General information 02/12/20 08:23 AM
PFAS AA Project Update Webinar Recording 2-11-2020.mp4 51 MB
Webinar Materials 02/12/20 08:23 AM
PFAS in Food Contact AA January 2020 Update.pptx 18.6 MB
Webinar slides 02/12/20 08:21 AM
PFAS in Food Contact AA January 2020 Update.pptx 18.6 MB
Webinar slides 02/07/20 09:43 AM
PFAS AA Project Update 1-28-2020.mp4 45.8 MB
Webinar Materials 02/05/20 03:38 PM
PFAS AA May 2019 Update.pdf 374 KB
Project updates 01/27/20 10:29 AM
PFAS AA November 2019 update.pdf 179 KB
Project updates 01/27/20 10:23 AM
PFAS AA October 2019 update.pdf 271.1 KB
Project updates 01/27/20 10:23 AM
PFAS AA September 2019 update.pdf 297.5 KB
Project updates 01/27/20 10:22 AM
PFAS AA August 2019 update.pdf 108.3 KB
Project updates 01/27/20 10:21 AM
PFAS AA July 2019 update.pdf 279.6 KB
Project updates 01/27/20 10:21 AM
PFAS AA Webinar_05152019.pdf 3 MB May 2019 Webinar
May 2019 Webinar
Webinar slides 01/27/20 10:18 AM
PFAS AA February 2019 update.pdf 177.3 KB
Project updates 01/27/20 10:15 AM
PFAS AA January 2019 update.pdf 174.7 KB
Project updates 01/27/20 10:15 AM
PFAS_Food_Pckg_AA_Statement_of_Work.pdf 585.3 KB
General information 01/27/20 10:03 AM
PFAS_Food_Pckg_AA_Deliverables.pdf 397.4 KB
General information 01/27/20 10:03 AM
PFAS_Food_Pckg_AA_Timeline.pdf 345.6 KB
General information 01/27/20 10:02 AM
PFASFoodPackagingAAProjectSummary110618.pdf 618.9 KB
General information 01/27/20 10:02 AM
PFAS_AA_Hazard_Assess_Methodology_DRAFT.pdf 424.7 KB
Hazard Assessment 01/27/20 10:01 AM
PFAS_AA_Hazard_Assess_Overview.pdf 595.7 KB
Hazard Assessment 01/27/20 10:01 AM

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