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What is PFAS?

Perfluoroalkyl and polyfluoroalkyl substances (collectively known as PFAS) are manmade chemicals used in many industries to make products waterproof, non-stick, and stain resistant. Some examples of products that may contain PFAS include: firefighting foam, carpet, furniture, waterproof clothing, plumbing supplies, medical equipment, cosmetics, consumer household goods, and certain types of food packaging. These chemicals are often described as “forever chemicals” because they do not break down over time and can build up in the environment and in our bodies.

Why is PFAS a problem?

Repeated exposure over time leads to PFAS accumulating in the human body, and exposure has been correlated with adverse health outcomes in humans. Certain types of PFAS have been in use since the 1940s for industrial applications, and PFAS have been used in food contact applications since the 1960s. According to the U.S. Centers for Disease Control (CDC), there is evidence that increases in exposure to certain PFAS can lead to increased cholesterol levels, changes in liver enzymes, small decreases in birth weight, lower antibody response to some vaccines, pregnancy-induced hypertension and preeclampsia, and kidney and testicular cancer.

PFAS can contaminate the environment in many different ways. When aqueous film-forming foam (AFFF) is used for training or to fight fires, it soaks into the ground and can contaminate groundwater and drinking water and eventually migrate to the ocean. PFAS accumulate in landfills from food packaging, personal and household products, and can also contaminate groundwater, drinking water, and the ocean. PFAS can accumulate in wastewater from personal and household product use. They are not filtered out during treatment and can be discharged into the ocean with the treated wastewater. Some treated wastewater containing PFAS are reused to irrigate golf courses, agricultural fields, and road medians.

Because structurally stable forms of PFAS are not easily broken down over time when exposed to environmental elements like ultraviolet sunlight, the forms that remain in the environment may lead to bioaccumulation in plants and animals that are then consumed by humans. Over time, these forms can continue to affect human health as people take in more PFAS than are excreted, leading to further bioaccumulation in the body even long after PFAS are phased out.

There are thousands of different types of PFAS, but only a small number have been evaluated for their risk to human health and the environment. Furthermore, there is little toxicity or safety data for most of the commonly used PFAS chemicals, including those that have been used in food packaging. When the National Health and Nutrition Examination Survey (NHANES) tested the blood of volunteers in 2016, they concluded that 98% of Americans have detectable PFAS in their blood. PFAS have also been found in fish, Hawaiian monk seals, sea turtles, whales, and dolphins around Hawai‘i.

What are authorized uses of PFAS in food contact applications?

Since the 1960s, the U.S. Food and Drug Administration (FDA) has authorized PFAS use in certain specific food contact applications. PFAS are allowed for non-stick coating applications; sealing gaskets for food processing equipment; manufacturing aids; and grease-proof agents for paper food packaging. However, current data indicate that paper and paperboard agents containing PFAS would result in dietary exposure to PFAS that may result in potential safety concerns. In February 2024, the FDA announced that substances containing PFAS used as grease-proofing agents on paper and paperboard for food contact use are no longer being sold by manufacturers in the U.S. market. At this time, the manufacturing processes and structure of PFAS chemicals used in the other three authorized uses have been determined to result in negligible amounts of PFAS migration.

How can PFAS contaminate food?

The most common ways that food can become contaminated with PFAS include contact with grease-resistant or water-resistant food packaging made with PFAS; contact with non-stick cookware when used contrary to the manufacturer’s recommendations (i.e., cook at medium and low temperatures as high heat may release PFAS into the food or the air, use wooden cooking utensils to prevent scratching the coating, as scratches can promote the release of PFAS); and by bioaccumulation of PFAS through the environment. Fish can accumulate PFAS through their diet and from the surrounding water, and produce can accumulate PFAS from contaminated soils or by irrigating with PFAS-contaminated water.

Why does the FDA allow PFAS to be applied to food contact surfaces, like non-stick pans?

PFAS approved for use in the manufacturing of non-stick cookware coatings consist of polymerized molecules (i.e., joined together to form large chains), that are applied through a heating process that tightly binds the polymer coating to the cookware. Studies show that this coating contains a negligible amount of PFAS capable of migrating to food (when used according to the manufacturer’s recommendations). Similarly, the PFAS used in manufacturing of gaskets that come into contact with food are also made of polymerized molecules.

What levels of dietary PFAS exposure cause adverse health effects in humans?

Most of the research on the effects of PFAS on human health are based on two types of PFAS, perfluorooctanoate (PFOA) and perfluorooctane sulfonate (PFOS). However, there are thousands of different specific PFAS chemicals, hundreds of which are used in industrial and consumer products with very different chemical structures and chemical and physical properties. The associated health effects for most of these different PFAS types are unknown. Therefore, filling this knowledge gap is a top research priority for State and federal agencies, including the Department of Health (DOH).

What is the federal government doing to reduce PFAS exposure in food?

