“One challenge to effectively evaluating the potential impacts of PFASs as well as cleaning up priority sites is that there is very little information on where these chemicals are being used. Through a Freedom of Information Act (FOIA) request to FDA, EDF obtained documents previously not made public that show that paper mills using PFASs may be a significant source of contamination to water and potentially to air and compost.

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.[1] FDA approved each notice, allowing the companies to sell their PFASs to make paper and paperboard repel oil and grease in food packaging such as pizza boxes, sandwich wrappers, and microwave popcorn bags. All four assessments based their estimates on what they called a ‘typical’ paper mill that produces 825 tons of PFAS-coated paper per day and discharges 26 million gallons of water per day.[2]

  • Chemours FCN 885 estimated 95 pounds/day of its PFAS[3] in the wastewater discharge at 43,000 ppt.
  • Chemours FCN 1027 – a notification for the same PFAS – increased the amount in paper from 0.42% to 0.8% resulting in 183 pounds per day in the wastewater discharge at 83,000 ppt.
  • Daikin FCN 933 estimated 180 pounds/day of its PFAS[4] in the wastewater discharge at 83,000 ppt.
  • Daikin FCN 1044 estimated 225 pounds/day of a similar PFAS[5] in the wastewater discharge at 103,000 ppt.

The two companies also estimated that nine pounds of PFASs would end-up in biosolids for each pound released to water and that these materials would go to a sanitary landfill or be incinerated. There was no mention of biosolids being composted. None of the assessments considered impacts from the manufacturer of the PFASs or estimated air emissions from their uses.

From 2002 to 2016, FDA approved a total of 25 FCNs[6] for 14 unique PFASs to treat paper including the ones described above. The other PFAS manufacturers were Archroma, Asahi Glass, Solenis, and Solvay Specialty. 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. In addition, we would expect to find similar discharges for PFAS-treated paper used for purposes other than food, although the numbers would vary based on levels used in the final product.[7] Click here for a list of the 25 FCNs and related environmental documentsprovided by FDA…

We do not know the location of the paper mills using any of the FDA-approved PFASs. 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. We divided the estimated pounds of PFAS per day in the wastewater discharge by the average daily flow of the river at its mouth. Based on this calculation, the following are rivers that would exceed 70 ppt:

Read the full report by Tom Neltner, J.D., and Maricel Maffini, Ph.D.