From The EPA:
Dear Manufacturers, Processors, Distributors, Users, and Those that Dispose of Fluorinated Polyolefin Containers:
The U.S. Environmental Protection Agency (EPA) is directing this information to manufacturers (including importers), processors, distributors, users, and those that dispose of fluorinated high-density polyethylene (HDPE) containers and similar plastics (i.e., fluorinated polyolefins). EPA was made aware of and determined via testing that certain per- and polyfluoroalkyl substances (PFAS) have formed and migrated from these fluorinated polyolefins.1 The contamination was first noted in HDPE containers used to store and transport a pesticide product.2 As the Agency continues to determine the potential scope of the use of this fluorination process outside of its use for pesticide storage containers, EPA is issuing this letter to: (1) remind industry of this issue to help prevent unintended PFAS formation and contamination and (2) emphasize the requirement under the Toxic Substances Control Act (TSCA) as it relates to PFAS and fluorinated polyolefins. These efforts are in line with EPA’s recently released PFAS Strategic Roadmap, which includes ambitious steps to further the science and research to restrict these PFAS from impacting human health and the environment.3
Fluorinated Polyolefins Containers and PFAS Formation. The process of fluorinating polyolefins involves the modification of certain types of polymers (plastics), using fluorine to create a high-performance barrier that is meant to mitigate permeation through container walls, as well as protect against environmental weathering and degradation of the plastic. Fluorination can occur before or after the shaping process of the HDPE containers or similar plastic and the fluorinated containers can be used to store and transport a variety of products.
It is during certain types of fluorination (e.g., the presence of oxygen) that the manufacture of PFAS has occurred. Manufacturers (including importers), processors, distributors, users, and those that dispose of fluorinated HDPE containers should be reminded of this potential for manufacturing PFAS and comply with any applicable regulations under TSCA, as described in the next section.
EPA is aware of alternative fluorination processes that use fluorine gas in the presence of gaseous inert (e.g., nitrogen) without the presence of oxygen that could reduce the potential for unintentional manufacture of PFAS. These alternative processes for fluorination of polyethylene are highlighted in the U.S. Food and Drug Administration’s (FDA) August 2021 letter on this issue as it relates to food contact articles.4
1 U.S. EPA’s Analytical Chemistry Branch PFAS Testing of Selected Fluorinated and Non-Fluorinated HDPE Containers,
4 U.S. Food and Drug Administration’s August 2021 Letter: https://www.fda.gov/media/151326/download