Perfluorinated additives in food packaging

February 2, 2017

House Environment Committee
Washington State House
House Hearing Room B
John L. O’Brien Building
Olympia, WA 98504

To members of the House Environment Committee:

PCC Natural Markets is very happy to see House Bill 1744, an act relating to use of perfluorinated chemicals in food packaging — and the names of its five courageous sponsors. We are here to speak for consumers.

As the largest consumer-owned-and-operated grocer in the nation, we are here to represent the people who purchase products without knowing they may be contaminated by additives harmful to human and environmental health. Only the rare consumer would know of perfluorinated chemicals by name (a.k.a. perfluoroalkyl substances, PFASs) but I assure you, from 25 years of working closely with thousands of consumers across the public spectrum, I can say food shoppers absolutely do not expect and do not want harmful chemical additives to be leaching from packaging into the foods they purchase. Especially when not declared or labeled. They count on government to protect the public interest.

When people purchase a slice of pizza, or a cookie or donut, they have no reason to believe the take-out box or the parchment paper are shedding chemicals that peer-reviewed science shows can damage human and environmental health. When we learned these paper items from our stores tested positive for PFASs, we were surprised but prepared to take action.

PCC already has started developing standards for packaging to avoid PFASs — and other toxic chemicals from food contact, such as phthalates and bisphenols — wherever we control the packaging. We will seek substitutes that do not contain persistent contaminants.

In 2015, scientists published a paper concluding that the growing body of epidemiological evidence shows some of the health effects of some PFAS chemicals “are supported by significant or suggestive associations,” including testicular and kidney cancers (Barry et al. 2013; Benbrahim-Tallaa et al. 2014), liver malfunction (Gallo et al. 2012), hypothyroidism (Lopez-Espinosa et al. 2012), high cholesterol (Fitz-Simon et al. 2013; Nelson et al. 2009), ulcerative colitis (Steenland et al. 2013), lower birth weight and size (Fei et al. 2007), obesity (Halldorsson et al. 2012), decreased immune response to vaccines (Grandjean et al. 2012), and reduced hormone levels and delayed puberty (Lopez-Espinosa et al. 2011).

The statement concludes, “We call on the international community to cooperate in limiting the production and use of PFASs and in developing safer non-fluorinated alternatives” in order to avoid long-term harm to human health and the environment. It urges governments, purchasing
organizations, retailers, and consumers to take the following actions:

The paper calls on governments to:

1. Enact legislation to require only essential uses of PFASs and enforce labeling to indicate uses.
2. Require manufacturers of PFASs to
a. conduct more extensive toxicological testing
b. make chemical structures public
c. provide validated analytical methods for detection of PFASs
d. assume extended producer responsibility and implement safe disposal of products and stockpiles containing PFASs.
3. Work with industry to develop public registries of products containing PFASs.
4. Make public annual statistical data on production, imports and exports of PFASs.
5. Whenever possible, avoid products containing, or manufactured using, PFASs in government procurement.
6. In collaboration with industry, ensure that infrastructure is in place to safely transport, dispose of, and destroy PFASs and PFAS-containing products, and to enforce these measures.

The statement calls on chemical manufacturers to:

1. Make data on PFASs publicly available, including chemical structures, properties and toxicology.
2. Provide scientists with standard samples of PFASs, including precursors and degradation products, to enable environmental monitoring of PFASs.
3. Work with scientists and governments to develop safe disposal methods for PFASs.
4. Provide the supply chain with documentation on PFAS content and safe disposal guidelines.
5. Develop nonfluorinated alternatives that are neither persistent nor toxic.

The statement calls on product manufacturers to:

1. Stop using PFASs where they are not essential or when safer alternatives exist.
2. Develop inexpensive and sensitive PFAS quantification methods for compliance testing.
3. Label products containing PFASs, including chemical identity and safe disposal guidelines.
4. Invest in the development and use of non-fluorinated alternatives.

The statement calls on purchasing organizations, retailers, and individual consumers to:

1. Whenever possible, avoid products containing, or manufactured using, PFASs. These include many products that are stain-resistant, waterproof, or nonstick.
2. Question the use of such fluorinated “performance” chemicals added to consumer products.

These are the recommendations of a collaborative of scientists and their peer-reviewed work published by
the National Institutes of Health.

We urge you to heed their advice as the only responsible choice.

We support House Bill 1744 and thank you for the opportunity to comment.

Trudy Bialic

Director, Public Affairs
PCC Natural Markets

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