About one year ago, the US Environmental Protection Agency (EPA) along with the Commonwealth of Massachusetts became aware of a previously unknown, potential per- and polyfluoroalkyl substances (PFAS) issue. Fluorinated high-density polyethylene (HDPE) containers containing a mosquito-control pesticide were leaching PFAS into the product.
PFAS in Certain Containers with Insecticides
By January 2021, EPA obtained data that some mosquito-control pesticides contained detectable levels of certain PFAS. The EPA is now testing different brands of fluorinated containers to determine whether they contain and/or leach PFAS and has asked the states with existing stocks of these pesticides to discontinue use as EPA evaluates the issue. EPA also began working with US Department of Agriculture (USDA) and US Food and Drug Administration (FDA) to get a better understanding of the use of fluorinated polyethylene containers for pesticides and other products (Source: Hunton Andrews Kurth).
According to Chemical Engineering and News, “An assortment of toxic per- and polyfluoroalkyl substances (PFAS) migrated into Anvil 10+10 from containers made of high-density polyethylene (HPDE) treated with fluorinated compounds and used to store and transport the pesticide, the EPA says. Anvil 10+10 is a synthetic pyrethroid insecticide used to control mosquitoes. It is sprayed in at least 25 states, according to the advocacy group Public Employees for Environmental Responsibility (PEER), which was instrumental in discovering the contamination.”
Concern about PFAS in some containers prompted a letter from FDA regarding fluorinated polyethylene food contact articles. (Photo by Elena Rabkina on Unsplash).
FDA Issues a Letter
Seemingly prompted by the news of PFAS in certain containers, on August 5, 2021, the FDA issued a letter to manufacturers, distributors, and users of fluorinated polyethylene food contact articles.
In this letter, the FDA states in part, “Recently, based on testing performed by the Environmental Protection Agency (EPA), FDA has become aware that certain per- and polyfluoroalkyl substances (PFAS) can form and migrate from some fluorinated high-density polyethylene (HDPE – a type of polyethylene) containers. EPA’s testing was conducted on containers that are not regulated by FDA (containers intended to hold mosquito-controlling pesticides not approved for direct use on food crops). However, we are concerned that such containers could also be used in contact with food. The specific PFAS detected in EPA’s testing are perfluoroalkyl carboxylic acids (PFCAs). Several of these PFCAs are either known or suspected to biopersist in humans and are associated with adverse health effects. Analytical studies find that PFCAs can form when the fluorination of HDPE occurs in the presence of oxygen or water, but not in the presence of nitrogen. As noted above, FDA’s regulation does not authorize fluorination of polyethylene containers in the presence of water, oxygen, or gases other than nitrogen.”
EPA Issues Testing Methodology for Oily Matrix
On September 29, 2021, EPA released an internally-validated method for detecting 28 PFAS compounds in oily matrices. The method is intended to help pesticide manufacturers, state regulators, and other interested stakeholders test pesticide products formulated in oil, petroleum distillates, or mineral oils for PFAS.
The universe of potentially PFAS contaminating activity is continuing to grow. Accordingly, if a regulator suspects your facility of creating or contributing to PFAS contamination, proceed with caution as you should investigate potential sources with diligence.
For more information on PFAS, see our PFAS Resources Page.
If you need help with an environmental issue, you can reach us at info@dragun.com or call our office at 248-932-0228. You can also contact our Senior Vice President, Jeffrey Bolin, M.S. at extension 125.
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