Perflourinated compounds (PFCs - including PFAS) are:

• Often toxic to people & ecosystems
• Do not breakdown in the environment
• Can accumulate in our food chain
• Are used in products and manufacturing processes across the global economy

Whether they are ending up in our products intentionally or unintentionally (from contamination), they are a serious and material sustainability issue that demands action.

You can find a deeper dive on forever chemicals and why they're a real problem here.

1. Restrict their intentional use in your products

Problem: Companies don't know what ingredients are being used by their contract manufacturers and their suppliers.

Solution: Add them to your Restricted Substances List (RSL) and Manufacturing Restricted Substance List (MRSL) banning them from being added to your products as far up your value chain as possible.

Confirming at each manufacturing step is another reason supply chain traceability is essential for consumer and environmental safety.

2. Identify safer alternatives using a hazard-based approach

Problem: These chemicals are common ingredients in a lot of products because of their performance qualities.

Solution: Work to find safer alternatives using a hazard based (as opposed to a risk based) approach and a robust alternatives assessment framework.

Although this has proven to be difficult for some applications we need to continue to innovate and encourage solutions.

The outdoor gear market caught heat (legal and reputational) over the last couple of years for their use of PFAS in water proof clothing.

Companies like Patagonia and Fjallraven have started create solutions through safer chemistry innovation.

As with any complex challenge, optimizing solutions that are safer as well as being competitive in terms of cost and performance takes time.

We’re optimistic about these solutions, like Biosurfactants, a green chemistry win that contains microorganisms (bacteria, fungi, and yeast) to create a surface-active agent that can be used to replace forever chemicals for some applications.

3. Engage in supply chain due diligence

Problem: Your procurement process may not be effectively integrating your safety standard and chemicals management policies

Solution: Conduct robust due diligence before selecting a new contract manufacturer and/or suppliers.

This often includes engaging your internal procurement partners to build out supplier questionnaires and lists of required documentation.

4. Leverage your procurement process

Problem: Companies often don’t own and operate their manufacturing process, so how can they ensure these chemicals are not being used?

Solution: Updating your Contract Manufacturing (CM) agreements to include a chemical management section creates another line of defense to ban the use of these chemicals intentionally.

Make sure to include provisions related to purity testing for raw materials, data sharing, process chemistry, and other provisions that address both intentionally added ingredients and contaminants.

5. Provide strategic partner onboarding

Problem: Many contract manufacturers and suppliers are lagging in their ability to identify and address restricted chemicals.

Solution: Once you’ve selected a new contract manufacturer and/or suppliers plan on hosting a user-focused onboarding process that helps educate and familiarize their team with your requirements.

6. Establish a comprehensive testing process

Problem: Even with all the “paper” controls in place, PFCs can still make their way into products for a variety of reasons - often as contaminants.

Solution: Create an analytical testing standard operating procedure for higher risk ingredients and products to help verify that your approach is working.

This should include raw materials, ingredients, and finished products before launch.

Continue random spot testing for finished products currently in the market as appropriate.

Use third party accredited laboratories with experience analyzing for this class of chemicals.

7. Build a contingency plan

Problem: Even when following all of these best practices you may find yourself with forever chemicals in your products.

Solution: Build a plan for how you will address the presence of these chemicals internally and publicly.

What steps will you take to identify the source and address it?

How will you provide transparency on the issue in ways that maintain your credibility and consumer trust while reducing liability?

Obtaining accurate test results for PFAS and related chemicals continues to be very challenging.

From our experience this is true for the following reasons:

• There are thousands of individual chemicals in this class and very few of them have standard test methods available

• Few commercial laboratories have experience testing for these chemicals in consumer products

• The chemical composition of PFCs means that false positives can be obtained when fluoride or flourite are present but not PFCs

Companies are morally (and legally) responsible for the ingredients in their products.

Forever chemicals can have well documented effects on people, the planet, and our environment.