How to Identify PFAS in Your Supply Chain

Why do you need to know where PFAS are in your products?

Identifying where PFAS are in your products is essential as regulations on these substances multiply worldwide. Knowing which products contain PFAS can help you stay compliant with the law and avoid potential legal and financial repercussions. 

As consumer awareness of PFAS rises, end users and investors will move to choose non-PFAS alternatives that are safer for human and environmental health. This awareness and demand for PFAS-free products will drive industry changes. By creating products without PFAS, you can ensure your products retain relevancy and market access.

What products are high in PFAS?

PFAS are found in a wide range of consumer and industrial products due to their unique properties. Common products that often contain PFAS include non-stick cookware like Teflon-coated pots and pans and water-repellent or stain-resistant fabrics such as outdoor gear, rain jackets, and upholstery. Another popular category of products is grease-resistant food packaging, long wear cosmetics, and personal care products. 

While these are often the categories you hear about in the news, it’s important to understand that PFAS are also commonly used in other products as well. This includes:

• Paints, coatings, and sealants, where they help provide durable, weather-resistant properties
• Electronics and medical devices, where they provide insulation, sterility, and resistance to degradation
• PCB boards, which have their components coated with PFAS in order to protect them from dust and moisture
• Speaker membranes in audit systems, which are often treated with PFAS to allow sound permeability but not dust or moisture
• Electronic displays, which can have protective coatings that can contain PFAS
• Aerospace and automotive industries, which rely on wire and cabling made with PFAS to help the materials withstand high heat conditions and corrosion 

How do you determine if PFAS are in your product?

To determine where PFAS are in your product, you need to understand the uses of PFAS, as discussed above. By understanding why these substances are added to materials, you can become more adept at looking at where in your own product those characteristics are needed. Looking through your bill of materials (BOMs), as well as your specified drawings, can help you identify where parts will need water, chemical, or heat resistance. Parts coming into contact with electricity that require insulating materials are often treated with flame retardants. Sensitive equipment that may be disrupted by moisture may require the use of water resistant coatings or membranes. Identifying these key characteristics can give you an idea of where to begin looking at what those parts are made from.

Do you need to contact your suppliers to get this info? 

If you are not manufacturing the part yourself, chances are you will need to ask your supply chain for this type of information. It is important to understand the large amount of PFAS known today and to be clear in your inquiries to your suppliers. It’s also important to know that these new requirements are new for everyone, so it may take some time for your supplier to respond. Consulting a compliance or material expert can help you direct your inquiry in a way that is clear and easy to understand. It may require you to gather multiple kinds of documentation from suppliers to help assess this information. If the information is not available, another alternative, although expensive and time consuming, could be chemical testing. 

What documents should you be looking at?

Ideally, full material disclosures/declarations (FMDs) will give you all the information about the part for any compliance need, including PFAS. These FMDs will identify the substances used to make up a part, the CAS number of the substance, and the weight of the substance for calculating percentage by weight for any needed regulatory thresholds. This is the easiest way to identify if any of the listed CAS numbers are contained in any of the substance lists provided by regulatory bodies for restrictions or prohibitions. 

If FMDs are not available, certificates of compliance are another highly accepted option. However, you need to be wary of what the document is declaring. Ideally, it should reference a regulation, but in the case of PFAS, where regulations are changing and no one covers the entirety of the scope, you have to pay attention to the definition of PFAS given as well as the statements provided. 

Material drawings, standards, or safety data sheets may provide additional insight into the substances in the product, but these can be old and out of date, so it’s best to understand your documentation from your suppliers and decide the level of risk you are willing to justify.

Common PFAS names and synonyms in products

PFAS stands for per- and polyfluoroalkyl substances. Because chemical substances are often named for their chemical structure, oftentimes you will see “perfluoro” or “polyfluoro” in the substance name. Common examples of this are perfluorooctanoic acid (PFOA), perfluorooctane sulfonic acid (PFOS), perfluorohexane sulfonic acid (PFHxS), and perfluorononanoic acid (PFNA). 

However, it’s important to understand that some substances can be given brand or industry names, such as polytetrafluoroethylene (PTFE). PTFE is best known as Teflon or the expanded PTFE version known as Gore-tex. PTFE is probably the most popular PFAS used in electronics and can be denoted in any of the ways listed here. 

Chemicals can often have shortened names as well to make it easier to refer to a substance. A good example of this is N-ethyl perfluorooctanesulfonamide (NEtFOSA), which is often called Sulfuramid. Other documents may simply seek to remove any unnecessary or potentially confusing information and only list CAS numbers, which are unique to each substance, to cut down on misidentification of substances borne from spelling or pronunciation issues. CAS numbers are the quickest and easiest way to cross-reference substances to known PFAS cast lists, which can total up to over 14,000 substances.

Developing a PFAS risk assessment strategy

In order to be prepared for the challenges that emerging PFAS regulations will present, it’s important to establish and track your current PFAS usage by performing due diligence campaigns on your supply chain. It’s easiest to combine various definitions and substance lists of known PFAS to survey your suppliers to inquire if those particular substances are used in the manufacturing of parts you utilize in your own products. 

Full material declarations are the best way to determine the presence of these substances in your products. For gaps in the coverage for these products, you can look at your parts that may need the characteristics often associated with PFAS, such as water or heat resistance. 

Consulting with a material chemist or compliance expert can also help you develop a risk profile in order to make informed decisions about where you may find PFAS in your products. Additionally, chemical testing is another way to identify the use of these substances in your products, but it may prove to be costly and time-consuming. 

The best strategy is to combine all of the above suggestions into a PFAS compliance program. As regulations are introduced to relevant industries, you can then make the required decisions to replace parts to PFAS-free options or understand any reporting or labeling requirements you may be obligated to. This can help you maintain market access and avoid any costly non-compliance events.