Evaluating Alternatives to Food Packaging Materials that Contain Per- and Poly-Fluorinated Substances (PFASs)

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From the Executive Summary:

This report provides a roadmap for conducting a full alternatives assessment (AA) for food packaging that is free of per- and poly-fluoroalkyl substances (PFASs) and identifies some currently available alternatives (see supplemental file). The roadmap follows the IC2 Alternatives Assessment Guide (2017) with additions from Northwest Green Chemistry’s experience creating frameworks and conducting AAs, such as minimum (‘showstopper’) criteria defined for each module. The report includes ways to leverage modules completed by other entities, how to test for PFASs, and how to identify PFASs-free alternatives using state procurement policies. Strategic steps forward in a resource constrained and imperfect information environment will allow Oregon Department of Environmental Quality to make the most of the Roadmap.

NGC’s priority selection criteria to scope an alternatives assessment based on the modules are:

  • OR DEQ should employ best practices for stakeholder engagement to enable improved problem definition, information gathering, results, and adoption of results. Key stakeholders provide insight from their perspectives that may not be initially apparent to researchers. Key stakeholders include representatives from food packaging manufacturers, users, retailers, and innovators. Government agency staff, industry/trade groups, nonprofits, and politicians will also bring a unique set of concerns and knowledge to the issues.

  • Based on NGC’s work identifying AA best practices, we recommend a decision analysis method similar to the IC2 hybrid method. This method presents acceptable alternatives in a selection guide to promote informed decision-making based on stakeholder’s varying application needs. Acceptable alternatives are those that meet minimum criteria for each module. Once these criteria are met, then the options should be subject to user preferences and needs.

  • Hazard module recommendations include information on how to scope a chemical inventory, using a tiered approach to chemical hazard assessment, and with special considerations for polymers. The hazard module also includes showstopper criteria and guidance for identifying safer alternatives.

  • NGC recommends setting a limit on exposure based on the hazards of the chemicals in question to eliminate unacceptable alternatives. A comparative exposure approach should be used to address exposure to workers, customers, and environmental receptors.

  • Cost and availability module recommendations include comparing the retail price of PFASs-containing products and the alternatives. Cost should not be used to eliminate alternatives as any product currently available on the market is at a reasonable price point for at least some users. Cost should be considered across the life cycle to include costs from waste management. Economic analysis across the life cycle would present the full picture of hidden costs, e.g. cleanup and health impacts of PFASs, though it is likely cost prohibitive for the initial AA.

  • We recommend using stakeholder input to define performance criteria for different uses that include minimum requirements and performance tests. Diverse users should be engaged, including from restaurants, cafeterias, caterers, hospitals, schools, prisons, and consumers, etc.

  • The goal of the social impact module is to ensure that the product(s) preferred by the alternatives assessment do not shift the burden from one community of people to another unduly. Organizations that should be involved in the social impact module in Oregon are OPAL Pdx, Beyond Toxics, and the Environmental Justice Task Force, among others.

  • To address the materials management module, a holistic consideration of the product from feedstock to end of life should be conducted. This includes impacts from feedstocks used and wastes generated and managed, as well as a consideration of how the product may fit into the circular economy.

  • The overall goal of the life cycle module is to take a comprehensive view of product impacts across the life cycle, to identify opportunities for innovation and improvement, and to avoid burden-shifting. This module builds on results from previous modules and considers how the product fits within the broader system. Life cycle thinking helps to identify hot spots and opportunities for innovation. Life cycle assessment is important for verifying assumptions.

This report does not include gathering data and reporting the results of an alternatives assessment. However, the researchers have compiled information on alternatives gathered by NGC and building on the work of other groups. A variety of alternatives exist for each packaging technology type and are laid out by material types, molded fiber technologies and coatings and other treatments. The report includes a technology map, a table of alternatives representing each technology a supplemental Excel file with extensive detail on the product, its manufacturer, and PFASs screening test results if available.

Some Recommended Next Steps:

An AA report is a snapshot in time and should be accompanied by an implementation plan. The plan should include strategies and resources for ongoing identification and evaluation of emerging alternatives, for driving and measuring adoption of alternatives, and for integrating other important information. Novel information may emerge over time including new toxicology studies, changes in economics, and new waste management methods. Oregon should consider collaborating with other governmental agencies and key stakeholders to create an implementation plan for the proposed AA. Additional recommendations for next steps include:

  • Publicly state Oregon’s priorities for PFASs free products. For example, as with a waste hierarchy, and consistent with OR’s materials management vision, OR DEQ could state that its priorities are 1) to avoid products with hazardous chemicals to which people and the environment will be exposed across the product life cycle and 2) to promote a circular economy that eliminates waste at the source and recovers materials at the highest possible value for reuse. This will clarify how existing statements on sustainability apply to food packaging.

  • Develop promotional and educational materials for diverse users explaining the issue and describing how to select PFASs-free alternatives.

  • Identify additional classes of chemicals to eliminate. For example, ortho-phthalates have been identified by the Food Packaging Forum as a priority for replacement in food packaging.

  • Create or revise procurement policies to purchase PFASs-free food packaging. Appendices A, B and C in this report provide detailed information, including pros and cons, of test methods, standards and certifications. Some certifications exclude PFASs and others do not. The European standards based on EN13432, generally exclude PFASs due to a 100 ppm fluorine limit, while US standards do not. However, some US standards (i.e. BPI certified compostable) are being updated to address this issue.

  • Identify products as PFASs-free by:

    • Testing and making a list of PFASs-free options available in Oregon.

    • Using the CEH list as a starting point, but keep it updated, as products change over time.

    • Using compostability/biodegradability certifications such as TÜV AUSTRIA Seedling Logo or post-2019 BPI compostable that also include limits for fluorine.

    • Consider supporting or developing a certification for simply PFASs-free products, as the compostability/biodegradability portion of these certifications is not relevant to Oregon currently due to Oregon composters declining compostable food packaging.