Safer Products

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Proposed Priority Product: Food Packaging Containing Perfluoroalkyl or Polyfluoroalkyl Substances

DTSC proposes to list one or more plant fiber-based food packaging containing perfluoroalkyl or polyfluoroalkyl substances (PFASs) as Priority Products under the Safer Consumer Products (SCP) regulations. PFASs are a class of chemicals characterized by highly stable carbon-fluorine bonds and used in many applications, including plant fiber-based food packaging.

Based on the criteria in the Safer Consumer Products regulations, DTSC has determined that plant fiber-based food packaging products containing PFASs have the potential to cause or contribute to significant and widespread adverse impacts to sensitive subpopulations, including fetuses, infants, young children, and workers; to environmentally sensitive habitats; and to threatened and endangered species. Given the known hazard traits, replacing currently used PFASs in food packaging with other members of the PFAS class could constitute a regrettable substitution. Hence, this proposal covers plant fiber-based food packaging containing any member of the class of PFASs.

Plant fiber-based food packaging products commonly found in restaurants, grocery stores, and homes are often treated with PFASs for grease, oil, or water resistance. These products can expose humans and biota to PFASs during their manufacturing, use, and end-of-life. PFASs can migrate from food packaging into the packaged food, with migration rates dependent on the temperature, acidity, storage time, and fat content of the food. Used PFAS-treated food packaging products are sometimes composted, releasing PFASs into the compost. When used food packaging is sent to a landfill, the PFASs can migrate into landfill leachate, contaminating surface waters and the surrounding environment. When applied to soil as fertilizers, biosolids from wastewater treatment plants that treat PFAS-contaminated landfill leachate can contaminate drinking water sources and food crops. Recycled products made from PFAS-treated paper, paperboard, and molded fiber food packaging can also be a source of PFAS exposure. Harmful PFAS combustion products may also be released when these products are incinerated.

Exposure to PFASs can lead to adverse health outcomes in humans. If humans are exposed to PFASs through diet, drinking water or inhalation, some of these chemicals remain in the body for a long time. As people continue to be exposed to PFASs the levels in their bodies may increase to the point where they suffer from adverse health effects. Studies indicate that some PFASs can cause reproductive and developmental, liver and kidney, and immunological effects, as well as tumors in laboratory animals. The most consistent findings from human epidemiology studies are a small increase in serum cholesterol levels among exposed populations, with more limited findings related to infant birth weights, effects on the immune system, cancer, and thyroid hormone disruption. Some PFASs have also been linked to phytotoxicity, aquatic toxicity, and terrestrial ecotoxicity.

Public Comment Period

To view comments regarding this proposal, please visit the CalSAFER site. Input from the workshop and public comment period will be taken into consideration as the Department finalizes the Product-Chemical Profile in preparation for rulemaking.

Public Workshop

DTSC hosted a virtual workshop to receive public input on August 31, 2020, following an introductory workshop on January 14th, 2020. DTSC will consider both verbal input at the public meeting and written comments submitted during the public comment period as we continue to refine our Priority Product definition and listing.

Below are downloads related to this workshop:

SCP Priority Products