In 2020, the FDA worked with manufacturers to voluntarily phase-out of their sales of compounds that contain 6:2 FTOH (short-chain polyfluoroalkyl PFAS).

In 2024, the FDA announced that grease-proofing materials containing PFAS are no longer being sold for use in food packaging in the U.S. A major source of dietary exposure to PFAS from food packaging like fast-food wrappers, microwave popcorn bags, take-out paperboard containers, and pet food bags is being eliminated.

Also in 2024, the U.S. Environmental Protection Agency (EPA) issued the first-ever national, legally enforceable drinking water standard to protect communities from exposure to six harmful types of PFAS.

What is DOH doing to reduce PFAS exposure in food?

Act 152, Relating to Environmental Protection, was signed into law in 2022. In addition to prohibiting the manufacture, sale, distribution, and use of Class B firefighting foams that contain PFAS (with certain exceptions), the law also prohibits the manufacture, sale or distribution for sale, or use of food packaging that contain PFAS, effective December 31, 2024. DOH’s Food and Drug Branch (FDB) will be conducting outreach to inform local stakeholders about Act 152 and promote food packaging alternatives to meet Act 152’s prohibition.

DOH’s Safe Drinking Water Branch (SDWB) has been testing for PFAS in drinking water for several years and is implementing sampling requirements for all purveyors to meet the 2024 EPA drinking water standards.

DOH’s Hazard Evaluation and Emergency Response (HEER) Office is investing resources to evaluate the impact of PFAS on our environment. This includes conducting the following studies:

• PFAS in fish and seawater in the nearshore environment;
• PFAS in frequently eaten fish purchased from local markets;
• PFAS in wastewater, biosolids, and landfill leachate;
• PFAS in drinking water;
• PFAS in Red Hill groundwater monitoring wells; and
• PFAS in compost and food crops grown in compost.

What products are banned?

Food packaging that contains PFAS are prohibited. “Food packaging” is defined in Act 152 as a “package or packaging component that is applied to or in direct contact with any food or beverage and is comprised, in substantial part, of paper, paperboard, or other materials originally derived from plant fibers.” Wraps and liners, plates, clamshells, food boats, and pizza boxes are all types of food packaging that cannot contain PFAS.

Who does this affect?

Manufacturers, kitchen supply distributors, retailers, wholesalers, and end users of these food packaging products – primarily restaurants and food establishments.

When does this ban take effect?

December 31, 2024. If you use PFAS coated food packaging products, please use up your existing stock and order compliant packaging going forward.

Are other states banning PFAS in food packaging?

Yes. In addition to Hawaiʻi, 11 other states have banned or have enacted phase-outs of PFAS in food packaging: California, Colorado, Connecticut, Maine, Maryland, Minnesota, New York, Oregon, Rhode Island, Vermont, and Washington.

Are there alternatives available?

Because states with large economies have enacted similar bans, like California and New York, the market for alternatives has grown exponentially in recent years. This has been accelerated with the FDA’s recent efforts to phase out the use of PFAS in food packaging. To comply with Act 152, look for PFAS-free labels or verify the country of origin – food-grade packaging manufactured in the U.S. should no longer contain PFAS. You can also request a certification from your distributor that the packaging is compliant.

Alternative packaging products include uncoated paper products, foil or foil-lined products, bioplastic or bioplastic-foamed products, molded fiber products with bioplastic linings, paper container products (i.e., clamshells or boats) with clay, wax, or bioplastic coatings, and/or paper sheets and bags with wax or bioplastic coatings. Bioplastics are manufactured using vegetable fats or oils, corn starch, and other renewable sources. Please also note any local county ordinances that prohibit petroleum-based plastic food packaging, such as the City and County of Honolulu’s Disposable Food Ware Ordinance.

What can you do to reduce PFAS exposure at home?

Because products containing PFAS are ubiquitous, it is difficult to completely eliminate exposure to all PFAS at this time. However, simple steps to reduce exposure include replacing household products with alternatives that do not contain PFAS. Use waxed dental floss, bio-based cosmetics, look for PFAS-free water-resistant clothing, and use non-stick cooking utensils properly, including replacing any non-stick cookware that is scratched or damaged. In general, purchase products from a reputable source or manufacturer and review certifications posted online.

Where can I find more information on PFAS?

Sources and additional information can be found at the following websites:

Hawaiʻi State Department of Health Hazard Evaluation and Emergency Response Office:
https://health.hawaii.gov/heer/environmental-health/highlighted-projects/pfas/

United States Food & Drug Administration:
https://www.fda.gov/food/environmental-contaminants-food/and-polyfluoroalkyl-substances-pfas

United States Environmental Protection Agency:
https://www.epa.gov/pfas

United States Centers for Disease Control:
https://www.atsdr.cdc.gov/pfas/index.html

United States National Institute of Environmental Health Sciences:
https://www.niehs.nih.gov/health/topics/agents/pfc