Prohibiting PFAS Chemicals – Call for Comment
12/8/2021 | Brittany Maule
Green Seal is proposing a new prohibition on per- and polyfluoroalkyl substances, or PFAS, a large class of chemicals that are commonly used in consumer products and associated with a number of adverse health and environmental effects.
Although only seven PFAS are formally classified as hazardous, a growing body of evidence indicates that all PFAS are likely to have harmful health and environmental effects. While Green Seal has long prohibited those seven PFAS, as part of Green Seal’s precautionary approach, we are now proposing to prohibit all chemicals in this class (approximately 12,000 PFAS) in certified products.
It can be challenging for consumers and even manufacturers to be sure that products do not use PFAS. For example, PFAS are often used in raw materials – and those proprietary formulas are often not fully disclosed to the final manufacturer. A prohibition on PFAS would allow Green Seal to verify that these chemicals are eliminated from these product supply chains and provide assurance to both manufacturers and buyers that their Green Seal certified cleaning and personal care products are PFAS-free.
Green Seal is taking a multi-year phased approach to this initiative, with the end goal of ensuring all certified product formulas and product packaging are PFAS-free across product categories. In this initial phase, our focus is on eliminating PFAS in formulas for certified cleaning and personal care products.
What are PFAS?
PFAS are a large group of synthetically produced chemicals that have a history of use dating back to the 1940s. PFAS have carbon-fluorine bonds that make them very stable and effective at repelling oil, water and heat. Today they are found in food packaging, coatings, paints, textiles, cookware, and even some cleaning products.
Unfortunately, the same unique chemical structure that makes PFAS so effective is also what gives them the moniker “forever chemicals.” PFAS are persistent in the environment, with evidence that some chemicals are so resistant to degradation that they could persist for hundreds of years. They also bioaccumulate in soil, drinking water and in humans, with some chemicals taking more than eight years to reach their half-life — or reduce their concentration by 50 percent in the human body.
PFAS are associated with numerous adverse health effects, including impacts on the endocrine and reproductive systems; increased risks of certain cancers such as prostate, testicular, and kidney; and decreased immune responses — including our body’s ability to develop beneficial antibodies in response to vaccines.
While two of the approximately 12,000 PFAS have been phased out of use in the U.S., evidence shows that the “safer substitutes” (other PFAS) also cause harmful health effects. Therefore, Green Seal is proposing to prohibit all chemicals classified as PFAS by the US EPA’s comprehensive CompTox PFAS Master List database — an evolving list that aggregates PFAS based on environmental occurrence, manufacturing process data, and testing programs from agencies across the globe.
Eliminating all PFAS from the supply chain for consumer and professional care products is a critical step in protecting human health and ending the environmental contamination caused by releases of these chemicals.
Recognizing an opportunity to increase supply chain transparency and encourage the use of safer alternatives, Green Seal is proposing to add criteria prohibiting PFAS to our standards for cleaning products and personal care products. These proposed updates include:
- Prohibiting any intentionally added PFAS
- Restricting any PFAS to 100ppm when present as a contaminant
The PFAS criteria will be added to the product health and environmental requirements section of each of the following standards:
- General Purpose Cleaners (GS-8, GS-37)
- Laundry Care Products (GS-48, GS-51)
- Specialty Cleaners (GS-52, GS-53)
- Personal Care Products (GS-44, GS-50)
The public comment period is now open until January 22, 2022. To submit comments or schedule a conference call, contact us by email at email@example.com.
The Proposed Revisions and supplementary documents are available on Green Seal’s Standard Revisions page.
Green Seal’s reputation for credibility and market impact rests on an open and transparent process for developing and revising our science-based standards. All major standard revisions include extensive stakeholder outreach and opportunities for public input. Green Seal publishes all formally submitted comments, as well as a response to each substantive issue identified by commenters.