Inhance Technologies’ Statement in Response to EPA’s Section 6 Approach on Fluorination of Plastic Containers

HOUSTON, July 12, 2024 – Inhance Technologies welcomes the opportunity to engage with the United States Environmental Protection Agency (EPA) regarding today’s announcement that EPA will commence a proceeding under Section 6 of the Toxic Substances Control Act (TSCA) to further evaluate the fluorination of plastic containers. In particular, EPA has stated its intent to solicit information on this technology, including how fluorinated containers are used and whether measures may be appropriate to address any potential risk due to minute impurities of some perfluoroalkyl and polyfluoroalkyl substances (PFAS) that may be generated by use of the technology. Nothing in EPA’s announcement indicates that the agency has made a decision to ban or restrict the fluorination of plastic containers or the sale or use of such containers.

Inhance Technologies will work with EPA, along with others in the industry, to provide information about the fluorination of plastic containers. We are confident that Inhance Technologies’ fluorination technology does not present a risk to the public or the environment. In fact, fluorination of plastic containers provides important benefits to the national economy. For example, as compared to other barrier technologies, fluorination is less resource intensive and has a lower carbon footprint. Additionally, the strong and consistent barrier provided by the fluorination process also prevents human and environmental exposure to volatile chemicals that are stored in fluorinated articles during transportation, storage, and use. 

EPA took this action in response to a citizen petition, filed by environmental groups, that seeks an immediate ban on the use of fluorination of plastic containers based on the baseless allegations that the technology poses an unreasonable risk. These environmental groups seek to deny access to fluorinated containers, which are critical to many industries from healthcare to crop protection, and whose supply chain partners would be left without viable alternatives for effective barrier protection, including for applications such as vaccines, pesticides, and fuel systems. 

Inhance shares EPA’s interest in ensuring that any risks associated with three specific PFAS compounds – perfluorooctanoic acid (PFOA), perfluorononanoic acid (PFNA), and perfluorodecanoic acid (PFDA) – are appropriately evaluated and managed consistent with TSCA and the agency’s own regulations. To the extent such compounds are inadvertently formed during the fluorination process, they are only formed as impurities at minute concentrations.  Inhance is confident that any further evaluation of the potential risk associated with these compounds by EPA will conclude that there is no unreasonable risk associated with the use of fluorinated containers.

Background
The fluorination process utilizes only fluorine and inert gases. No PFAS – including PFOA, PFNA, and PFDA – are used at any point during Inhance Technologies’ fluorination process. To the extent that any PFOA, PFNA, or PFDA may be produced during the fluorination process, such amounts are unintentionally formed at very low concentrations as impurities, are not separable from the polyolefin plastic containers, serve no functional purpose, and have no commercial purpose or value. Concentrations of PFOA, PFNA, or PFDA remaining on articles following fluorination, if any, are exceptionally low, and the total annual volume of PFAS compounds unintentionally formed by fluorination processes is miniscule compared to other sources of these PFAS.