In the nearly 900 documents we received from FDA, we found environmental assessments in four Food Contact Substance Notifications (FCNs) submitted in 2009-2010 by two companies, Daikin America and Chemours.
Daikin FCN 1044 estimated 225 pounds/day of a similar PFAS[5] in the wastewater discharge at 103,000 ppt.
While we do not have the environmental assessments for the other FCNs, we would expect the discharges from paper mills using these PFASs to be similar to estimates provided by Daikin America and Chemours.
Through an EPA permit database, we identified 269 pulp and paper mills that discharge directly to a river; 42 discharged more than 26 million gallons per day of wastewater described by the “typical” mill in Chemours’ and Daikin America’s environmental assessment.
For perspective, we looked at the rivers downstream of some of those 42 paper mills and calculated the potential impact using the estimates provided by Daikin America in its FCN 1044, the FCN with the largest numbers.
FDA’s environmental review of PFAS Pursuant to the National Environmental Policy Act (NEPA), FDA is obligated to consider the environmental implications of its decisions to approve the use of food additives including chemicals used to make food or substances that contact food.
One substantial change was to grant categorical exclusions from the general requirement that companies conduct an environmental assessment.
Final thoughts and some recommendations Given the concerns that other forms of PFAS pose similar health risks as PFOA and PFOS, and the potential levels that might be seen in rivers downstream from paper mills using any of the 14 PFASs approved by FDA, we think identifying the paper mills using these chemicals should be a priority.
We are also concerned about FDA’s process.
1071022-26-8) [6] FDA approved six additional FCNs from Chemours for PFASs used to make molded parts for repeat-use food contact articles such as gaskets for food processing equipment and food containers.